ML20054H886
| ML20054H886 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/23/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8206250138 | |
| Download: ML20054H886 (185) | |
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- O, BEFORE THE ATOMIC SAFETY,AND LICENSING BOARD l
l In the Mattar cf: :
LONG ISLAND LIGHTING COMPANY :
- DOCKET NO. 50-322-OL (Shoreham Nuclear Power Station) :
O CArr: June 23, 1982 PAGz5r: 5167 - 5339 AO: Riverhead, New York
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1 UNITED STATES OF AMERICh 2 NUCLEAR REGULATORY COMMISSIdN BEFORE THE ATOMIC SAFETY AND LICENSING'BOAHD
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5 In the Matter of s , .-
6 LONG ISLAND LIGHTING COMPANY a Docket No.,50-322-OL .
7 (Shoreham Nuclear Power Station) , \
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12 Riverhead, N Ev York 11901 ' '
13 Vednesday,' June 23, 1982 O 14 The hearing in the above-[ entitled ma tter
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15 reconvened, pursuant to recess, at 9 0'$'a.m.
16 BEFORE: Y, 17 LAWRENCE BRENNER, Chairman s 18 Administrative Judge ,
19 JAMES CARPENTER, Member [4 y x
20 Administrative Judge 'n V ,
21 PETER A. MORRIS, Member ,
22 Administrative Judge
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23 WALTER H. JORDAN, Assistant to .th e Board - .
24 Administrative Judge - -
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3 g ALDERSON F.FrOAl!43 COMPAhY,INC, ' N
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5168 l
l 1 APPEARANCES:
2 On behalf of Applicants 3 ANTHONY F. EARLEY, Esq.
4 T. S. ELLIS III, Esq.
. 5 Hunton & Williams 6 707 East Main Street 7 ,
Richmond, Va. 23212 8 On behalf of the Regulatory Staffs 9 RICHARD RAWSON, Esq.
10 Washingtott, D.C.
11 On behalf of Suffolk County:
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12 KARLA J. LETSCHE, Esq.
13 Kirkpatrick, Lockhart, Hill, 14 Christopher E Phillips 15 1900 M Street, N.W.
16 Washington, D.C. 20036 37 18 19 1
20
, 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
5169 1
SEE1EE1E 2 WITNESSES: DIRECT CROSS PEDIPECT RECPOSS BOARD 3
George F. Dawe, 4
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 5170 (Afternoon Session. . page 5261) 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) 13 By Ms. Letsche 5261 O- 14 15 'E E g I_ E I,T,,,E BOUND IN 16 NUMBER ' IDENTIFIED RECEIVED TRANSCRIPT 17 Suffolk County No. 20 5262 5318 5318 18 19 RECESSES:
20 Morning - 5219 21 22 Noon - 5260 23 Afternoon - 5301 O u 25 O
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3 JUDGE BRENNER: Good morning.
{
4 We have no preliminary matters. If the 5 parties have none, we will simply proceed with the cross 6 examination of Suffolk County.
7 Whereupon, 8 GEORGE F. DAWE, 9 GEORGE GARABEDIAN, 10 PIO W. IANNI, 11 ROBERT N. KASCSAK, 12 PAUL J. McGUIRE, 13 PAUL W. BIEGELHAUPT and 14 DAVID J. ROBARE, 15 the witnesses on the stand at the time of recess, having 16 been previously duly sworn, were examined and testified 17 further as follows:
18 CROSS EXAMINATION -- Resumed l 19 BY MS. LETSCHE:
20 Q Gentlemen, I will direct your attention to 21 page 60 of your prefiled testimony, pa rticu larly the l 22 Catecory J on that page, which is subtitled " Heavy l
l 23 Loads."
p) s_ 24 Who is conducting the study that is referenced 25 in this section of the testimony?
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() 1 A (WITNESS DAWE) Stone and Webster conducted 2 the studies that are referenced here, and it is 3 conducting the ongoing studies.
{
4 0 Those were and are being conducted in response 5 to an NRC request; is that correct?
6 A (WITNESS DAWE) The specific studies that are 7 being done, perhaps I should characterize them as -
8 reports that are being done, are being done in response 9 to NUREG-0612. The crane designs and so forth are 10 completed in the plant. What we are now doing is 11 providing the information that the Commission has 12 requested.
13 0 What techniques are you using, Mr. Dawe, in 14 providing the information for the staff?
15 A (WITNESS DAWE) Well, essentially we are 16 providing a report which formats the information in a 17 form that the regulatory staff can match directly to 18 NUPEG-0612. The basic crane and lifting rig designs j
19 were done and the considerations are' already gone into 20 them in terms of the pathways, the locations of lifts, 21 the time of lifts and so on. What we are doing at this 22 point is really compiling information that we already 23 have because it was part of our existing design to avoid
) 24 interactions due to heavy lifts.
25 So essentially what this refers to is the l )
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5172 0 1 peckeging =f 11 of thet informetion for ett of the 2 heavy lifting throughout the p1 ant.
3 JUDGE BRENNER: Let's go off the record.
4 [0ff-the-record discussion.]
5 JUDGE BRENNER: Let's go back on the record.
6 BY MS. LETSCHE: (Resuming) 7 Q You said this is an ongoing process of
! 8 compiling this information. When do you anticipate that 9 it will be complete?
10 A (WITNESS DAWE) By the end of August of this 11 year.
12 Q Mr. Dave, have any changes been made to the 13 plant as a result of this report or this compilation of 14 information that you are undertaking?
15 A (WITNESS DAWE) No, they have not.
16 Q Do you expect that any will be made?
17 A (WITNESS DAWE) No, I personally do not expect 18 any to be made.
19 Q I would like to move on to page 61 of your 20 testimony, Section K, Analysis of Industry Experience.
21 Mr. Kas:sak, the ISEG program which is 22 described in your testimony here, that is really a 23 program, not a study, isn't it?
24 A (WITNESS KASCSAK) Yes. This LER review is a 25 program.
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() 1 0 What other activities are the responsibility 2 of the ISEG7 You reference in your testimony that in
() 3 addition to other activities, they will perform the reviews you described. What other activities are they 4
5 responsible for?
6 [ Witnesses conferring.]
7 A (WITNESS KASCSAK) Their primary function is 8 to perform an independent safety review of activities in 9 the plant. That includes primarily the review of safety 10 evaluations, the review of changes to plant procedures, 11 changes to tech specs, evaluation of plant modifications 12 and the design changes that may have been initiated as a 13 result of those modifications. In general, they are 14 there to provide an independent assessment of these 15 changes as they affect safety. They report 16 independently offsite to a headquarters organization 17 that is intended to be independent of the plant staff 18 operations.
19 JUDGE JORDAN: Could I ask, are the members of 20 the ISEG full-time? That is their only job?
21 WITNESS KASCSAKs The chairman of the ISEG 22 group has other functions, but the group leader who is 23 stationed at the site and the three other members that 24 work for the group leader also will be at the site and 25 all those functions are full-time.
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5174 1 JUDGE JORDAN: Th ank you.
2 BY MS. LETSCHE (Resuming):
3 0 In responding to Judge Jordan , you are using O 4 the future tense. Does that mean that these people have 5 not yet all come onto the site or come on board?
6 A (WITNESS KASCSAK) For the most part the 7 entire group is f unctional. For a number of months the 8 group leader and a few of his staf f have been at the 9 site. I am not sure if the last retaining member is on to board at this point in time. If it is not right now, it 11 is imminent.
12 13 14 15 16 17 18 19 20 21 22 23
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() 1 0 Have the procedures which will go vern the 2 reviews by the ISEG that you described in your
(} 3 testimony, are they all in place?
(WITNESS KASCSAK) There is a corporate 4 A 5 procedure dealing with the charter of the ISEG group.
6 That policy is in place. The implementing procedures, 7 the program procedures are in draft form and have been 8 reviewed and a re in the process of being signed off on 9 at the present time. They have been implementing them to in draft f rm.
11 JUDGE MORRISa Excuse me, Mr. Kascsak. I l 12 think the Board would like to see copies of the charter 13 f or ISEG, and any draf t or other procedures that are 0 14 available.
15 UITNESS KASCSAK Fine.
16 BY MS. LETSCHE (Resuming):
17 Q Mr. Kascsak, what sort of -- well, the people 18 who are part of this ISEG group, what is their 19 background?
20 JUDGE BRENNERa Ms. Letsche, I don't know if 21 you were here, but we are repeating testimony that we 22 have already got on the record right now, as to the 23 membership of the ISE" in terms of qualifications. Not 24 all of the members were named during the previous 25 testimony, and I must admit, I forget the contention O
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) 1 during which this came up. Are you aware of that?
2 MS. LETSCHE: No, I was not, Judge Brenner,
(} 3 and I will go back and look at the transcripts and determine if all of my questions have been answered.
4 5 And if not, then I will come back. I apologize for it 6 if it was repetitive.
7 BY MS. LETSCHE (Resuming):
8 0 Let me isk you this, Mr. Kascsak. What sort 9 of training have the members of the ISEG received 10 relating to the identification of systems interaction?
11 A (WITNESS KASCSAK) The makeup of this group 12 consists of personnel with varied experience, operating 13 and engineering experience. So their f amiliarity with O, the plant, their past training and engineering and 14 15 operating disciplines gives them intuitive knowledge as 16 to the characteristics of the plant and the type of 17 concerns that they should be evaluating.
18 In addition to the experience tha t they bring 19 into the group, they are given training on the use of 20 the procedures and the screening and review process that 21 they are required to perform as part of the LER review 22 program. This training will consist of identifying how 23 LER's are generated and certainly, most of them are 24 aware of this, but it will be reviewed in some more 25 detail.
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() 1 It will identify for them the types of 2 activities that they should be -- or, the types of 3 attributes that they should be looking for when they 4 review the LEP. And if an LER is identified into a 5 system that receives a project review, which is the term 6 they use, it requires an indepth study by those 7 individuals. And the procedures and training that they 8 vill be given tell them the type of review that is going 9 to be required to complete the requirements of the 10 procedure, in terms of the depth of the study and the 11 types of considerations they should give to the review 12 of the LER while they are performing that study.
13 In addition, as part of the procedures, there 14 are independent reviews of each project study, meaning 15 that the study is reviewed by a minimum of two of the 16 individuals in the group, and both of those individuals 17 are required to sign off on the study and its 18 conclusions. And again, they will be trained on what 19 that independent second verification review should-20 consist of, and the type of information they need to 21 perform sort review.
22 0 Who is going to be providing this training 23 that you are describing?
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(._/ 24 (Panel of witnesses conferring.)
25 A (WITNESS KASCSAK) I believe the training to
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() 1 the individual staff members will be given by the group 2 leader. I am not aware of any other training that he
{} 3 may be contracting other people to do the training.
I am not aware of that at this point.
But 4
5 Q Is the group leader going to receive any 6 training with respect to identification of systems 7 inte raction ?
8 A (WITNESS KASCSAK) Well, the group leader, whom 9 I can identify -- his name is Jack Alexander, and he is 10 a certified RO -- he has spent numerous hours 11 familiarizing himself with this program and has visited 12 INPO and had discussions with people at NSAC and is very 13 auch aware of the types of activities that should be 0 14 performed under this program.
15 In that sense, he has been training himself to 16 understand the attributes of the program and embody that 17 in the procedures that he has developed.
18 In addition, he has the full resources of all 19 of the local organizations, the operating staff and the l 20 e n ginee rin g sta f f to assist him in performing these 21 reviews or in doing any analysis or esiculations that he 22 might require.
23 0 Mr. Kas sak, I appreciate the general 1
24 descriptions you have given us of the sorts of training 25 and the preparation th a t the members of this group are ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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) 1 going to receive or conduct. I am not sure you answered 2 my question, though. Are you aware of any specific 3 training r31 sting to the identification of systems
{
4 interactions that any of'these people are going to 5 receive?
6 A (WITNESS KASCSAK) As we have been discussing 7 all along, systems interaction is an inherent part -- it 8 is a normal part of the plant engineering process. And 9 people that are experienced in plant design and 10 operations are also f amilia r with systems interactions.
11 And therefore, the training that he has received in all 12 these other disciplines makes him more qualified to 13 consider systems interactions.
O 14 0 Mr. Kasesak, are any of these, either the 15 group leader or the members of the ISEG, -- have they or 16 will they receive any training or -- I guess, receive 17 any training or' support f rom any of the laboratories 18 that have conducted studies of systems interactions like 19 Sandia or Brookhaven or Lawrence Livermore, to your 20 knowledge?
21 (Panel of witnesses conferring.)
22 A ( WITNESS K ASCSAK) I think, to get at the heart 23 of your question, the ISEG group will be making use of, 24 as I said, other organizations, and their primary 25 function is a screening process to look at and evaluate O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554 2345
5180 1 the operating experiences, to identify instances that 2 are applicable to Shoreham. And where more detailed
(} 3 evaluation or engineering calculations or systems 4 studies are required they will pass them on to other 5 organizations for their review.
6 And it is that type of review that would be 7 similar to the reviews that I think you are referencino, 8 the Lawrence Livermore and the Sandia studies, which are I
9 nore indepth, technical, theoretical type reviews of 10 these past LER's.
11 In terms of training, again, the INPO 12 organiza tion which these people are very f amiliar with 13 and, in fact, will be an integral part of the program, 14 the SOER's that will be reviewed by Shoreham for 15 applicability will have gone through the INPO 16 o rg a niza tio n , which also performs the function of 17 r ev ie wi n g , in gres t depth, these LER's in developing for 18 the benefit of the ISEG group detailed descriptions of 19 the event, detailed evaluations of the interactions that 20 may have taken place, computer modeling of the event or 21 wha tever , and prepare for the benefit of the ISEC group 22 conclusions and recommendations that will be evaluated 23 case by case for Shoreham.
A kJ 24 And it is really tha t program tha t is the main 25 focus of the LER review program, and I might point out O
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() I that that program has been given high accolades by the 2 NRC staff, and I believe has made great strides to
(} 3 fulfilling the recommendations that came out of the THI 4 review.
5 0 Mr. Kas:sak, is the answer to my question that 6 -- my question, whether or not these people have 7 received or will receive any kind of training from the 6 labs I mentioned -- is the anwer to that no?
9 A (WITNESS KASCSAK) The answer is no.
10 A (WITNESS DAWE) If I could just add a comment 11 to that response. I think there is just a little bit of 12 apples and oranges here, because the lab work that is 13 being done is developmental work. It is geared towards O 14 new techniques for predictive studies. And what has 15 been addressed in our testimony is review of operating 16 experience and looking at things that have happened.
17 And I just personally do not see the 18 applicability of all of this, exactly the way it is 19 being tied together now.
20 0 3 r. Kascsak, in conducting a screening process 21 which the ISEG people are going to do, you told us, on 22 what basis are the ISEG members going to be able to 23 evaluate the INPO conclusions with respect to systems l
24 interaction s, if there are any such conclusions?
25 A (WITNESS K ASCS AK ) Well, the screening process O
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() 1 I speak of deals with the spectrum of LER's that they 2 will be reviewing, not just the INPO SOER's. But again,
(} 3 the procedures and training tha t they will receive will identify for them the attributes that they should be 4
5 looking for in considering the applicability of this 6 event to Shoreham.
7 And within those attributes will be the-8 consideration of whether the same systems and components 9 thst played a part in tha t even t, whether they exist at 10 Shoreham; whether the same event could occur. They will 11 consider the types of equipment used at Shoreham and 12 whether the same types of equipment that were referenced 13 in the event exist at Shorehas and whether or not the 14 same interactions can take place.
15 The entire focus of this program is to look at 16 sbnormal events, to look at events that should not have 17 occurred, and theref ore, they are very sensitive to 18 looking at things that are unusual. And systems 19 interactions is certainly within that category and they 20 will be very sensitive to that.
21 0 I understand that wha t you are saying, Mr.
22 Kascsak, -- and maybe you just don't know the answer to 23 this question, but in your testimony it says, ISEG 24 review of the SER and SOER will identify any ineidents 25 involving systems interactions. What I am asking you is l
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() 1 on what basis is the ISEG going to be able to make that 2 identification of whether or not incidents involved 3 systems interactions?
4 A (WITNESS KASCSAK) Well, I think what we are 5 doing here is we are drawing a conclusion of their 6 program. I mean, they are going to identify incidents ,
7 involving all kinds of things, but assured through the 8 p ro g ram will be the identification of systems 9 interactions. And they won't stamp something that says 10 this is a systems interaction, but they will identify an 11 event that is, in fact, an interaction event, and ther 12 will evaluate that event and evaluate whether or not any
, 13 action is required to -correct that type of event on 14 Shoreham.
15 0 The "they" in your answer is the INPO? Is 16 that right?
17 A (WITNESS KASCSAK) No, it is the ISEG group, i
18 and any assistance they seek f rom other organiz3tions.
l 19 Q So they are not going to be going throdgh and t 20 saying this is a systems interaction problem, or this 21 one is not a systems interaction problem? Is that what l
i 22 you are saying?,
23 (Panel of witnesses conferring.)
24 MS. LETSCHE: Judge Brenner, as Mr. Kascsak 25 indicated earlier, he is very familiar with this l
)
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i 5184 1 program. He is the LILCO representative on this panel 2 and I would like to get his answers to these questions.
3 JUDGE BRENNER: All right.
(}
4 WITNESS KASCSAKa Well, I think I stated they 5 are not going to explicitly identify this as a systems 6 interaction, but the program as it exists and will be 7 implemented will detect and evaluate systems 8 interactions as an, intuitive part of the program.
9 JUDGE BRENNER: Mr. McGuire, wait a minute.
10 We will stay with Mr. Kascsak for this line, and then we 11 will allow other members of the panel to add at the 12 end. But, Ms. Letsche, you indicate when you are 13 prepared to accept input from other members of the panel O 14 and try not to let it go on too long in time. But I 15 agree, you are entitled to pursue this with Mr. Kascsak.
16 MS. LEISCHE: Thank you, Judge Brenner.
17 BY HS. LETSCHE (Resuming):
18 0 Just so that I understand you, Mr. Kascsak, 19 you are now sa ying tha t this sta tement in your testimony 20 that the ISEG review will identify incidents involving 21 systems interactions, that that really is not the cases 22 that the review will not say this incident is a systems 23 interaction event. Is that right?
24 A (WITNESS KASCSAK) I disagree with your 25 conclusion. I have said that the program will detect O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
5185 1 systems interactions. What I stated, though, is that 2 there will not be an explicit identification in the 3 project review summary which says that this review 4 discovered a systems interaction. I think that will be 5 obvious.
6 0 You indicated that the ISEG members will 7 determine whether or not instances that they review are 8 applicable to Shoreham, and tha t -- is that right?
9 A ( W IT N ES S K AS CS AK ) True.
10 0 And I think you also said tha t they will also
} 11 determine whether or not more detailed studies of a 12 particular incident are required. Is that right?
13 A (WITNESS K ASCSAK) . Tha t is also correct.
14 0 And they will determine whether or not they 15 need to get any assistance from the people on the LILCO 16 staff or any outside persons in conducting these 17 reviews? Is that right? For the detailed study.
18 A (WITNESS KASCSAK) Initially, they have that 19 opportunity before they prepared their report. But as I 20 said, the report will be reviewed by an independent 21 member of the ISEG group. It will also be reviewed 22 prior to implementation by both the plant staff and the 23 nuclear engineering organizations to ensure that the 24 activities and conclusions they reached were appropriate 25 and correct. And if additional studies -- if other O
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O ' ore a1= tt=== re t ta t aa1*1=a 1 =*=at =12at d-2 varranted, they would also make that recommendation.
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() 1 Q The other organizations or the plants that you 2 referenced are going to be reviewing just the project 3 studies that the ICG determines are required, is that 4 right?
5 A (WITNESS KASCSAK) No. They will be reviewing 6 each conclusion and recommendation coming out of the 7 ISEG group.
8 Q And those will be conclusions and 9 recommendations after they have done the screening of 10 the INPO information?
11 A (WITNESS KASCSAK) Well, as I said, that is 12 one -- that is what would happen if they were not 13 involved in performing something during the preparation O 14 of that study by the ISEG group and required by 15 procedures to use this review after the report has been 16 completed.
17 Q After the ISEO group report is completed?
18 A (WITNESS K ASCSAK) Right.
19 Q I'm just trying to get it clear in my head. I 20 understand that the ISEG group can voluntarily bring in 21 and decide they want help from the plant staff or l
22 somebody else. Ihey will do that after they have 23 screened the INPO information and decided we want to do
( 24 a project study on this because it is applicable to 25 Shoreham.
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(]} ' 1 A (WITNESS KASCSAK) That is correct.
2 0 The other way that the plant staff or other 3 people could be involved is in reviewing the actual 4 project stadies that the ISEG group produces, is that S right?
6 A (WITNESS KASCSAK) They will review that.
7 (Counsel for Suffolk' County conferring.)
8 Q Mr. Kascsak, if the ISEG group makes a 9 recommendation -- I assume that is one of the things to they can do, isn't it?
11 A (WITNESS KASCSAK) Yes.
12 Q Recommend that a change be made in the plant 13 or something like that?
14 A (WITNESS KASCSAK) Yes.
15 0 If the ISEG group does recommend a change, who 16 is involved? Is the ISEG group also involved in the 17 implementation of the change?
18 A (WITNESS KASCSAK) Well, the process calls for 19 the recommendation to go to the nuclear operations 20 support department manager who then would process that i
21 recommendation through the management of the company, l
l 22 and he would process that by probably in most cases 23 having another organization review the recommendations
() ,
24 for implementation and do a more detailed -- if there is 25 a change involved -- a more detailed evaluation of the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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( 1 conceptual engineering that might be involved, and that )
2 would enter into the design modification procedures 3 within the company and be evaluated in that loop.
(}
4 0 If some sort of outside consultant had been 5 involved in the detailed project study that ISEG did, 6 would that group also be involved in the implementation 7 of a recommended change?
8 A (WITNESS KASCSAK) Not necessarily, although 9 the ISEG group is involved in following up their .
10 recommendations, and they will monitor the rest of the 11 program to ensure that their recommendations are 12 implemented, or if they are not implemented, they will 13 evaluate the reasons for their not being implemented and 14 have the opportunity again through their ensuring that 15 the loop is closed that if their recommendations were 16 not implemented, that they concur with the reasons why 17 they were not implemented.
18 JUDGE BRENNER: Off the record.
19 (Discussion off the record.)
20 JUDGE BRENNER: Let's go back on the record.
21 BY MS. LETSCHE: (Resuming) 22 0 Mr. Kas:sak, you mentioned the NSO manager in 23 one of your earlier answers with respect to where 1
24 recommendations from the ISEG co. Does that person have
- 25 the authority to reject a recommendation that the ISEG l
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5190 0 1 oro=> oexest 2 (Panel of witnesses conferring.)
g 3 JUDGE BRENNER: Mr. Dawe, you are conferring
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4 with Mr. Kascsak. That is the general proposition , and 5 I can see how you might have automatically fallen into 6 that habit, but it is not the proposition right now. We 7 are stayin7 with Mr. Kascsak. Save your thoughts and 8 when Ms. letsche indicates she is finished exploring 9 what it is she wishes to explore with Mr. Kascsak, then 10 we will take the other comments.
11 MS. LETSCHE Thank you, Judge Brenner.
12 WITNESS KASCSAK I would have co refresh 13 myself with the procedure, and I do not have it here O 14 with me righ t now. The practical matter is that it is 15 very unlikely that he would personally make an instant 16 decision on the recommendation. He would, in all 17 probability, and in fact the procedure calls for him to 18 send a recommendation to the appropria te organization 19 for evaluation and implementation, and that could be the 20 plant staff or the engineering department. And after 21 their review and conclusions and reporting back to him 22 on what would be involved in the modification, then he 23 could reach a decision as to whether or not it should be 24 implemented or not. Again, that decision is fed back to 25 the ISEG group for their concurrence.
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() 1 BY MS. LETSCHE: (Resuming) 2 0 What if they don't concur? !
3 A (WITNESS KASCSAK) If they don't concur, then 4 they have the opportunity to appeal that decision 5 through the management orga niza tion, through the vice 6 president of nuclear.
7 (Counsel for Suffolk County conferring.)
8 A (WITNESS K ASCSAK) I might add one thing that 9 I forgot to mention before; that is, that INPO does come to to the company to evaluate the operational activities of 11 the plant, and one of those things that they will be 12 auditing is the ISEG program and the plant-specific 13 review of our LER review program, including the review O 14 of the 50ERs that were generated through the INPO 15 organization. The evaluation that INPO vill perform 16 vill be fed back to our management organizations to in 17 fact have a double check on the credibility of the 18 program as it is being im pl em en t ed .
19 (Counsel f or Suff olk County conferring.)
20 0 One more question relating to my prior line, 21 Mr. Kascsak, on who is reviewing or deciding to accept l
22 or reject an ISEG group recommandation. Is the last 23 person in the line who ultimately makes the decision the
() 24 vice president of nuclear or the vice president of 25 engineering?
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() 1 A (WITNESS KASCSAK) Well, the vice president of 2 nuclear is in charge of the nuclear engineering 3 department. He is in charge and has the
)
4 responsibilities for the entire nuclear arm of the 5 company, and in that respect all of the organizations 6 report to him, and he is in fact the executive officer 7 in charge of his part of the program and would have the 8 corporate responsibility for making that decision.
9 0 One other question, Mr. Kascsak, and then 10 everyone else can chine in if they want to. What sort 11 of training -- maybe training isn't the right word --
12 but experience do the ISEG members have in terms of 13 walking down the plant?
O 14 A (WITNESS KASCSAK) Well, for the most part all 15 of the members of the ISEG group are very familiar with 16 the plant. They have worked either in the startup 17 organizations, the engineering organizations, the 18 construction organizations; in fact, all of the members 19 that are now within the ISEG program are and have been 20 involved in the plant design, construction and startup 21 program, and they will continue -- they will be 22 stationed at the site, and they will bo intermittently 23 involved in the activities of the plant and continue to
) 24 be familiar with the plant.
25 And that is a definite. If anyone was brought O
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() 1 into the group that didn't have that experience, ther 2 would be required to become familiarized with the plant.
3 (Counsel for Suffolk County conferring.)
4 MS. LETSCHE: Judge Brenner, at this point if 5 any other panel members, unless the Board has questions 6 for Mr. Kascsak, if any of the other panel members have 7 a comment --
8 JUDGE BRENNER: We vill give them an 9 opportunity in a moment. Let me jump in. I have had a 10 chance to review my own notes, which is certainly a very 11 incomplete index of the transcript, and since I diverted 12 you by mentioning that this came up earlier, let me be a
, 13 little more precise and also indicate a detail or two O 14 which was left open earlier in case that matters to you.
15 Testimony regarding the composition of the 16 ISEG was given on June 9th at some point between lunch 17 and the afternoon break. I do not remember which LILCO 18 witness gave the testimony. It came up when we were 19 hearing the testimony on Contention 11, passive 20 mechanical valve failure. My recollection is, though, 21 that although we got the nsmes of some of the members of 22 the group, not all of the persons had been finally 23 selected, and therefore, we did not get all of the names.
24 So if the names of the individuals are 25 important to you as a follovup to your question as to l
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() 1 plant familiarity, you might want to pursue that now. I 2 do not want to leave you with the impression that we had 3 all of the names on the record. We did have some of the 4 names, and we had the general disciplines which would be 5 represented on the group.
6 MR. ELLISa Was this the time, Judge Brenner, 7 when the other panel members, if they had something to 8 say, could say it?
9 JUDGE BRENNER: No, because I want to see if 10 Ms. Letsche wants to ask that last question in view of 11 my advice, and immediately after that we will go to the 12 other panel members. I am going to ask it if you do not.
13 MS. LETSCHE: No. I want to know also, Judge O 14 Brenner.
15 JUDGE BRENNER: All right. M r. Kascsak, why 16 do you not give us the membership of the ISEG, and in 17 addition to the name perhaps indicate their other 18 position, present position, and what other duties ther 19 will have while on the ISEG, and also their position 20 within the ISEG group.
21 WITNESS KASCSAKs Well, I will start f rom the 22 chairman. The chairman of the ISEG group is Brian 23 McCaffrey, who is the regulatory supervisor within the 24 nuclear operations support division operation. In that 25 position he has responsibilities dealing with regulatory O
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() 1 matters that affect the plant. He is currently 2 involved, as you are probab1'y aware, in these current 3 licensing proceedings. He will continue to stay..
} ,
4 involved in that capacity in other' regulatory matters 5 that affect the plant. He will be loca ted in the' 6 headquarters orgsnization presently in Hicksville.
7 JUDGE BRENNERa M r. Kascsak, speak just a 8 little louder, please. . ,
9 WITNESS KASCSAK The remaining group, which' 10 is the onsite portion of the group, beginst with the 11 group leader who is Jack Alexander. He is, as I 12 mentioned before, a certified reactor oporator. He,has 13 worked within the startup organization snd plant staff. ~
CE) 14 He will fulfill the chartar of the ISEG group, and as I 15 mentioned before, their duties involve the review of all 16 safety aspacts of the plant, including review of safety 17 evaluations, changes to procedures, changes,to tech 18 specs, reviewing plant modifications as they. occur. He 19 vill be involved in reviewing any regulatory matters 20 tha t might affect the plant, and he really has a very 21 broad charte r in tha t respect.
l 22 On his staff he has three individuals'that are 23 working for him. Two of them are presently.on board and
() 24 maybe three. At least as of a couple of weeks ago there 25 were only two. One of those individuals is Bob
(
ALDERSON RLPORTING COMPANY,IP'C, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
5196 O 1 Scaracini who worked within tne construction 2 organization and was stationed at the site for many,
[ 3 many years involved in the construction of the plant.
4 The other individual -- I am afraid I am going 5 to have to go back and get his name because I did not 6 personslly know the individual, and I did not retain the 7 name for this purpose, but I could find that out for you.
8 JUDGE BRENNER: Let us see if we could get 9 this a little quicker. Can you list the names of the to people you now re:all in the group?
11 WITNESS KASCSAKs Well, I have just finished.
12 Actually, as I mentioned, there was one other individual 13 that is currently on board that I just cannot recall his O 14 name.
15 JUDGE BRENNER: I thought you said Mr.
16 Alexander had three people working for him.
17 WITNESS KASCSAK I said the group would 18 consist of three people. It is a total group of five, 19 four of which are at the site, three of which are 20 currently on board.
21 JUDGE BRENNERa So we are missing two names.
22 WITNESS KASCSAKa We are missing two names.
23 One name may not exist at this point in time.
24 JUDGE BRENNER: When we get the information 25 that Judge Morris asked for --
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() 1 WITNESS KASCSAKa I will update you on that 2 status.
3 JUDGE BRENNER: We hope it is this week, if 4 possible, and it would be helpful if we could get their 5 qualifications along with their names.
6 Let me pursue this just a little more. I do 7 not want to go into it too far at this point. But 8 according to my notes the chairman of the ISEG will 9 report to the head of the nuclear operations support 10 group, is that correct?
11 WITNESS KASCSAKa That is correct.
12 JUDGE BRENNERa And that is Mr. Kubinak?
13 WITNESS KASCSAK That is correct.
O 14 JUDGE BRENNER And who in turn will report to 15 Nr. Pollack who is the vice president for nuclear?
16 WITNESS KASCSAKa That is also correct.
17 JUDGE BRENNERa And what other duties will Nr.
18 NcCaffrey have while he is chairman of ISEG7 19 WITNESS KASCSAKa Well, in his position as 20 regulatory supervisor, in that capacity he has 21 responsibilities for regulatory matters that affect the 22 plant, and that includes the processing of NRC 23 correspondence, bulletins, circulars, other direct 24 correspondence in the company, making the management of 25 the company aware of regulatory matters, and ensuring O
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i lO 1 that those matters are addressed by the appropriate ,
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() 1 JUDGE BRENNER What other duties will Mr.
2 Alexander have besides being group leader of the ISEG?
{} 3 responsibilities.
WITNESS KASCSAK He has no other 4
5 JUDGE BRENNER: And the other three members 6 will have no other responsibilities?
7 WITNESS KASCSAKs They also dedicated to the 8 ISEG.
9 JUDGE HORRIS: Will Mr. McCaffrey have other 10 personnel reporting to him?
11 WITNESS KASCSAKs Yes, he will.
12 JUDGE MORRIS s How many or what functions?
13 WITNESS KASCSAKs Well, he will have other O 14 engineers reporting to him to fulfill the other aspects 15 of his responsibilities. I can't recall the number, a 16 number of individuals, greater than two, less than five 17 probably.
18 JUDGE 50RRIS: Could you supply that 19 information also?
20 WITNESS KASCSAK: Yes.
21 JUDGE BRENNER: What I was going to ask for if 22 it exists -- and I don't want it made up necessarily 23 this week, although eventually it might be helpful for
( 24 other contentions in addition to this one -- is there an 25 organization chart that would include the reporting line O
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() 1 of the ISEG through the head of nuclear operations 2 support and to Mr. Pollack relative to the other 3 reporting lines including the organizations that would
[}
4 have responsibility for keeping the plant on line and 5 also the Q A/QC organizations?
6 WITNESS KASCSAK: I think we can supply you 7 with an organizational chart for the entire office of 8 nuclear, including which will show the reporting 9 responsibilities of ISEG and all of the other to departments within that organization.
11 JUDGE BRENNER: I think it would be 12 appropriate to give Mr. Dave and Mr. McGuire, both of 13 whom verbally or otherwise indicated a desire to O 14 supplement some of your questions of Mr. Kascsak with 15 respect to the ISEG.
16 MS. LETSCHEs That is fine, Judge Brenner.
17 WITNESS DAWEs I have no supplementary 18 information.
19 WITNESS MC GUIRE: I also pass. I forgot what l 20 I was going to say.
21 JUDGE BRENNER: Your counsel worked very hard 22 for you, and you missed tha t opportunity. Let's proceed.
23 JUDGE JORDAN: Can I ask just one question 24 about the statement you made that the ISEG will include 25 review of licensee event reports generated at Shoreham.
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() 1 Do they also review the LERs from other plants?
2 WITNESS KASCSAKs A recent addition to the 3 program which came out of some of the discussions we 4 have had with the peer review group committee involved 5 in the PRA deals with evaluating past LERs for the 6 Fitzpatrick plant.
7 JUDGE JORDAN: For what plant?
8 WITNESS KASCSAK: For the Fitzpatrick plant.
9 A concept that has been brought forth is the 10 identification of a surroga te plant, a plant that would 11 be of similar design to the Shoreham plant in terms of 12 its systems and how the plant would operate. In a sense 13 it might be a precursor to the experience that is 14 occurring at Shoreham. And we have identified the 1
15 Fitzpatrick plant as a plant that we want to go back and 16 review the operator experiences on. And a commitment 17 has been made to go back and review all of the LERs, 18 past LERs since the initial operation of Fitzpatrick, 19 and to bring them to bear on the LER review program.
20 We believe that the INPO program will in fact 21 screen any significant LER from any plant, including 22 plants similar to $horeham, but to ensure that is the 23 case for Fitzpatrick, we have also committed to review a
() 24 number of LERs that have been produ :ed since the 25 initiation of the INPO program and to evaluate whether O
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() 1 or not there is enough sensitivity in that program to 2 ensure that any of the events that would be applicable 3 to Shoreham would be identified through the SOER
,(}
4 program. And we will be proceeding to draw that 5 conclusion, and if the conclusion is acceptable, then we 6 will continue to proceed with the SOER program. If the 7 conclusion is that more sensitivity is required, then we 8 will take actions to most likely re"iew individual LERs 9 from the Fitzpatrick plant.
10 JUDGE J3RDAN Is the reason for not including 11 other LERs from other boiling water reactors because the 12 volume is too large?
13 WITNESS KASCSAKa Well, the main reason is O 14 because the INPO program is in fact -- the basis of that 15 program is relieve individual utilities from reviewing 16 the large numbers of LERs that would be generated and 17 reporting them in such a way that only the significant 18 ones are forwarded to each utility for their review.
19 JUDGE JORDANS I see. That's fine. Thank you.
20 (Counsel for Suffolk County conferring.)
21 BY MS. LETSCHE: (Resuming) 22 0 Mr. Kss:sak, I would just like to follow up 23 one thing you stated to Judge Jordan. Why has LILCO
! ( 24 chosen to look at the Fitzpatrick plant as the surrogate 25 plant rather than maybe other ones that are out there or O
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() 1 other ones designed by Stone and Webster?
2 A (WITNESS KASCSAK) Well, simply because 3 Fitzpatrick is the best choice. It is a GE BWR-4 It
[}
4 is a Stone and Webster architect engineer design, and it 5 was built and constructed in a similar -- it has been 6 operating, but I mean many of the design decisions and 7 processes that were involved in designing that plant are 8 similar to the processes that a re involved in the design 9 of the Shoreham plant. Therefore, it is the most to directly applicable to the Shoreham, and it has operated 11 since about 1975.
12 (Counsel for Suffolk County conferring.)
13 0 Have you also considered adding the Nine Mile O 14 plant to what LERs you are going to review?
15 A (WITNESS KASCSAK) Well, Nine Mile 1 is a much 16 different plant than Shoreham, so I do not think it 17 would be a good choice, number one. If your question is 18 are there other plants maybe like Browns Ferry or 19 Lismerick or something like tha t tha t may come along, I 20 think we would have to consider that based upon the 21 results of this review that we are performing right now.
22 0 Nine Mile 1 was designed by Stone and Webster, 23 wasn't it, or constructed by Stone and Webster, I'm 0)
\s 24 sorry.
25 (Panel of witnesses conferring.)
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5204 1 A (WITNESS DAWE) Nine Mile 1 was constructed by 2 Stone and Webster. It was not designed by Stone and
() 3 Webster, as we have stated in the last several days.
4 A (WITNESS KASCSAK) Nine Mile 1 is also a BWR-2 5 plant which is significantly different in terms of its 6 systems than the Shoreham plant.
7 (Counsel for Suffolk County conferring.)
8 0 okay, gentlemen. I would like to move on to 9 Section L of your testimony on page 61, which is hended 10 "Preoperational and Startup Testing."
11 Mr. Kascsak, you stated earlier that your 12 organization has performed certain tasks pertinent to 13 this section of the testimony here. Can you tell me 14 what the tasks are that you have performed that are 15 pertinent to these?
16 A (WITNESS KASCSAK) Well, my statement dealt 17 with the familiarity we had with the startup 18 organization and the fact that we have performed tasks 19 at the request of the sta rtup organization, particularly 20 the preparation of the number of test procedures and the 21 review of test procedures at their request.
22 We also as an organization have interaction 23 with the plant staff relative to changes that are being 24 made in the plant and how that might affect their test 25 program.
O l
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() 1 Q Have you yourself prepared test procedures?
2 A (WIINESS KASCSAK) I myself have not, but I
{} 3 4
have reviewed procedures prepared by people working for me.
5 Q Have you reviewed any procedures for the 6 integrated electrical tests that are mentioned in your 7 testimony? ;
8 A (WITNESS KASCSAK) I have reviewed the 9 procedures that exist for that test.
10 0 And how about the loss of offsite power test 11 that is referenced in your testimony?
12 A (WITNESS KASCSAK) I do not believe that 13 procedure presently exists. It is a procedure that is O 96 defined. It is a test that is defined to take place, 15 and there are standard procedures that are made 16 available to the company through General Electric or 17 other organizations that we would use to develop 18 Shoreham-specific procedures.
i 19 0 How about the power ascension test program?
20 A (WITNESS KASCSAK) Some of those procedures 21 exist; some of them do not at the present time. And I 22 have seen some of the ones that do exist.
23 0 Do all of the integrated electrical test 24 procedures exist?
25 A (WITNESS KASCSAK) Yes, they do.
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() 1 0 Well, with respect to all of the ones that do 2 not exist, on what do you base your conclusion in this 3 testimony that these programs are going to provide you 4 sn opportunity to ve rif y that adverse systems 5 interactions will not occur?
6 A (WITNESS KASCSAK) Tha t assurance is obtained 7 toward the program definition and the methods that will 8 be used in the program itself. The individual 9 procedures are merely implementations of those, of the 10 program definition and the methods that will be used.
11 0 But the definition and the methods are not 12 Shoreham specific, right?
13 A (WITNESS KASCSAK) Yes, they are. Chapter 14 O 14 of the FSAR identifies the startup program and the 15 methods and the procedure types that will be used in the 16 program. And it is really this entire integrated 17 program, the commencement with the checkout and initial 18 operation of the systems and components that are 19 performed by the startup organization, which gets into a 20 very detailed check of component by component, wiring 21 checks, instrument calibration, instrument checks, 22 checking of motors, valves, pumps on an individual 23 componen t basis.
24 It is then preceded by preoperational tests 25 which are individual system tests which will assure that
()
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() 1 the system perf orms in accordance with its design 2 requirements. And this is e requirement of the program, 3 that the test procedure be written around the 4 performance requirements of the system. And it takes 5 into account an evaluation of how the system was 6 constructed to ensure tha t the system was constructed in 7 accordance with the design documents, the design 8 drawings, and that when that system is operated that it 9 operates in accordance with its essential variables, and 10 if those variables are not maintained through the tests, 11 then corrective actions are initiated to correct the 12 performance of that system. Supporting systems are 13 evaluated. The procedures that are used to operate the O 14 systems, the human aspects of how procedures, how 15 systems are operated, are evaluated in this phase to 16 ensure that the system starts and operates in accordance 17 with its design requirements. If supporting systems or 18 interactions took place that prevented its performance, 19 they would be discovered through this part of the 20 procedure, this part of the program.
21 Continuing on, the program gets into 22 integrated tests where we evaluate the performance of 23 the plant as an integral part. We will evaluate the
( 24 plant against transients, as we talked about, loss of 25 offsite power, turbine trip, loss of feedvater, ESIV O
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() 1 isolation and asny o th e rs. These are all events that we 2 will be putting the plant through to evaluate its 3 response, and we will be evaluating that response 4 aqsinst analysis, predictive analysis which was produced 5 by the engineers who are knowledgeable in the plant to 6 tell the startup organiza tion how the plant should 7 operate.
8 Those results will be reviewed by the plant 9 staff. It will be reviewed by General Electric and the 10 engineering organizations for acceptability. If we find 11 the plant is responding in a way that is unacceptable, 12 corrective action will be taken. So it is the program 13 itself. It is this entire process that ensures that the O 14 plant will have no adverse systems interaction, that it 15 will in fact operate the way it is intended to operate.
16 0 Any intaractions that might be identified in 17 the course of these tests are going to be those that 18 occur under the circumstances of a particular test, 19 right?
20 A (WITNESS K ASCSAK ) Well, whatever would occur 21 would occur during a test, yes.
22 0 You have listed here integrated electrical 23 tests and the loss of offsite power test, and I take it 24 these are two that you believe would identify systems 25 interactions. That is why they are listed here, is that O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5209 O i riaat2 2 A (WITNESS KASCSAK) They are examples of tests 3 that we would discover in a systems interaction.
4 0 You did not list an other ones, though?
5 A (WITNESS KASCSAK) Well, I did not list them 6 all. I just listed examplos of types of tests that 7 would discover unacceptable interactions.
8 0 And these are going to -- these tests are 9 going to discover them by verifying to the design works?
10 A (WITNESS KASCSAK) Yes. The procedures will 11 identify exactly what should happen, what the ac'ceptable 12 limits are. We will be looking at pump, we will be 13 looking at performance, and we will be ensuring that the 14 plant response as it should; that when we induce a loss 15 of offsite power signal that the diesel generators start 16 and pick up load as they are required to do, that the 17 voltages and f requencies are acceptable. And we will be 18 monitoring the voltages at all of the ECCS equipment to 19 ensure that they are acceptable. We will be aonitoring 20 the actual starting of the pump and the operation of the 21 system to ensure that it comes up and operates at its 22 design requirements in terms of pressure flows, et 23 cetera.
24 0 Let us talk about the test that you have 25 looked at, the procedures for its that is, the O -
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( 1 integrated electrical test. Do the procedures, the 2 Shoreham-specific procedures with respect to that test
(} 3 direct an operator to look during the course of a test for possible spatial systems interactions?
4 Is that in 5 the procedure?
6 A (WITNESS KASCSAK) Well, the test engineers 7 will be looking at -- they will be there during the 8 entire test, and they will be monitoring the response of 9 the plant to ensure that it is acceptable from any 10 interaction.
11 0 I am asking you if the procedure directs him 12 to look for spatial interactions as you all have defined 13 them? Is he instructed to walk the lines?
O 14 (Panel of witnesses conferring.)
15 A (WITNESS KASCSAK) Yes. There will be 16 individuals walking the systems to ensure that the ,
17 systems are operating properly.
18 0 And that is true with respect to the 19 integrated electrical test procedure that you have 20 reviewed?
21 A (WITNESS KASCSAK) Yes.
22 0 Is he instructed to iden tif y any possible 23 human systems interactions while he is conducting this 24 integrated electrical test?
25 A (WITNESS KASCSAK) Again, it is an inherent O
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! I part of the program. He vill be looking at his 2 procedures. He vill be looking at the operational 3 procedures that tell him how a system should be l 4 operated. And if he discovers that in the 5 implementation of those procedures something should be 6 corrected, he vill identify it. That includes all 7 interactions -- spatial, functional, human, all of them.
8 9
10 11 12 i
- O 14 15 16 17 18 19 20 i
21 22 23 O 24 25 O -
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1 0 Well, with respect to the loss of offnite 2 power test, the proced ures don' t exist yet -- or the 3 Shoreham specific procedures don't exist. Does the test 4 program instruct the -- or indicate that the person 5 conducting the test is supposed to walk the lines and 6 not to look for any kinds of spatial interactions?
7 (Panel of witnesses conferring.)
8 MS. LEISCHE: Judge Brenner, I would like to 9 have Mr. Kascsk's response to these questions.
10 JUDGE BRENNER: Ms. Letsche, let me suggest 11 when that's the esse you say that in advance, because 12 it's perfectly appropriate for the panel to confer, and 13 then for you to jump in in the middle while they're O 14 doing that is not a very orderly procedure. g 15 MS. LETSCHE: I apologize, Judge. I will do 16 that in the future.
17 JUDGE BREMNER And again, let's not try to 18 prolong beyond whst is necessarily for your substantive 19 approach the amount of time when you will stay only with 20 Mr. Ka sess ir .
21 WITNESS KASCSAK The procedure will require 22 the te';t engineers and technicians to be out within the 23 plant and within the switch yard and at the switch gear 24 rooms and st the con trols, more control centers, the 25 pump stations, monitoring performance of the pumps, O
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() 1 looking at the instrumentation. And in that respect 2 they will be in the plant and they will be observing
{} 3 4
what is happening during this test. And if they again see any interaction or concern, they will identify it.
5 MS. LETSCHE: (Resuming) 6 Q Is that in the procedure, that they are 7 supposed to look? The reason I'm confused, and I just 8 vant to understand here, these are designed to be design 9 verification tests. I gather that from your testimony.
10 My question is, in doing a design verification 11 is there also an instruction in the test procedure which 12 tells the operator, look for something else, something 13 in addition to that particular kind of interactions, or
' O 14 is he in fact looking to see that the design is verified 15 according to the test procedure?
16 A (WITNESS KASCSAK) The procedure itself 17 doesn't identify anything as explicit as I think you are l
18 looking for. But the training of the individuals, their 19 familiarity with the program and the entire objective of 20 having the plant operate properly requires them to look 21 for these types of concerns. And there would be no 22 hesitation on their part in fact.
23 This is, I'm sure, one of the things tha t they 24 will be doing when they are performing their other 25 duties explicitly identified in the procedures.
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( 1 0 The group that will be conducting the startup 2 and the preop tests of those programs, do they receive I
(} 3 training in identification -- any specific training 4 relating to that?
5 A (WITNESS KASCSAK) I'm going to be repetitive 6 here again, but these are highly experienced l 7 individuals. Many of these are personnel from the 8 General Elactric organization, the Stone & Webster 9 organization, the LILCO organization. And these 10 individuals have ben through other startups before.
11 They have been trained in engineering and operational 12 disciplines.
13 They understand the plant. They understand 14 how systems.should operate and how they shouldn't 15 o pe ra te . And they certainly understand the concept of 16 systems interaction. And, although the terminology may 17 have not been used to the extent that we are using it 18 here today, the concept and the real depth of their 19 knowledge deals with concerns about systems 20 interactions.
21 JUDGE NORRIS. Ex cuse me, Mr. Kascsak, but you 22 are repeating yourself, and I think for only the second 23 time. I think Ms. Letsche is trying to ask some 24 specific questions about formal training in a discipline 25 which she es11s safety interaction f or shorthand, and if ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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() I there are no specific programs for training people in 2 those areas, why don't you just say no.
3 WITNESS K ASCS AK: Well, I think that might be
{'}
4 misleading if I just say no.
5 JUDGE MORRIS: Well, you 'v e already told us 6 the general answer. We don't need to hear t. hat any more.
7 WITNESS KASCSAK: Okay.
8 Again, I think the training that they do 9 receive is relevant to the concern of systems 10 interactions, and although there wasn't a particular 11 training course identified as a systes interactions 12 training, I do believe they are trained in the concerns 13 about systems interactions.
O 14 WITNESS McGUIRE: At we still restricted?
15 MS. LETSCHE No, you may go ahead.
16 WITNESS IANNI I think a good example of what 17 Mr. Kasessk vss trying to say happened to us on our 18 first BWR-6 startup recently overseas. A test was under tg way on some system or another and prior to that an 20 operator had lined up somehow the fuel pool valves such 21 that they were letting water into the containment. And 22 as they were running this other test, which had nothing 23 to do with the containment, the operators, being alert 24 and walking around, noticed tha t the containment level 25 had changed slightly.
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() 1 And th e test instructor didn't tell them to 2 look for the contsinment level, but they saw it because
{} 3 they were alert and they walk around, and they notice things, especially on a first of a kind plant. And they 4
5 discovered, sure enough, the operator had lef t the valve 6 open against instructions and that that was occurring.
7 That's sn example of a systems interaction, 8 which was subsequently corrected by tougher instructions 9 and thing of this sort, because the operator did violate to his rules. But I think tha t is an example where an 11 operator, or good operators, look when they are running 12 tests, whether or not they get hit from the blind side.
13 And I've been on. reactor startups, 14 experimental reactors, where we were doing things for 15 the first time. And you very, very gingerly approach --
16 you very gingerly approach the test and you are on 17 constant lookout for things that happen. This is just 18 always part of the test engineer's approach to things, 19 and I guess it is inherent.
20 So I just wanted to mention that. That has 21 been my experience in this area.
22 BY MS. LETSCHE: (Resuming) 23 0 Mr. Ianni, let me just ask question following 24 up on that. After the example you mentioned in this 25 BWR-6 plant, it might make sense to put somethino in the O
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O i precedure to ser, p1e se = heck out the operators, 2 whether or not they followed instructions on opening and 3 closing valves, isn't that right?
4 A (WITNESS IANNI) That instruction already 5 exists, and that operator I imagine had his hands
~
8 slapped pretty badly, because it was caused by an error 7 on his part when he left that valve open. And it was 8 not a major event, but nevertheless he lef t that valve 9 open. He had violated an existing procedure. So he to gets whatever punishment you get for violating existing 11 procedures.
12 It is all built into the system.
13 0 But I meant an instruction in the test O 14 procedure for the person conducting the test to make 15 sure that the operators have followed the procedures 16 that they are supposed to follow.
17 A (WITNESS IANNI) I'm sorry, is that a question 18 to me?
19 0 Well, it was sort of a follow-up to my earlier 20 question, and my only point was that when you have an 21 experience like that, wouldn't it make sense when you 22 discover something, that the experience that these 23 people have with respect to reactors and in conducting 24 these tests, they discover something tha t h a ppe ns, if 25 you have that kind of experience doesn't it make sense O
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() 1 to put it back into the system so that the next guy who 2 does one of these tests looks for it?
I
( 3 A (WITNESS McGUIRE) May I answer that?
}
l 4 0 Sure.
5 A (WITNESS McGUIRE) I worked for GE startup for 8 four years and we have an in-house procedure called an 7 operating event report. Those types of things you just 8 mentioned would be distributed to all the startup 9 organization within GE and at all of the other sites to to incorporate it there. That is a way of flagging events 11 tha t could happen.
12 (Counsel for Suffolk County conferring.)
13 0 I don't have any other questions on this O 14 section. I don't know if any of the other panel members 15 understood that I didn't mind if you wanted to chime in 16 at this point. But if not, I will move on to the next 17 section.
18 JUDGE BRENNER: Do you mean no other questions 19 on subsection L?
20 MS. LETSCHE: Yes, that's right.
21 Subsection M --
22 JUDGE BRENNER: Ms. Letsche, this would be a 23 good time for the mid-morning break.
24 MS. LETSCHE: That's fine, Judge Brenner.
25 JUDGE BRENNER: We're going to take a longer O
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l 5219 O i sce k this orning. rhe so rd a.s so.. ..tters to 2 discuss. We're going to take a half-hour bresk until j 3 11:00. :
4 (Whereupon, 10:30 a.m., the proceeding vss 5 recessed, to reconvene at 11:00 a.m. the same def.)
6 7
8 9
10 11 12 13 -
i j
O 14 l 15 j 16 l 17 i
i 18 l
19 20 21
- 22 1
23 24 i 25 I
O t l
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() 1 (11:20 a.m.)
2 JUDGE BRENNER: Let's go on the record.
3 We apologize for keeping everybody out longer
('}
4 than we predicted. I will use the same line I've heard 5 f rom probably each of the parties at one time or 6 another by having more time to confer, we vill be more 7 efficient on the record.
8 (Laughter.)
9 JUDGE BRENNER: I have two matters before we 10 resume cross-examina tion. One relates to the substance 11 of -- well, not the substance, but it relates to the l
12 contention and one does not. The ones which does not is 13 a minor logistical problem that the Board is O 14 experiencing with respect to the hearing space here, and 15 ee would like to take it up at the end of the day with te lead counsel for the parties. So if they could be 17 present at the end of the day, we would appreciate 18 thst. It will only take a few moments.
19 With respect to the contention, we received a 20 revised Staff cross-examination plan on this contention 21 this morning, and consistent with our policy in the l 22 past, we do indeed appreciate receiving revised plans 23 when psrties have adjusted their plans.
24 We do have a concern, Mr. Rawson, about the 25 second paragraph on page 2, and I infer from the l (~)
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( 1 paragraph that you would have no trouble with my reading 2 or paraphrasing that paragraph. But I want to make sure
(} 3 before I do it.
4 MR. RAWSON. No, sir, I would have no problems 5 with that.
6 JUDGE BRENNER: Perhaps I had better quote the 7 paragraph: "The Staff will offer rebuttal testimony on 8 this issue" -- referring generally to contention 7(b).
9 " Staff witness James H. Conran, Sr., was primarily to responsible for the development of the Denton 11 memorandum. He will be asked to discuss the background 12 and definitions of the Denton memorandum and its 13 consistency with substantive industry and NRC Staff O 14 practice. Mr. Conran was the Staff's witness on this 15 subject at the TMI-1 restart hearings, where the Denton 16 classification terminology was adopted by the Licensing 17 Board involved. The Staff believes Mr. Conran is the 18 Staff witness best qualified to address this subject for 19 the Board. (Counsel for LILCO and Suffolk County have 20 been informed that the Staff will offer testimony in 21 rebuttal on the subject of the Denton memorandum.)"
22 Our concern is not with the presentation of 23 this testimony, but rather some procedural matters. The 24 Staff's original cross-examination plan disclosed a 25 desire to of fer some rebuttal, and if I recall the words O
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V 1 of that plan, Mr. Rawson, it was either as part of the 2 Sta f f 's case or sepa ra tely, at the direction of the 3 Board. Is that essentially correct?
4 MR. RAWSON4 It is essentially correct, Judge 5 Brenner, yes.
6 JUDGE BRENNER: I was concerned when I read 7 that. I had a conversation with you as to whether --
8 off the record, as to whether it would be -- the 9 conversation was off the record -- as to whether it 10 would be brief questions along the line of the quick 11 type rebuttal we permitted or whether it would be 12 extensive.
13 I had no idea of the subject area, and you O 14 said it would be quick. As I read this paragraph, it 15 doesn't appear to be quicks it appears to be extensive, 16 and certainly important, potentially. It also raises 17 the question in the Board's mind as to whether this 18 should have been included in the direct testimony. This 19 subject was certainly at issue from day one on this 20 contention, and in fact we were frankly somewhat 21 surprised not to find more of it in the Staff's 22 testimony.
23 We don't want to hear it for the first time 24 orally, is the long and the short of it, and we don't 25 think the parties should be subject to that, either.
O ALDERSON REPORTING COMPANY, INC, 400 VIRGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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4
() 1 You have also attached material to the revised 2 cross plan which relates to tha t subject, some of which 3 you may use in cross-examination but sone of which might 4 also be pertinent as part of this additional testimony.
5 And I would like to hear the Staff view'in response to 6 our reaction.
7 Basically, what we have in mind is to require 8 that it be filed in writing on July 1st.
9 MR. RAWSON: Judge Brenner, that would present to no problem for the Staff. When I said that we 11 anticipated that the rebut tal testimony of Mr. Conran on 12 this subject would be brief, it was my intention to 13 convey the idea that it would be a series of perhaps a O 14 half a dozen questions on oral examination, which is all 15 that I still anticipate that it would take for the Staff i
16 to make the points it wants to make in this area.
17 With respect to the issue having been raised 18 earlier in contention 7(b), the Staff did not think that 19 there was anything in the te stimony that was filed by 20 Suffolk County which called for rebuttal in this area lur 21 the Staff. The Denton memorandum was cited and we had 22 no problems with the citations that were used 23 specifically by Suffolk County.
() 24 There ware a couple of general statements in 25 some of LILCO's prefiled testimony which we thought
(
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() 1 called the issue into the contention and to which we 2 think it appropriate to respond.
I 3 JUDGE BRENNER4 Well, the long of the short of O 4 it is, in addition to any particular rebuttal to 5 particular points, we think -- and we thought even 6 before seeing this, but after reviewing this last 7 testioony -- that this area was deserving of greater 8 amplification, given the contention, without regard to 9 the testimony of the other parties.
10 We are not raising this now so as to prevent 11 you from putting it in. Quite the contrary, we are 12 anxious to see it. We are raising it as anather reason 13 as to why it should be in writing and as to why you 14 should consider the contention and what the Staff might 15 have to offer to assist the record on it in addition to 16 just pure rebuttal.
17 I don't want to take advantage of your 18 agreeable approach to saying July 1st is no problem, and 19 maybe you'll learn to be less agreeable in the future.
20 Tha t leads me to the next questions Can you better July 21 1st? July 1st is very tight. For us to be prepared, we 22 want to hear it that following week.
23 JUDGE JORDAN: Wouldn't the Conran testimony
() 24 that he presented at T3I-1 as is be suitable?
25 MR. RAWSON. Judg e Jordan, I think there are
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() 1 some dif ferences in emphasis which the Board would want 2 to be made aware of and which we ought to bring to the 3 Board's attention in that regard. Certainly the
(}
4 testimony that was provided *here goes a long way toward 5 the testimony that we would be planning to introduce.
6 Judge Brenner, I at this time would anticipate 7 no problems in filing that with the Board and with the 8 parties on July 1st, which I understand to be next 9 Tharsday. That would present no problems for us. And 10 certainly if that estimate changes after we have had a 11 chance to discuss this today and tomorrow, I will 12 certainly let the parties know that.
13 JUDGE BRENNER: Well, a change later would be O 14 very serious. Let me mention that, in terms of where we 15 are in the schedule of this hearing. So please don't 16 sake that request lightly.
17 HR. RAWSON: We will make every effort to file 18 it before July 1st.
19 JUDGE BRENNER: That is the part I really 20 wanted to hear. July 1st is tight for us. We would 21 like to receive four copies at the Board offices on July 22 1st, and in addition please send a copy to Judge Jordan 23 Express Mail on tha t date, and of course make
( 24 arrangements for rapid delivery to the other parties.
25 Again, this isn't in the nature of O
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() 1 discouraging the offer. In fact, to the contrary, we 2 apprecia te it. We just want to make its use more 3 efficient for the Board and the parties.
4 .MR. RAWSON: We understand, sir.
5 JUDGE BRENNER: We can resume the 6 cross-examination at this time. We vill go until 12:30 7 and then take an hour and 15 minutes for lunch.
8 WITNESS KASCSAK Excuse me, Judge Brenner.
9 If I could just correct an error that I had introduced to earlier, in particular in regard to the number of 11 individuals involved in the ISAG program.
12 I had erroneously assumed that in the formal 13 identification of this program in our correspondence 14 with the NRC, tha t when we had used the number of five 15 individuals in tha ISAG program that that included the 16 chairman, and I was incorrect. The chairman is not 17 counted in tha t five, so there is actually siz 18 individuals. There will be the chairman and five 19 individuals at the plant site, of which the group leader 20 vill be the primary individual responsible for that 21 group.
22 JUDGE BRENNER4 Okay, thank you. And when we 23 get that information --
( 24 WITNESS KASCSAKa In addition, we will 25 hopefully have for you today all of the other ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 inf ormation you've requested relevant to that 2 organization.
{} 3 4
JUDGE BRENNER: Thank you.
difference in completeness and also on your physical If it makes a 5 ability to conduct your lives, tomorrow will be okay 6 also.
7 WITNESS KASCSAK: We will do the best we can.
8 BY MS. LETSCHEs (Resuming) 9 0 Mr. Robare, I would like to direct your 10 attention to section M of your testimony on page 63, 11 which refers to protection systems. I believe you 12 stated earlier that you were involved in the evaluation 13 that is referenced in this portion, is that right?
O 14 A (WITNESS ROBARE) Yes. That study was 15 actually completed in 1970. My association at the time 16 of preparation was not that detailed. Since the 17 publication of that report, I have been involved in the 18 utilization of it specifically on Shoreham licensing 19 matters.
20 0 Does this study have a name or title?
21 A (WITNESS ROBARE) Yes, it does. The title is 22 " Compliance of Protection Systems to Industry Criteria 4 23 General Electric BWR Nuclear Steam Supply System." It's 24 number is NEDO-10139. It is da ted June 1970.
25 If I could characterize the approach to this O
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5228 O ' resort- it - aeaeric revie or the swa to sno-2 compliance with the at that time draft IEEE Standard 3 279. It utilized FMEA's to show compliance with the 4 stsndard, and included in the standards requirements are 5 single failure demonstration, general integrity, general 6 independence, control and protection system 7 independence, channel bypass, and removal from 8 operation, and numerous other design requirements.
9 The stuiy included the reactor protection 10 system, the emergency core cooling systems, and the 11 reactor isolation systems -- essentially, all of the 12 major safety systems in the nuclear steam supply.
13 (Counsel for Suffolk County conferring.)
14 15 16 .
17 18 19 20 21 22 23 24 25 O
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() 1 0 Mr. Robaire, this study showing compliance 2 with the IEEE requirements, is that a regulatory
{} 3 requirement?
Shoreham has made a 4 A (WITNESS ROBARE) 5 commitment to comply with IEEE-279-1971 and I believe 6 that is also referenced in a regulation, so I would say 7 it is a regulatory requirement that the plant meet 8 IEEE-279. I don't know that the study is required as a 9 regulatory requirement.
10 0 Thank you for that clarification.
11 You state in your testimony that this 12 evaluation included aspects of separation and system 13 interaction. Can you tell me what the aspects of system O 14 interaction are that you are referring to there ?
15 A (WITNESS ROBARE) Yes. The FEEA has included 16 a broad look at interactions within protection systems 17 and ECCS and containment isolation systems and also any 18 interactions that might occur between the safety systems 19 and the control grade systems.
20 (Counsel for Suffolk County conferring.)
21 0 By control grade systems, Mr. Robare, do you 22 sean systems like feedvater control?
23 A (WITNESS ROBARE) Yes, I do.
( 24 0 The FMEAs were -- were they limited to single 25 failures?
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() 1 A (WITNESS ROBARE) That is generally the FMEA 2 technique. I can't be positive whether there may be 3 instances of multiple f ailure evalua tions in the 4 report. I am not svare of thst detail right now.
5 Q What kinds of interactions -- systems 6 interaction was this study intended to identify?
7 A (WITNESS ROBARE) Primarily they are 8 functional systems interactions and a significant 9 emphasis on human or operator and maintenance type 10 errors.
11 Q The study that you referred to that was done 12 in 1970, that was just a generic study, though, right?
13 A (WITNESS ROBARE) It was not just a generic 14 study. It was a study of BWRs that applies directly to l 15 Shoreham. In fact, it is referenced in the Shoreham 16 FSAR.
17 0 In doing the study, though, when you were 18 looking for human interactions what sort of operating 19 procedures -- did you review operating procedures as 20 part of the study?
21 A (WITNESS ROB ARE) The human interaction 22 aspects of IEEE 279 have to do with -- primarily with 23 channel bypass systems, channels out of operation --
24 that sort of thing --
not operational error Der se.
25 Q Did you review -- well, I am not sure how to l ()
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() 1 ask this question. What data did you utilize in doing 2 the human systems interaction portion of that study?
{} 3 A (WITNESS ROBARE) Well, we didn't use data per 4 se. He took the elementary diagrams for all of the 5 systems and we evaluated f ailures in equipment out of 6 service and assured ourselves that the protection system 7 functions would not be degradated by such failures. In 8 other words, we assured complete electrical and 9 functional separation in light of single failures.
10 (Counsel for Suffolk County conf e rring. )
11 Q Mr. Robare, has this 1970 study been updated 12 to reflect design changes subsequent to 19707 13 A (WITNESS ROBARE) No, it has not. The 1970 0 14 study wa s prepared before the Shorehan design was 15 completed in order to show the appropriateness of the 16 General Electric design for the systems. Since the 17 report, the Shoreham-specific designs have been i 18 completed and, as the FSAR states and demonstrates, the l
19 design has been continually in full compliance with IEEE 20 279.
l l
21 Q Is that documented in Chapter VII of the FSAR?
22 A (WITNESS ROBARE) Yes, it is.
23 Q What was done to make the determination that 24 the Shoreham design is in compliance with the IEEE 25 requirements?
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() 1 A (WITNESS ROBARE) IEEE 279 is one of the prime 2 design requirement tools in the design of these systems 3 and the designers are constantly aware of those 4 requirements and have design record files demonstrating 5 for Shoreham specifically compliance to each paragraph 6 of that standard. It is constantly revieva$ whenever a 7 design change is contemplated for the systems.
8 0 There weren't any Shoreham-specific FMEAs or 9 FMEAs, let's say, performed in making the determination 10 that is reflected in the FS AR?
11 A (WITNESS ROBARE) As I previously stated, the 12 FMEAs in the generic report are directly applicable to i 13 Shoreham and a re ref erenced in the FSAR. In cases where
'- 14 there were plant differences they are addressed in the i
15 generic report.
16 0 They are addressed in the generic report?
17 A (WITNESS ROBARE) Yes, they are. For 18 instance, there are differences in plant size within the 19 BWRs that are addressed in the report.
20 0 In the 1970 report?
21 A (WITNESS ROBARE) Tha t is correct.
22 JUDGE JORDAN: Isn't cable separation an 23 important part of IEEE 279, Mr. Robare?
() 24 WITNESS ROBARE: Yes, it is.
25 JUDGE JORDANS And so, theref ore, d oesn 't tha t ALDERSON REPORTING COMPANY,INC, 400 VIRGINtA AVE, S.W., WASHINGTON, D.C. 20024 (202) $54-2345
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() 1 part at least have to be plant-specific?
2 WITNESS ROBARE: IEEE 279 requires that the 3 divisional safety circuits be separated and that has O 4 indeed been the case in the Shoreham design. That is a 5 requirement by the designer placed in both the panel 6 manufacturing and on the Stone and Webster cabling 7 outside of the panels.
8 JUDGE JORDANS Well, the previous testimony g that you have given here on cable separation, wasn't 10 that partly done to assure compliance with IEEE 279?
11 WITNESS ROBARE: Yes, it was.
12 JUDGE JORDAN. And then I guess I am still a 13 little bit puzzled by why you say the ganaric study 14 assured complia nce of Shoreham. It seems to me it took 15 more than a generic study. It took some site-specific 16 study.
17 WITNESS ROBARE4 Well, the generic study 18 assumes that when the designer establishes the i
19 requirement for separation of safety divisional circuits 20 that that process is properly incorporated in the 21 plant. So he would be satisfied for his purposes in 22 design knowing thst he had established that 23 requirement. He would not necessarily keep a list or a
() 24 tabulation of all of the cable in the plant. He would 25 establish that requirement.
(
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() 1 JUDGE JORDAN: I guess then my problem was 2 only that IEEE 279 applies to the design and not to the
/^ 3 as-built plant. Is that correct?
V}
4 WITNESS ROBARE: No, it applies to both. It 5 is a design requirement that has to be demonstrated in 6 the as-built plant.
7 JUDGE JORDAN: Well, I guess I was -- this is 8 perhaps terminology that is puzzling me, and since you 9 d id testify as to the cable separation, at least tha t 10 part demonstrates that to your satisfaction that the 11 Shoreham plant does meet the aspect of IEEE 279. But 12 are there other aspects -- of 279 that are also 13 site-specific and have to be demonstrated in the case of l
14 the as-built plant outside of the generic studies?
15 WITNESS ROBARE: The designers of these 16 systems -- and there would be more than one individual 17 involved -- would utilize the requirements of IEEE 279
! 18 in establishing the elementary diagrams for those l
19 systems and they would include compliance with all of 20 the other aspects of 279 in addition to cable separation 21 -- for instance, channel integrity and independence and 22 Separation from control systems and thst sort of thing.
23 JUDGE JORDAN: All right. But I guess I don't 24 see how a 1970 generic study really gives you a great 25 deal of confidence that the Shoreham as-built plant
(
l l
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() 1 complies with IEEE 279. That is my problem. You see 2 where it is?
3 WITNESS ROBARE: I think I do. I think I 4 would characterize it that the 1970 study established 5 the appropriateness of the basic BWR design and then on 6 each plant the responsible designer would assure 7 specifically that those requirements are met in each 8 aspect of 279.
9 JUDGE JORDANS Fine. Now, the.n, has that been 10 documented? I guess I should address that question to 11 Mr. Kascsak. Could I ask, Mr. Kascsak, do you know that 12 the as-built plant meets the requirements of 279 and, if 13 so, how do you know that?
14 WITNESS KASCSAK Well, I would say that the 15 co3pliance with 279, as it compliance with many other 16 design documents, is a require, ment that is inherent in 17 the design process in the sense that the designers who 18 prepare the Shoreham-specific drawings ensure that the 19 drawings reflect that compliance and that our program 20 would assure that the as-built plant reflects the design 21 re7uirements in those documents.
22 I don't believe there has been an explicit 23 investigation into whether we have complied with 279.
() 24 JUDGE JORDAN: Are you only saying, therefore,
, 25 that the design complied with 279, and that you have l
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5236 1 other ways of making sure that the as-built plant meets 2 the design?
3 WITNESS KASCSAK: Yes.
4 JUDGE JORDAN All right. I think that clears 5 up my particular semantic problem that I had. Go ahead.
6 BY MS. LETSCHE (Resuming) 7 C Mr. Robare, isn't compliance with the IEEE 8 requirements dependent, in addition to the design, on 9 the particular equipment that has been purchased to be 10 used in the plant?
11 A (WITNESS ROBARE) I'm not quite sure what you 12 sean by that. Do you mean the qualification of that 13 equipment or the design of the equipment?
14 0 Any aspects of the equipment -- the 15 qualification, the design, the manufacture.
16 A (WITNESS ROBARE) Are you asking me does IEEE 17 279 require vendor-type requirements? I'm not aware of 18 tha t.
19 0 I guess maybe my question wasn't quite 20 specific enough. In order to have confidence that there 21 aren't going to be any adverse systems interactions in 22 the systems that were reviewed within the report that 23 you mentioned to us, isn't it also necessary to look at 24 the particular equipment or components that have been 25 chosen by the party who has constructed the plant O
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5237 O i ccordine to the desion?
2 A (WITNESS ROBARE) Yes. And the reason we have 3 ass ur an ce that the design is adequate is that all of the 4 components required to provide a safety function are 5 fully safety grade on Shoreham and have been qualified 6 and have QA to provide us with that assurance.
7 0 The GE study that you referenced in this 8 portion of your testimony did not look at that element, 9 though, did it?
10 A (WITNESS ROBARE) No, it did not. It was not 11 a qualifica tion program. It looked at both safety 12 grade -- I am sorry to interrupt you. May I finish?
13 0 Finish your answer, please.
O 14 A (WITNESS ROBARE) It looked at both safety 15 grade and non-safety grade equipment and assumed it 16 f ailure independent of its pedigree.
17 (Witnesses conferring.)
18 (Counsel for Suffolk County conferring.)
19 0 3r. Robare, let me see if I understand the 20 process that goes on here. When you, GE, have a design 21 spec -- which is what I assume you were talking about in 22 the evaluation of the BWR-5 design -- and it says you 23 have to use component X, this black box that complies 24 with the requirements of IEEE, what if the black box 25 that the person constructing the plant buys is a O
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() 1 different black box from the one that you might have 2 specified or the one that you might have had in mind?
3 The internals of the black box might be different.
4 Isn't it necessary to look at the specific 5 black box they bought in response to that design 6 requirement?
7 A (WITNESS ROBARE) Well, certain it is, and we 8 have two situa tions there. One are black boxes that 9 General Electric designs and manufactures in those cases to as part of the design process, we would do FMEAs to 11 ensure that no single failure could affect the operation 12 of that component.
13 Similarly, for purchased components we,would O 14 establish that requirement in the purchase
( 15 spe cifica tion , that no single failure can preclude the 16 operation of the =omponent.
17 0 And then that is something that the person 18 constructing the plant would have to verify -- that in 19 fact the black box they purchased does meet that single 20 failure criterion? That is not something GE reviewed is 21 my only point.
22 A (WITNESS ROBARE) No. That is something that 23 GE reviews. The GE designers are fully responsible for
() 24 the specification and adequacy of the components, 25 whether we purchase them or make them -- manufacture I
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() 1 them.
2 0 Well, have you reviewed the equipment at the 3 Shoreham plant -- the Shoreham equipment -- rereviewed 4 it to make sure that everything is the same as what you 5 assumed in your 1970 study?
6 A (WITNESS ROBARE) Hsve I personally or has 7 General Electric?
8 0 Well, have you personally, first?
9 A (WITNESS ROBARE) We are talking hundreds, if 10 not thousands, of components. I have not personally 11 investigated each of those, but the reason I have 12 assurance that the design is adequate is because 13 components that are needed to perform a saf ety function 14 have been rated or qualified as safety grade and that 15 means they are designed and have quality assurance, as 16 ve discussed previously, to give us the assurance tha t 17 that is extremely high quality, reliable equipment.
18 And additionally, the overall system design 19 allows a single failure and the performance of that 20 safety function should there be a failure.
21 (Counsel for Suffolk County conferring.)
22 C "r. Robare, perhaps you have answered it --
23 and maybe it's my problem -- but let me just ask one
() 24 more question and hopefully finish this.
25 Does the GE designer -- whoever wrote the GE O
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() 1 design spec -- review the particular component in the 2 Shoreham plant and make a determination that that 3 component complies with IEEE 2797 4 A (WITNESS ROBARE) He would certainly review 5 the design of each component. Now often we have one 6 component that is applie.d to 40 plants, so he would not 7 go to 40 sites to look at that same component. But he 8 would be intimately aware of the design and adequacy of 9 that component to meet his requirements in the design 10 specification and purchased part drawings.
11 (Counsel for Suffolk County conferring.)
12 0 If the reviewer or the designer is looking at 13 the componen t that is going to be in 40 plants and the 14 manufacture of that component changes at some point over 15 that time period -- 1970 up to where we are now -- does 16 the designar go back and look again at new manufactured 17 components?
18 A (WITNESS ROBARE) This is where the Appendix B 19 quality assurance program for safety grade equipment 20 comes into play. If a manufacturer is changed, then 21 there would be a requirement to evaluste that 22 manufacturer and to assure that his design is adequate 23 and meets all of the requirements and that a prototype
() 24 testing program would be incorporated and our engineers 25 would have to be fully satisfied tha t the component O
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meets all of the requirements that the grevious vendors
(]) 1 2 met.
3 0 okay. I would like to move on to the next 4 section of the testimony on page 53.
5 JUDGE MORRIS: Ex cus e me , Ms. Letsche. Mr.
6 Robare, I am not sure I fully understood the scope of 7 this study. Your last sentence says: "If selected 8 failures modes and effects analyses were performed."
9 Could you explain what you mean by " selected?" Was this 10 a few out of many possible or were they selected because 11 of some standard importance? Just what was the 12 selection?
13 WITNESS ROBAREs The word " selected" was 14 perhaps a poor choice of wo rd s. We re ally looked at all 15 of the failure modes that could affect the operation of 16 all of the protection systems. " Selected" did not mean 17 to imply we only looked at certain ones. That is 18 documented in the report.
l 19 JUDGE JORDAN: Mr. Robare or any member of the 1
20 panel, is it the LILCO position that compliance with 21 IEEE 279 is important in eliminating at least certain 22 types of system interaction such as common mode failures 23 due to cables running near to each other where a fire
() 24 could affect all of the cables and such other matters as 25 th a t , that compliance with IEEE 279 is important in O
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() 1 achieving high reliability for the protection system 7 2 But is it your position at this instant that 3 IEEE 279 guarantees that there will not be system 4 interactions, that there will not be any possible common 5 mode failures?
6 WITNESS ROBARE: No, I don't think we could go 7 that far. We feel that IEEE 279 is certainly a very 8 thorough industry standard that assures to a very 9 reasonable degree the separation and independent of 10 safety systems within their own divisions and separation 11 from the control systems.
12 I don't think it demonstrates or precludes the 13 possibility of common mode failures. However, I don't 14 think we could say that IEEE 279 compliance would 15 eliminate that probability.
16 JUDGE JORDAN: I notice the next section we 17 vill be dealing with reliability of the scraa system, so 18 I shall not pursue that further at this particular 19 moment excepting to ask since you have gone further than 20 IEEE 279 in evaluating scram failure, have you also gone 21 f urther than IEEE 279 in elimina ting other failures --
22 failures in the other systems that you said you applied?
23 WITN ESS ROBARE That is a very broad question.
() 24 JUDGE JORDANS Yes, it is a broad question, 25 but I guess I realize that your testimony has emphasized O
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() 1 one aspect of -- namely the scram f ailure -- and I only 2 vant to question then why didn't you also emphasize your 3 further efforts to improve the reliability, say, of the 4 ECCS system? That is, as you said, compliance with the 5 IEEE 279 is by no means a quarantee. It does not 6 prevent multiple failures, isn't that correct?
7 WITNESS ROBARE: That is correct.
8 JUDGE JORDAN. Now how about the other 9 systems? Have you dono a study of the reliability of 10 the other systems to common mode failures equivalent to 11 that, that you presumably have done and will be 12 addressing in the next section?
13 WITNESS ROBARE: Yes, we have. I would like O 14 to state that the systems interaction-related studies in 15 our testimony are a sampling of major studies that were 16 formally published as part of the design process. We 17 have definitely done a lot more than that and I believe 18 Mr. Ianni here was directly involved in the ECCS 19 reliability evaluations. Mr. Ianni could address that 20 further if you like.
21 JUDGE JORDAN Yes, I think it would be well 22 to have that on the record at this point since it is not 23 going to be addressed a t other places because it is a 24 aost important item.
25 WITNESS IANNI The basic ECCS for Shoreham O
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() 1 and all of our power plants were derived after the 2 mid-1960s when we initiated the basic ECCS network.
i
{} 3 After we did that on Dresden-2, then we went back on the BWR-4, which was then new, and we did for that time a 4
5 very thorough reliability analysis of the ECCS network 6 and we had just started the Rel'iability Group at that l
7 time under Ivan Jacobs and that was one of the first 8 jobs we had was to try and balance the ECCS network.
9 And as a result of that study we arrived at to adding, f or exam ple, a radundancy in the auto blowdown 11 circuit as one of the fallouts of that study, because 12 the study indicated to us that that path to success 13 boosted the overall reliability of success because it l 14 made available to the ECCS all of the low pressure pumps 15 that might be in the plant, and so we did upgrade that 16 system even though it didn 't make sense from a single 17 failure criterion. It was not required.
18 We also looked at the electrical network --
19 that is, the diesel tie-ins and things of this sort. We 20 did reliability studies on that and in general we 21 applied what amounted to state-of-the-art at that time 22 in designing the basic systems as you see them today.
23 And as far as common mode failures, one of the 24 things we were worrying about was -- phenomenological 25 common soda failure -- was if it doesn't flood right you O
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O i a a detter ear 1 it 1 o- so eacea == ita t o r-2 of introducing the water over the core -- one which is 3 at the top that sprays. In addition to that, we flooded 4 from the bottom.
5 And we had, as a result of this study, we had 6 big discussions about the phenomenon and why did we need 7 to do it two ways and that we wanted functional 8 diversity. We didn't know as much about core cooling 9 then as we do now, and the Reliability Group indicated 10 that the probability of success would be enhanced 11 significantly by having two modes of cooling the core 12 independent of each other at the phenomenological level.
13 So that is how we used it on ECCS as far as my 14 experience goes.
15 JUDGE JORDAN: This next question will reflect 16 my unfamiliarity. Part of the ECCS system, of course, 17 is the HPCI. Now does the HPCI include both the spray 18 and the core flood from the botton? Does that tern 19 include both?
20 WITNESS IANNI N o, sir. HPCI is flooding 21 only. It injects wa ter into a circular sparger outside 22 the core.
23 JUDGE JORDAN: So tha t provides flood from the 24 bottom?
25 WITN ESS I ANNI 4 Yes, sir.
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() 1 JUDGE JORDAN: Now that is not a redundant 2 system so in itself it does not meet 279, is that 3 correct?
4 WITNESS ROBARE: The design of the HPCI system 5 does meet IEEE 279. I believe you are thinking the 6 broader context of the overall plant safety systems.
7 Since that is a single train it is obviously not single 8 failure proof.
9 JUDGE JORDANS I hadn't realized that. Are to you saying IEEE 279 does apply to single channel systems 11 also?
12 WITNESS ROBARE: Yes, it does. It requires 13 multiple sensor inputs and logic separation and 14 diversity. However, on a systen level the system cannot 15 be single failure proof since there are single 16 components such as the turbine which could fail.
17 JUDGE JORDAN I see. It is'the final 18 component that is not redundant. The other systems are 19 redundant. Is that correct ?
20 WITNESS ROBARE: Well, some of them are.
21 JUDGE JORDAN Well, the sensors and the logic.
22 WITNESS ROBARE: Yes. But on a total ECCS 23 network basis there is a redundant system to HPCI, and
() 24 that is the automatic depressurization system. So that 25 meets single failure criterion for a high pressure O
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() 1 function on a system level basis.
2 JUDGE JORDAN: And the two systems together then do meet the separation and redundancy requirements
{} 3 4 of IEEE 279?
5 WITNESS ROBARE Tha t is correct.
6 JUDGE JORD AN All right. I didn 't want to go 7 further myself right at the moment. There will be 8 questions as to whether IEEE 279 is an adequate response 9 to all systems -- to systems inteciction, but we will 10 pursue that later.
11 JUDGE MORRIS 4 Just to make sure the record is 12 clear, could you please summarize what 279 is applied to?
13 WITNESS ROBARE: Yes. IEEE 279 is applied on O 14 the BWR to the reactor protection system -- that is, the 15 system that provides the scram signal. It applies to 16 the emergency core cooling systems and that would be 17 HPCI, ADS, LPCI, and core spray. And it applies to the 18 containment isolation system -- that is, the automatic 19 signals to isolate for vessel isolation. In Shoreham it 20 is called the nuclear steam supply shutoff system.
21 JUDGE MORRIS: Again for further 22 clarification, does 279 apply only to the electrical 23 parts of those systems, or does it apply to piping
) 24 systens, subsystems?
25 WITNESS ROBARE: It is an electrical design O
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() 1 standard. It does not apply to the mechanical piping.
2 BY MS. LETSCHE: (Resuming)
(} 3 0 I would like now to move to Section N on scram Mr. Robare, when was this -- was this also 4 reliablity.
5 a GE generic study?
6 A (WITNESS ROBARE) Yes, it was. It was issued 7 September 30, 1976.
8 ,0 Does it have a name?
9 A (WITNESS ROBARE) Yes. The name is "BWR Scram 10 System Reliability Analysis." I do not have a version 11 with me today that has the report number on it.
12 0 Was it prepared at the request of or submitted 13 to the NRC?
O 14 A (WITNESS ROBARE) This report was prepared as 15 part of the ATWS generic work. It was supported by the 16 utilities and submitted to the NRC, yes. I would not 17 characterize it as required by the NRC.
18 0 This was not a Shoreham-specific study, was it?
19 A (WITNESS ROBARE) It was not only 20 Shoreham-specific. It was a generic study that included 21 or bounded the Shoreham plant design and product line.
22 In other words, the reference plan that was used bounded l 23 the Shoreham ATWS situation.
24 0 Was this study then looking specifically at 25 the ATWS event?
O ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5249 (WITNESS ROBARE) Well, it was prepared in the
(]) 1 A 2 context of the ATWS generic issue. It was looking
- 3 specifically at the scram reliability of the BWR and it 4 included common mode failure analyses and FMEAs and 5 event trees in order to establish a quantitative l
6 reliability number for scram reliability.
7 Q You state here that this was a study of 8 functional interactions. That was the only type of 9 systems interaction that it was designed to identify?
10 A (WITNESS ROBARE) I believe it also included 11 the operator or human interaction possibilities.
12 0 When you say that the study was of functional 13 interactions in your testimony here, can you tell me 14 what -- be a little more specific in the types of 15 interactions you dere referencing there?
16 A (WITNESS ROBARE) Yes. There are extensive 17 use of FMEAs in those analyses which establish 18 functional interact.'.ons, numerous functional interaction 19 possibilities, aEsumed single failures and consequences 1
20 on multiple systees, in other words.
21 (Counsel for Suffolk County conferring.)
22 Q Has this study been updated since it was done 23 in, I believe you said, '767
() 24 A (WITNESS ROBARE) I don't believe it has, no.
25 JUDGE MORRIS: Excuse me. In your answer, Er.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
5250 0 1 Rohere, rou were confinino reurse1f to cenera1 t1ectric 2 update and not ne:essarily other studies of this kind?
3 WITNESS ROBARE: Yes. I meant to state that 4 this particular stuiy wss not upda ted. Now there have 5 been other studies in the context of the ATWS issue tha 6 relate to this.
7 BY NS. LETSCHE: (Resuming) 8 0 Was this study limited to the electrical 9 systems, as the earlier one wes?
10 A (WITNESS ROBARE) No, it is not. It evaluates 11 all potential failures, whether they are electrical or 12 sechanical.
13 (Counsel for Suff olk County conferring.)
0 14 Q Did it include a study of the control rod 15 drives themselves?
16 A (WITNESS ROBARE) What do you mean a study of 17 th~e control rod drive?
18 0 Did the study include or did your FMEAs 19 include tha possibility of failures in the control rod 20 drive?
21 A (WITNESS ROBARE) Yes, it did.
22 Q How about f lures in the nitrogen accumulator?
23 A (WITNESS ROBARE) It included failures of all 24 sort which could affect scram. .
25 JUDGE BRENNER: Is the answer then yes?
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O 1 WITNESS ROBARE: Yes, the answer is yes.
2 BY HS. LETSCHE: (Resumint) !
3 0 Did it includethepossibL11tyof}failuresin 4 the scram disenarge volume?
1 5 A (WITNESS ROBARE) Yes, it did.-
e 0 Did that study pick up th e possj bility > of the l incident at Brown's Ferry recen tly involvin g the scram 7
8 system?
9 A (WITNESS ROBARE) It' evaluated that ,
10 possibility, yes. That was one of the failure modes 11 that was considered. s 12 0 But there weren't any changes made-to prevent
'/
. 13 that from accurring? / /
! f ,
i . ,
14 A (WITNESS ROBARE) Not.as a result of this l .
15 report. There have been changes made at Shoreham to 16 alleviate that situation, yes.
/
17 0 Subsequent to.the Brown's Ferry event were 18 these changes made? ' >
19 A (WITNESS ROBARE) There were some changes made 20 subsequent to this report 'and additional changes hade
-/ .
21 subsequent to the event at Brown's Ferry. Thare were
/ >
22 recommenations in this report-to modify the screm , ,9
/
discharge volume, I believe instrumentation. -
23 l
24 0 GE made specific recommendations to 3horJham ] f ,4 ' '
/
25 specifically that changes be agde? "
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() 1 A (WITNESS ROBARE) Shorehas participated in 2 this report in that sense. They were advised of the 3 recommendations, yes.
[}
! 4 C Did GE or has GE reviewed Shoreham to
( r 5 determine whether or not the GE recommendations wee
- 6 implemented?
7 A (WITNESS ROBARE) The equipment in the scram 8 discharge volume is not in GE's scope of supply. We o
have made recommendations that we have been informed 9
10 have been incorporated in the Shorehan design. Yes,'we 11 have.
f
! 12 (Counsel for Suffolk County conferring.)
l 13 Q Nr. Robare, you said that the report that you
( referenced in you testimony did evaluate the possibility l 14 l
15 of an event such ss occurred at Brown's Ferry. I take 16 it -- well, did you make any recommendations to the 17 Brown 's Ferry plant that changes be made there as a l
18 result of what you discovered in your study?
19 A (WITNESS ROBARE) I really can't speak to that 20 with authority. I an only aware of how it was applied 21 to Shorehan.
22 0 Well, I guess my real question is, if the l
23 systems interaction study you referred to us to actually 24 evaluated this possibility, why did it happen?
/ f (WITNESS ROBARE) This study evaluated the l' 25 A 1:
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() I probability of a complete failure to scram. That did 2 not happen.
3 JUDGE BRENNER: Mr. Robare, in my 4 non-technical language it sounds to me like you are 5 saying it was a go-no go study. That is, if scram 6 failure did not occur that that was a successful result 7 and that was the end of the study. Is that what you 8 mean?
9 WITNESS ROBARE: What I mean is that the to reliability of the scram system or the probability of a 11 failure -- a complete failure to scram because of scram 12 discharge volume concerns -- that probability was 13 sufficiently low that major design changes were not 14 recommended or deemed necessary. There were some minor 15 changes recommended and when the partial failure to 16 scram actually occurred at Brown's Ferry we further 17 recommended more extensive changes.
18 But this report deals with a total failure to Ig scram and demonstrates that that probability, as we 20 still believe, is extremely low.
21 JUDGE BRENNER: Would it be a lengthy answer 22 on your part if I asked you to list what changes were 23 made after the report to Shoreham and then again what
() 24 changes were made after the Brown's Ferry incident to 25 Shoreham? We could come back to that after lunch, if O
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() 1 you want time.
2 WITNESS ROBARE: I could do that after lunch, 3 yes.
O 4 JUDGE BRENNER: After the Brown's Ferry 5 incident, was there any check, so to speak, on the 1976 6 study to go back and see whether the methodology of the 7 study could have -- or the applica tion of the 8 methodology could have been done in a sore improved way l 9 so as to have led -- so as to have been a better 10 pradictor of what occurred at Brown's Ferry and perhaps 11 led to identification of all of the changes solely as a 12 result of the study as distinguished to awaiting the t 13 event at Brown's Ferry?
14 WITNESS BOBARE: I really can't speak to that 15 with very much authority. I know that this report dealt 16 with the total failure of scram and the event was a 17 partial failure that was not considered at that time. I 18 really don't know whether they went back and used the 19 same methodology to evaluate the partial failure.
20 Mr. Ianni may be able to help you with that.
l 21 WITNESS IANNI Yes. We were involved in 1
22 doing some of the hydraulic analyses following Brown's 23 Ferry of the partial scram where, as you recall, the.
() 24 scram took place and brought the power down to about, 25 what was it, ten or 15 percent instead of zero and half l
O I
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(]) the rods hsd gone in and then the others they got in in 2 about five or ten minutes and brought it down to zero.
3 And indeed when we looked at our reliability 4 study fsilure to totally scram due to a problem in the
-7 5 volume was very, very low -- well, below 10 . Now 6 Brown's Ferry was a partial scram and that we did nto 7 evaluate. You can't put a number on it, and the 8 obviously question is having known -- well, first of 9 all, let me put something in perspective.
10 When you have statistically a probability 11 study and you see something that happens, say, once in 12 10,000 years, in order to get statistically significant 13 numbers of data on which to drav quantitative
\
l 14 conclusions you have got to go several times that. And 15 so when something is very improbable you have a hard 18 time deciding, based upon the basis of one incident, 17 whether or not when the next one is going to occur in l
i 18 400 reactor years, which is what our experience that we 19 have is -- 400 reactor years -- or that one would occur 20 again for a million years.
21 In other words, it has to do with what is 22 called statistical significance and the interval 23 between, f or very low probability events, the interval
() 24 that you can use to really measure yourself is extremely 25 huge since there isn't any way you can ever do it ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 experimentally. And so you take the conservative 2 approach and say well, I will assume that it might 3 happen again in 400 years and then you say if that 4 happened,what could I have done in my analysis.
5 The problem you run into is in trying to 6 figure out what did really happen there. We were never 7 able to pinpoint deterministically the actual cause.
8 For example, it may be in a random failure that occurred 9 because something was caught and then flushed out -- and 10 I am sure you have read the dif feren t reports and so 11 forth, and it seems like everyone has their own opinion 12 on it.
13 It could have been a statistical situation in O 14 which water accumulated at just the right time at that 15 point in time, or it could have been something 16 deterministic. So what was done in the fix was you did 17 everything you could assuming the worst, and that was l
18 the fix that was recommended to a;l of the plants, which 19 I saw, incident 111y, installed at Shoreham. It is there.
20 But to go back to the reliability studies to 21 say how can I improve it, you have to understand what l
22 happened to it, what caused it, and not knowing that it 23 is kind of hard to really say how could I correct it.
() 24 I guess all I can say is that probably the 25 estimate that we came up with f or the total f ailure ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5257 O i ight be too tow. Iou see the d11e a that we are in in 2 being able to correct the model? It is very difficult.
3 JUDGE BRENNER: Maybe we will come back to 4 this after the lunch break. What I as trying to find 5 out is -- and I will just throw this out for now and not 6 ask for an immediate response in view of the time -- but 7 I Want to find out whethat it is s f air characterization 8 that the events at Brown's Ferry disclosed an 9 interaction.
to If that is the esse, I then vant to know 11 whether the methodology of the study, putting 12 p robabilities asid e, was such that the potential for 13 that sort of interaction was shown and, if not, was the O 14 study relooked at again in that light to see how it 15 could be improved.
16 Let me stop here. There is a line of 17 questions that the Board wants to pursue along those 18 lines and rather than give you all of the questions and 19 then make it difficult, we vill come back to it. But I 20 understand your answer about-the probability, but I am 21 trying to focus on the identification of systems 22 inters: tion, particulsrly since this is one of the 23 studies cited in the direct testimony as shedding light, 24 if You will, on systems interaction potential.
25 MS. LETSCPE: Judge Brenner, if I might say O
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() 1 so, it might be helpful for the panel and possibly in 2 follow-up questions that we might be asking after the 3 lunch break if they were to review over the lunch break 4 the INPO report analysis. I think we might have some 5 questions referring to that. It talks about the causes 6 of the event.
7 JUDGE BRENNER: This is the first you are 8 telling them of this?
9 MS. LETSCHEs Yes.
10 JUDGE BR ENNER You know, they are getting to 11 miss a lot of eating time as a result of --
12 HS. LETSCHEa Judge Brenner, well, I think 13 obviously they can look at as much as they want, but the 14 first three or four pages have the suasary and the 15 conclusions of the report.
16 JUDGE BRENNER: Well, you can pursue it after I
17 lunch, but if they indicate they are not sufficiently 18 familiar with it to answer your questions, we will l
l 19 understand. Let me leave it that way. It is about a l
20 30-page report, is it not?
i l 21 MS. LETSCHEa Probably, yes.
22 JUDGE BRENNER: Small print, single space. My 23 Comment of yesterday applies to that also in terms of
() 24 earlier disclosure.
25 HS. LETSCHE: Judge Brenner, frankly I did not A
U ALDERSON REPORTING COMPANY,INC.
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5259 I realize we were going to have to. I didn't know when
(])
2 this study listed in the testimony had been done and 3 frankly I was sort of surprised by some of the answers I O 4 received.
5 JUDGE BRENNER: Let me ask the panel, are the 6 witnesses familiar with that study -- familiar in terms 7 of other than knowing of its existence -- that is, 8 knowledge of the contents?
9 (Witnesses conferring.)
to WITNESS KASCSAK: To give you a brief answer, 11 LILCO does get copies of all of th e NSAC re ports. It is 12 in our required reading list for'our engineers. I have 13 seen that study before and have read it briefly. It was
( 14 used in conjunction with other reports by our engineers 15 when we made decisions on making modifications to the 16 plant relative to this incident at Brown's Ferry.
17 It may be difficult to deal with it on a 18 page-by-page, sentence-by-sentence type of form, if tha t 19 is what we are going to get into.
20 JUDGE BRENNER: How about the GE witnesses?
I 21 WITNESS ROBARE: I have not seen the report l
22 previously.
23 WITNESS I ANNI: I have not seen this report
() 24 previously either, and I am sure there are probability 25 people who would have and the people who worry about the O
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() 1 scram system, which isn't in my area of responsibility, 2 so I never read this.
3 JUDGE BRENNER: All right. We will see where 4 it goes af ter the lunch break.
5 MS. LETSCHE: I might say, Judge Brenner, that 6 I don't intend to go through it in any grea t detail and 7 all of the charts and all of the other aspects of that 8 report, which is why I specifically mentioned the 9 beginning -- the first four or five pages -- and I 10 really don't intend any kind of detailed examination.
11 JUDGE BRENNER: Well, I understand, and it may 12 be that that is sufficient, but I can tell you 13 personally that when I sa asked questions about excerpts 14 from a document I am nervous about what I don't know 15 sbout the rest of the document, if you will, and what 16 you may consider unimportant the witnesses may consider 17 helpful context.
18 Let's break until 2s00.
19 (Whereupon, at 12:40 o' clock p.m., the hearing l 20 recessed, to reconvene at 2:00 o' clock p.m., the same 1
21 day.)
22 i
23
() 24 l 25 O
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3 JUDGE BRENNER: Let's go on the record. As we
)
4 discussed off the record, we will proceed with the cross 5 examination on the scram reliability study, Subsection 6 N, on page 63 of the testimony, and then the Board might 7 have questions regarding that study and the Browns Ferry 8 incident, depending upon what is asked prior to our 9 questions.
10 Whereupon, 11 GEORGE F. DAWE, 12 GEORGE GARABEDIAN, 13 PIO W. IANNI, O 14 ROBERT H. KASCSAK, 15 PAUL J. McGUIRE, 16 PAUL W. RIEGELHAUPT and 17 DAVID J. ROBARE, 18 the witnesses on the stand at the time of recess, 19 resumed the stand and, having been previously duly 20 sworn, were examined and testified further as follows4 21 CROSS EXAMINATION -- Resumed 22 BY MS. LETSCHE 23 0 M r. Roba re , did the NS AC study of the Browns
( 24 Ferry incident, which I gave you a copy of to review 25 over lunch, and that is NSAC-20, December 1980 entitled O
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() 1 " Analysis of Incomplete Control Rod Insertion at Browns 2 Ferry 3." Did that identify the possibility of a 3 systems interaction between the radvaste system and the
[}
5 ( Panel of witnesses conf erring.)
6 A (WITNESS B0 BARE) Can you tell me what page?
7 0 Well, I can refer you particularly to the 8 conclusions on page 5 where it is stated that 9 appropriate steps should be taken by all BWR plants to 10 g ua rd against -- and then the 1, 2, 3, third bullet down 11 there in particula r might help you to answer my question.
12 55. LEISCHE: Judge Brenner, maybe while the 13 witness is considering that, I would like to have marked O 14 as Suffolk County Exhibit 20 for identification a 15 document which consists of the first page and the 16 abstract, table of contents and introduction and 17 executive summary of the NSAC report I just referenced 18 in the record. It goes through page 5 of that report, 19 this excerpt.
20 JUDGE BRENNER All right, it is so marked for 21 identification.
22 (The document referred to 23 was marked Suffolk County 24 Exhibit No. 20 for 25 identification.)
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() 1 WITNESS ROBARE: Yes, that was a conclusion of 2 that report.
3 BY HS. LETSCHE (Resuming):
4 0 Was this type of systems interaction; that is, 5 one between the radwaste system and the scram discharge 6 volume, considered in the study that you reference at 7 page 63 of your testimony, scram reliability study?
8 A (WITNESS ROBARE) The report that is referenced 9 considered the failure of the scram discharge volume in 10 general. I do not know tha t it specifically addressed 11 that particula r f ailure mode.
12 0 Does that mean that it did not address that 13 particular systems interaction?
14 A (WITNESS B0 BARE) I really have not looked 15 specifically a t that. I know that the design at 16 Shoreham is different from the Browns Ferry design. And 17 we can talk about that, if you would like.
18 0 Well, maybe we can talk about that in a 19 minute. What I wanted to talk about now was your 20 study. You indica ted bef ore that there were changes 21 recommended by GE following the Browns Ferry event, I 22 believe, and I think that Judge Brenner had asked you to 23 go back and get some information on those, and I don't
( 24 really want to get into the details of it right now.
25 But, my question is: Before the changes were O
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() 1 made, or those recommendations were made, did the 2 Shoreham plant or other plants of that design meet IEEE 3 279 requirements before those changes?
4 A (WITNESS ROBARE) Did you say Shoreham and 5 other plants?
6 0 Well, let's limit it to Shoreham.
7 A (WITNESS ROBARE) Yes, Shoreham did meet IEEE 8 279.
9 Q Did the BWR design that was involved -- let me 10 rephrase that.
11 Did the generic design that you studied, and 12 as to which you recommended changes be made, did that 13 design meet the IEEE 279 standards before you 14 recommended the changes?
15 A (WITNESS ROBARE) Yes, it did.
16 Q I assume you will agree with me that the 17 Browns Ferry event involved the failure of the scram 18 discharge volene and the scran discharge instrument 19 volume.
20 A (WITNESS M cSUIR E) Not the instrument volume; 21 just the s: ram discharge volume. There is only one 22 instrument volume at Browns Ferry.
23 Q But it involved the failure of half of the
() 24 scram discharge volume?
25 A (WITNESS ROBARE) Yes.
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(} 1 0 wouldn't the probability of failure of half of 2 the volume be higher than the probability of the failure 3 of the entire system?
O 4 A ( WITNESS ROBARE) I think that is generally 5 true. I would think so, yes.
8 (Counsel for Suffolk County conferring.)
7 MS. LEISCHE: Judge Brenner, that concludes 8 right now my planned examination on this. If the Board 9 would like to ask its questions, I might have some 10 follow-up to that.
11 JUDGE BRENNER: We vill see if this makes it 12 more efficient.
- 13 MR. ELLISs May they give you now the 14 information you requested beforehand ? Mr. Robare has 15 it. It is simple.
l 18 JUDGE BRENNER: That was on the tip of my 17 tongue, to state we will adopt Mr. Ellis' suggestion and 18 we will take a rest while the witnesses ask themselves 19 the q uestion s and then answer them.
20 Seriously, if the witnesses do need some of 21 the questions repeated, I will attempt to do that, but I 22 will let you go ahead in the first instance.
23 WITNESS ROBARE. Okay. The first thing 1
() 24 would like to state is that this particular study on 25 scram reliability did make recommendations. The O
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() 1 recommendations involved the installation of a 2 recirculation pump trip for the ATWS concern, and the 3 recommendation to modify the scram system to provide i
4 what is called an alternate rod insertion back-up scram 5 signal.
e This noening, I believe I implied that it also 7 recommended scram discharge volume changes. That was 8 not the case, as I reviewed the report in detail.
9 The next question we posed to ourselves was 10 did the study consider the Browns Ferry event, and the 11 answer to that question is yes. There is a fault tree 12 in this study entitled " Scram discharge volume fault 13 tree," that shows the failures involved do result in an 14 inadequate scram discharge volume condition.
15 And, by the way, back on the first point, the 16 recommendations nade in the report were indeed adopted 17 by LILCO in the Shoreham plant. They have installed the 18 pump trip and the alternate rod insertion modification.
19 l'he reason we did not recommend changes to the l
20 scram discharge volume as a result of this study was the
! 21 sultiple fsilure nature and low probability of 22 occurrence, that we judged would be involved in the 23 Browns Ferry type event. In essence, there were th ree
() 24 failures, including a leakage and a blockage and a 25 failure to detect, a failure of the operator to detect
(
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5267 O ' to vota e-2 Now, indeed, a Browns Ferry partial failure to 3 scran did occur following publication of this report, 4 and we would state that it was a systems interaction 5 type of concern.
6 We would like to talk now a little bit about 7 the Shoreham-specific design, both before and after the 8 report and the Browns Ferry partial failure to scram 9 incident. Mr. KasesuK will address the Shorehan design 10 as it compares to Browns Ferry.
11 WITNESS KASCSAK: I would' like to again make 12 the point to just clarify what Mr. Robare stated that 13 the recommandations of the original report, which dealt 14 mostly with the addition of RPT, recirculation pump 15 trip, and alternate rod insertion, ARI, were 16 incorporated prior to the Browns Ferry event.
17 What I would like to do now is discuss a 18 little bit of the differences in the Shorehan design 19 that existed prior to Browns Ferry, and to address the 20 2odifications that were made to the Shoreham plant as a 21 result of our investigation of the incident at Browns 22 Ferry.
23 First of all, the initial Browns Ferry design l () 24 had a single instrument volume, with that single i 25 instrument volume being connected to the two scram i
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() 1 discharge volumes by a small two-inch line which ran 2 spproximstaly 150 feet into the plan t, and at a very 3 small slope to the line. It is believed that that 4 particular aspect of the design was highly contributory 5 to the event itself.
6 The Shoreham design, as it was originally 7 designed prior to Browns Ferry, was significantly 8 different. We have two separate scram discharge volumes 9 with integral instrument volumes attached to each scram 10 discharge volume. The scram discharge volume is a 11 U-shaped, 8-inch diameter pip.e. Connected to that 12 8-inch diameter pipe is a 10-inch vertical instrument 13 volume. And obviously, they are very closely connected 14 because they are integral, so that distance in terms of 15 transporting water from the scram discharge volume to 16 the instrument volume is markedly different than the 17 Browns Ferry design.
18 There may have been -- the Shoreham plant 19 always had redundant level instrumentation, and we 20 weren't able to find out in the short time we had 21 whether or not Browns Ferry had redundant 22 instrumentation in their original design, so that also 23 may have been a difference.
() 24 Getting into the changes that have taken place 25 as a result of our avslustion of Browns Ferry, primarily G
V l
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() I we have done a number of things. We have added 2 additional water level instrumentation to the instrument l
3 volume, and we have added diverse instrumentation. The CE) 4 original instrumentation were magnetrol flow type 5 switches, sad we have added level transmitters, pressure 6 delta t type transmitters to be a means of detectinq l 7 increases in water level.
8 We have relocated the initial flow switches.
9 One switch was located on the train line and one switch
. 10 was lo sted on the instrument volume. We have relocated 11 those switches or altered the instrument volume to 12 preclude sny concerns about ability of water to get into 13 the instrument line for adequate detection.
14 We have performed an extensive thermal 15 hydraulic snalysis of the system, looking at flow 16 volumes, valve opening and closing times, the vent and 17 drain capacity ~ to insure that the system is adequately 18 designed to vent and drain the system as it is intended.
19 We have also included in our start-up test 20 program a test that will confirm that the system 21 operates as it is intended in the design 22 specifications. And lastly, we have added some 23 additional surveillance checks to our technical
() 24 specifications to insure that there is no water 25 accumulating in the discharge volume and that the level O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5270 instrumentation is adequately calibrated and in good
(]) 1 2 maintenance condition.
3 I think that is a good summary of what we have O 4 done as a result of this incident.
5 MR. ELLIS: I believe Mr. Robare had something 6 else.
7 WITNESS ROBARE: The last thing I wanted to 8 say was that with these changes, we have re-evaluated 9 the probability of this event occurring and have -- I to don 't have the numbers with me, but our engineers feel 11 that it is well within the reasonable design figure of 12 reliability.
13 WITNESS McGUIRE: I would like to add to the 14 panel. I was involved in the evaluation of Browns 15 Ferry. I was not involved in writing the report, but 16 just to help evaluate the incident. The interaction 17 between the radwaste system and the scram dischrage 18 volume was considered the remote or lowest probability l 19 of the event that caused the Browns Ferry problem.
l 20 Since both instrument volumes are connected, 21 or since both scram volumes are conne:ted to a single 22 instrument volume, it was just not probable that you 23 would only have uster in one scram volume. But because
() 24 the exact problem could not be identified, INPO listed 25 every possibility where there could have been a problem, O
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5271 and that is why the radwaste drain system is mentioned
(]) 1 2 in the report.
3 JUDGE BRENNER: Mr. McGuire, following up on 4 the last point, if the interaction between the SDIV and 5 the SDV had been the cause, that would have been a 6 systems interaction problem, at least in part. Correct?
7 (Panel of witnesses conferring.)
8 WITNESS MCGUIRE: Judge Brenner, that itself, 9 systems interaction as I understand it is one system 10 acting on another. This is like an intra-a : tion, if you
, 11 vant to call it that. It is one system where it was 12 felt that a component failure was the cause.
13 JUDGE BRENNERs All right. But the failure of s
14 that one component --
and this, as I understand your 15 answer, this was just one of the possibilities 16 postulated -- could have led to the failure complicated 17 by possibly human error in failing to monitor the levels 18 -- led to the failure to realize that there was a 19 problem in the scram discharge volume. That is, that it 20 was half full.
21 RITNESS MCGUIRE: Tha t is correct, because in 22 order for a pipe to drain, it has to be vented and it 23 appeared in this case that the one-half, the containment
() 24 water was not vented because if it was vented it would ,
25 have drained to the instrument volume, which is a lower l ()
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5272 O i teve1 aine.
2 JUDGE BRENNER: I guess I should ask Mr.
{} 3 4
Robare, were the other possible postulated causes considered in the FMEA of the 1976 study that you 5 referred to, or is it just the possible failure in the 6 instrument line?
7 (Panel of witnes.ses conferring.)
8 WITNESS ROBARE: The original FMEA done in 9 1976 did include each of the potential f ailures in the 10 NSAC report. It specifically did not make the 11 distinctio about the radvaste drain system 12 interconnection. It merely assumes that the water in 13 the header is undetected. And without knowing the O 14 details of the probability, I cannot tell exactly 15 whether that was specifically a concern. It is not 16 shown on the fault tree.
17 JUDGE BRENNER4 A s I mentioned ea rlier, in the 18 context of this contention, there is not as much -- I 19 was as much interested in the example of this incident 20 for what it might tell us about the methodology of 21 studies as I am particular in particular fixes for 22 Shoreham. And after lunch, just before Mr. Robare, you 23 tes tified that with the changes, the probablities are
() 24 well within accepted limits, going back and applying 25 what you learned from the earlier study and taking the O
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5273 changes into account.
(]) 1 2 I guess that doesn't surprise me, since as I 3 understood the original study, even without the changes 4 you felt that the probabilities were within acceptable 5 limits. So why should I think it is significant that 6 the same study, even with more changes, would reach the 7 same conclusion.
8 WITNESS ROBARE The reason I made that 9 comment, I believe you asked me before lunch whether we 10 vent back and reassessed after Browns Ferry, and I was 11 saying that we did.
12 JUDGE BRENNER: Okay, I guess I wasn't very 13 clear, and I apologize. Well perhaps, I asked both 14 questions. Have you reassessed the study methodology in 15 light of the fact that it predicted no problem from any 16 of these postulated causes of the Browns Ferry incident, 17 and yet, the incident occurred?
18 WITNESS ROBAREs I don't think I would 19 characterize it that we predicted no problem. We 20 predicted that it was an extremely unlikely probability 21 to have the three multiple concurrent failures.
22 Now, indeed, it did happen, and we made design 23 recommendations and we have again reassessed. We have
() 24 more confidence now that we feel the design is adequate.
25 WITNESS IANNI: Can I try to answer maybe what O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
5274 lll 1 your concern is? The original estimate was a lov 2 number. A very 1sv probability of this o::urring. And 3 statistically, you would not have expected it this early.
4 Now, when something does happen this early 5 when you have predicted such a low number and it was not 6 the full scale scram; it was only a partial failure to 7 scram, then your reliability people view this as a 8 precursor of things to come. So at that point in time, 9 you sort of push the probability numbers aside and you 10 go in there and turn it over to the engineers to make 11 fixes.
12 Now, what they did when they updated the 13 calculations, they took the now known number -- at least 14 the one we have got; once in 400 reactor years -- put 15 that number into the model slong with the changes, and 16 calculated that new number. And the questien is well, 17 how much acre do I believe in that new number than the 18 old number, and the answer is. it is s better number 19 now. And until we get more data, it will continue to be 20 the best number that we have.
21 Does tha t help you at all?
22 JUDGE BRENNER: Well, I don 't know. I will 23 think about all of this later. Given the fact that the lh 24 Browns Ferry event occurred and that the study had 25 previously predicted the probability sufficiently low so O
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() 1 ss not to require any design =hanges beyond those 2 actually made after the report, I suppose you can reach 3 at least one out of two conclusions. One is that well, 4 the probability was not zero, and it just occurred early 5 in life. Luck of the draw, so to speak.
8 Or , the stud y vss flawed with respect to the 7 prediction of low probability, and in fact, the 8 probability is much higher. And I am wondering if there 9 was some study of the stuiy, if you will, to determine 10 whether the latter conclusion is a correct one. That 11 is, that the probsbility was under-predicted due to 12 something in the methodology of the study which can now 13 be -recognized and improved.
14 (Panel of witnesses conferring.)
15 WITNESS ROBARE: It is my understanding from 16 talking to the reliability people that the reliabilities 17 were under-predicted, since there were no data points.
18 And now that we have a data point, we have much more 19 conservatively estimated the reliability of this 20 occurrence.
21 JUDGE BRENNER: Let me try one or two more,
, 22 and then Judge Jordan is going to have some questions.
23 Aside from looking at it in a probabilistic sense, did
() 24 the study also look at the possibility of an incident 25 lite the Browns Ferry incident in a more traditional, if O
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5276 ll 1 you will, as distinguished from probabilistic sense to 2 look for dependent type failures; whether they be 3 classic systems interactions, definition type f ailures 4 or dependent type failures within the same system?
5 And if the answer to that is -- well, let me 6 get the answer to that, first.
7 (Panel of witnesses conferring.)
8 WITNESS ROBARE: One comment would be, as Mr.
9 Kascsak has testified, the design that was incorporated 10 at Shoreham before the Browns Ferry event was a much 11 more reliable design. Our engineers had thought about 12 this as the design evolved for later plants, and had 13 decided to make improvements from a classical 14 engineering design approach rather than a probability 15 a pp roach. And, of course, after the event, they 16 recommendei further improvements.
17 JUDGE BRENNER: Is my recollection correct 18 that you did not recall if these improvements 19 recommended after the study were also made known to the 20 Browns Ferry operators?
21 22 23 24 ,
25 O
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() 1 WITNESS ROBAREa This particular study, as I 2 corrected after lunch, did not make japrovement 3 recommendations in this particular area. As far as this
- 4 general scram discharge design for operating plants 5 versus plants under construction, as is often the case, 6 there can be a difference in the design, and one has to 7 evaluate the appropriateness or the need to backfit a 8 design change. At the time they did not feel that was 9 necessary for the Browns Ferry type design. They have to since changed that recommendation.
11 JUDGE BRENNER: Now, the 1976 study did l 12 disclose the possibility of dependent failure mechanisms 13 similar to the three or so possibilities suspected as 14 the cause of the Browns Ferry event, is that correct?
15 . WITNESS ROBAREa That is correct.
16 JUDGE BRENNER: Why was not this disclosure 17 grounds for concluding that safety systems did not meet 18 all the criteria the systems'should meet given these 19 dependant f ailure possibilities?
l 20 WITNESS ROBAREs The design was still single 21 failure proof at tha t time. It still met the IEEE 279 22 type of assessment. When the evaluation was made for 23 this report, it was felt th.at the system reliability was l
l
() 24 high enouga not to warrant a change for that specific 25 concern. There were numerous failure modes and fault
()
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() I trees involved in this failure to scram study, and this 2 was just one of them that was judged at the time to not 3 wa r ra n t a design change.
4 JUDGE BRENNER: Of the suspected causes -- and 5 there are severs 1, as Mr. McGuire indica ted -- for the 6 Browns Ferry incident, are they solely failures within 7 safety systems or do they involve failures of 8 non-safety-related systems as well as safety systems?
9 Can you characterize them?
10 WITNESS ROBAREa Do you want me to limit it to 11 the scram discharage volume concern or for any failure 12 to seria?
13 JUDGE BRENNER: Just the scram discharge 14 volume concern, but don't limit yourself just to the 15 suspected cause focused in on by Ms. Letsche before, 16 since as I understand it there are several suspected 17 causes, and that Mr. McGuire at least thinks that is not 18 the most likely suspect.
19 (Witnesses conferring.)
20 WITNESS DAWE Judge Brenner, are you 21 referring specifically to the NSAC study conclusions?
22 JUDGE BRENNER: I was not, but if that would 23 help you, that's fine. We have had testimony that j () 24 collectively the panel is familiar with the Lessons 25 Learned from the, Brown s Ferry incident, and I don't want O
ALDERSON REPORTING COMPANY,INC, 400 VIRGtNIA AVE, S.W, WASHINGTON D.C. 20024 (202) 554 2345
i 5279 1 to create a problem for you by having you not understand 2 what the authors of the study had in mind. So you could
- 3 take it sny vsy you want, whatever way is easier for O 4 you. -
5 (Witnesses conferring.)-
6 WITNESS ROBARE: The only non-safety grade 7 equipment aspect that we understand could enter ,into the 8 scram discharge volume concern is the drain lines on the 9 scram discharge volume are not fully safety grade, and 10 possibly the NSAC con -lusion about the radwaste system 11 interaction, we are not sure that we agree with that 12 right here now.
13 JUDGE BRENNER: For the, record, could you fill
~
14 out just a little bit the NSAC concern for the radwaste 15 system interaction, knowing that in' asking you to 16 summarize that, that doesn't necessarily connote 17 agreement on your part.
18 WITNESS ROBARE: It is probably best if I just 19 quote this paragraph from the report. "Either of the 20 foregoing may have bebn aggravated by momentary pressure 21 of vacuum surges in the clean radwc Tt e drain system 22 caused by large influxes of v= U:>r ' coa sources other 23 than the SDIV. Both the sc4ao s .enarge volume vent 24 lines and the scram dischstge instrument volume drain 25 line discharge into the CRW drain system. This O
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() I hydraulically complex system receives intermittent 2 drainage from approximately 50 other sources. Some of 3 that drainage is f requently hot water, which could
)
4 increase pressure or such in surges."
5 Now, it is my understanding Shoreham does not 6 have tha t type of arrangement with the radwaste f
7 connection.
8 JUDGE BRENNER: But your point in not 9 necessarily agreeing with that conclusion was in 10 addition to the f act that Shoreham might be different, 11 as you just indicated, you are not even sure you agree 12 with that conclusion for Browns Ferry, is that correct?
l I
13 WITNESS ROBARE: That is correct. For this 14 morning and this afternoon, my only information would be 15 the fault tree that we have developed in this report 16 which does not specifically show the radwaste l
17 connection.
18 JUDGE BRENNER: In saying that the drain lines 19 are not safety-related, did you mean their ability to 20 withstand seismic events or something else? I am 1
l 21 wondering how that lack of being safety grade 22 contributed possibly to the accident, and as I think 23 about it, a blockage could have occurred, even a safety 24 grade line.
l 25 WITNESS KASCSAK: Naybe I could add a l
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() 1 clarification here. What we are talking about is the 2 drainage of the instrument volume to another area of the 3 pla nt , and a t Browns Ferry it was a little more 4 complicata 1 drainage, but even it Shoreham that drainage 5 goes to clean radwaste.
6 Now, the blockage of that system in itself 7 very unlikely, but even the blockage of that sistem and 8 the fact that a non-safety system could impact a safety 9 system is considered in the initial design in that the 10 sizing of the instrument volume and the level at which 11 it detects increases in water level is designed so that 12 if the scram discharga or the instrument volume fills 13 with water, it will automatically scram the plant, and 14 that automatic scram is to ensure that there is enough, 15 there is still remaining in the scram discharge volume 16 sufficient volume to allow the full scram to take place, 17 so that the design already takes into account -- and the 18 Shoreham design did this prior to Browns Ferry, and we 19 haven't changed the dasign to make it less susceptible 20 to this failure, but the initial design in itself took 21 into account that interaction.
22 JUDGE BRENNER: But Browns Ferry did not have 23 that scram feature?
() 24 WITNESS KASCSAK: They did have that scram 25 feture, and that is why Mr. Robare stated bef ore that it O
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() I had to be a series of failures, a blockage and a failure 2 to detect coincidentally to prevent the scram from 3 taking place, and that it is believed tha t the size of 4 the drain line from the scram discharge volume or some 5 of the thermal hydraulics v'nting and sizing of that 6 line contributed to the fact that that high level was 7 not sensed.
8 JUDGE BRENNER Okay, that explains something 9 that I misunderstood earlier. Apparently you are 10 talking about the automatic sensing of that scram 11 initiator as opposed to an operator appreciating it.
12 WITNESS KASCSAKa It is automatic.
13 JUDGE JORDANS You mentioned that the study 14 did consider the possibility of the scram discharge i
15 volume being in a sense a common mode, and however --
16 and tha t it was considered, but nevertheless the 17 reliability figures were.so small that it was not 18 considered to be an important item.
19 Is that spproxima tely correct?
20 WITNESS ROBARE: Yes, it is.
21 JUDGE JORDANS Now, so by some definitions 22 anyhow, common mode failures are considered to be a type 23 of system intersction and I believe, in fact, this LILCO
() 24 testimony later on will include that as one of the 25 sys tems interactions. Is that correct?
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() 1 WITNESS DAWE My recollection of the 2 testimony is that it is the other way around, that the 3 systems interactions are a subset within common mode 4 failures as opposed to common mode failures being within 5 the subset of systems interactions, but there is that 6 link.
7 JUDGE JORDAN: So is it not the case that the 8 estimates on the probability of failures were wrong,
-6 -7 9 they were 10 or 10 rather than the actual figure 10 of one every 400 years, is that correct?
11 WITNESS ROBARE That is not necessarily 12 correct. It could be correct.
! 13 JUDGE JORDAN Well, you are saying that the 14 fact that you have one every 400 years doesn't mean
-6 15 necessarily that the 10 is wrong? Is that what you 16 are saying?
17 WITNESS ROBARE: Yes, but I wouldn't want to 18 press that point. Our engineers have conceded tha t 19 these numbers were perhaps not overly conservative, and 20 ve have adjusted them in light of the actual 21 occurrence.
22 JUDGE JORDAN: All right, now, have you read 23 and considered the evaluation by the analysis and the
() 24 evaluation of operat,ional data of any NRC, the AEOD 25 evaluation of the Browns Ferry event?
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() 1 WITNESS ROBARE: I have seen that report, 2 yes.
3 JUDGE J3RDANs Did they conclude that a single 4 failure, namely, s single blockage in the venting system 5 or drain line in the west header SDV, can result in an 6 undetected accumulation of water in both the east and 7 vest headers which could disable the s: ram capability of 8 all control rods?
9 (Witnesses confarring.)
10 WITNESS ROBARE: That was true for Browns 11 Ferry. The Shoreham design is different from that.
12 JUDGE BRENNER: The 1976 study, however, was a 13 generic study, correct?
O' 14 WITNESS ROBARE: It was a generic study that 15 looked at plants like Browns Ferry to bound the worst 16 case design.
17 JUDGE BRENNERs So if we are pursuing the 18 thought about what the Browns Ferry incident should l
19 teach us about the efficacy, so to speak, of the 1976 j
20 study, your point about Shoreham, about the Shore Am 21 design not fitting the description Judge Jordan just 22 gsve, while noteworthy, is really irrelevan t to looking 23 at whether the study should have detected that type of I 24 common mode failure.
25 JUDGE JORDAN: Well, the study just did fail O
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() 1 to consider adequately some common mode failure.
2 Well -- and I've used the word " adequately," because I 3 know they did consider common mode f ailure. I've heard 4 OE argue strongly that the probability of a common mode 5 failure in the system discharge volume is so small that 6 it need not be considered, and yet the study was wrong.
7 Now, does that in itself have a lesson? Does 8 that mean that the methodology that Judge Brenner was 9 talking about should have -- does need improving?
10 WITNESS ROBARE: I think the methodology is 11 adequate and accurate. The numbers associated with the 12 failure probabilities were not conservative, and that 13 part of the methodology was not adequate.
14 JUDGE JORDAN: Well, I guess does this not 15 sean that the technology is really inadequate to ferret 16 out all possible common mode f ailures, and I think maybe 17 Hr. Ianni mentioned something like that the other day.
18 Is that an accurate statement?
19 WITNESS ROBARE: I think that is a good, 20 general accurate statement. In this particular case, 21 though, I think we had anticipated the f ault tree for 22 this particular event. It was not that we -- it wasn't 23 that we did not anticipate the possibility of those
() 24 paths to that event. It is just that we had not 25 conservatively judged the probability of that O
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() 1 occurrence.
2 JUDGE J3RD AN : Namely, the probability of a 3 single blockage in the venting line?
)
4 WITNESS ROBAREs Yes.
5 JUDGE JORDANS I see.
6 The AEOD recommends that all plants should 7 provide one SIV tank for each SDV header. Is this a 8 recomnendation that is being carried out in either 9 Browns Ferry or Shoreham?
10 WITNESS DAWEa Judge Jordan, that has always 11 been the case at Shoreham. That was our design 12 originally. We had one instrument volume for each scran 13 discharge volume, and it was part of the scram discharge O 14 volume, so there were no small lines to go through 15 before you got to the instrumentation. There are 16 differences in designs between these plants because the 17 design organizations for one were different.
18 JUDGE JORDANS And yet it was not -- well, the l
19 1976 study didn't identify this as being required, a 20 required change in order to prevent the common mode 21 failure, did it?
22 WITNESS ROBARE: That is correct.
23 JUDGE JORD AN: I don't want to go into the
() 24 present estimates of reliability, but I do want to ask, 25 do you feel tha t there are no longer any -- well, first l
f%
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() 1 of all, any possible common mode failures that could 2 result in failure to scram or is the technology that you are now using for ferreting out possible failures good
{} 3 enough that it has reduced it again to what you feel is 4
5 a tolerable level?
i 6 WITNESS ROBARE: We certainly can't say there 7 is no possible common moie failure to prevent scram 8 because there is only one type of control rod drive. We 9 do feel, agree with your latter assessment that the 10 probability of a common acde failure to present scram is 11 now within the realm of good design practice.
12 JUDGE JORDAN: So you would say that the i 13 bottlentek or the most likely common mode f ailure now O 14 lies in the mechanisms themselves?
15 WITNESS ROBARE: I really don't have personal 16 knowledge of that.
17 WITNESS KASCSAKa Judge Brenner, if I could 18 just comment on the discussion you've had about the 19 methodology -- and I think we have thought a lot about l
l 20 the Browns Ferry event, and obviously we have had 21 relationships with these types of analysis through the l
22 Shoreham PRA, and I think I would not characterize this 23 problem as one that would belle the methodology, but
() 24 that to a large part this problem was directly related 25 to a design problem, and although the generic studies do O
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() I take into account general designs and particular design ;
2 f es tures tha t GE believes that their design should have, 3 there are some certain plant-specific aspects of how i
)
4 these designs are implemented, and the actual 5 implementation of their design features, namely, in this 6 case, the venting and the draining of the scram 7 discharge volume, contributed signficantly to this 8 particular failure, and it is I think very possible that 9 the analysis they performed didn't really review all of 10 the differant designs that existed out there relative to 11 how each plant implemented their design specifications.
12 And tha t particular aspect of the Browns Ferry design 13 contributed significantly to this event, and a more 14 detailed look at a specific plant design using the same 15 methodology I feel could have in fact detected that 16 problem.
17 JUDGE JORDANS Would a thorough walkthrough 18 such as you have described, should that have detected 19 this type of f ailure to implement the design?
20 (Witnesses conferring.)
l 21 MR. ELLIS: I'm sorry, Judge Jordan. Did you 22 say failure to implement design?
23 JUDGE JORD AN s Yes. I think Mr. Kasesak's
() 24 statement was that it wasn't so much the design itself 25 was wrong as it was that they built the thing without l
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() 1 adequate slope in the lines, I presume. Isn't that what 2 you were saying, essentially?
3 WITNESS KASCSAKs Well, I was implying that a 4 design deficiency in the plant had existed that may not 5 have been obvious in the generic study. I mean, in 6 terms of the assumptions that were beine used by the 7 modellers in the logic trees, and why that deficiency 8 existed at Browns Ferry is something I can't comment on, 9 although I think we have pointed out before that that is 10 not a typical situation.
11 JUDGE JORDAN Tha t 's righ t. Now, you 12 mentioned the deficiency of Browns Ferry, and I was only 13 asking now, was that the. type of walkthrough that you l
O 14 have accomplished at Shoreham, would that type of l
15 valkthrough have discovered a deficiency like that?
16 WITNESS KASCSAKs Well, I believe it would 17 have. It would look at the system and look at all 18 aspects of that design and evaluate the adequacy of 19 those.
20 JUDGE BRENNER: Mr. Kascsak, I have a problem 21 with your explanation that is somewhat different. The 22 scram reliability study was cited in the testimony as an 23 example, among others, of the type of study that we 24 should draw some comfort from with respect to the fact 25 that in combination these studies ha ve detected systems
(:)
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() 1 interactions and give reasonable assurance that systems 2 structures and components are classified correctly, is 3 that right?
4 WITNESS KASCSAK4 That i= ccrrect.
5 JUDGE BRENNER: Why then should I be comforted 6 by the fact that the reason that the Browns Ferry 7 problem was not picked up in'the study is that it was a 8 deficiency in the Browns Ferry design?
9 WITNESS KASCSAK Well, you were challenging 10 the methodology, and I was trying to at least give you 11 sy opinion as to the fact that it is not necessarily a 12 flaw in the methodology but in f act the implementation 13 of the design assumptions that go into the development O 14 of the logic trees and involved in developing the 15 predictions of failures, and I am sure a properly 18 designed vent and drain system was considered to be 17 necessary in the model.
18 JUDGE BRENNERa Well, what good is a study 19 tha t is supposed to pick up functional dependencies if 20 it cannot pick up a design problem such as this one?
21 I guess I want to stay with you, Mr. Kascsak, 22 because in your view you had an explana tion as to why I 23 shouldn't draw the adverse conclusion, in part because 24 this was a particular design problem, and I don't 25 understand why that should not lead me to d raw an
! (1)
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() 1 adverse conclusion.
2 WITNESS KASCSAK: Well, I'm not intimately 3 familiar with the GE study, and therefore I cannot
[}
4 discuss with you in detail the assumptions that were 5 used by the modelers, but I am sure there had to be some i 6 assumptions used by the designers when they laid out the 7 model, and I would question whether or not all of those 1
8 assumptions --
9 WITNESS RIEGELHAUPTa Excuse me. I would like 10 to make a statement at this point.
l 11 JUDGE BRENNER Well, let him finish.
12 WITNESS KASCSAKs The point is that I think a l 13 possible explanation is s f ailure to implement or to l
() 14 apply those assumptions in the design of a specific 15 plant.
16 JUDGE BRENNER: Well, Mr. Robare testified a 17 short while ago that the study was meant to bound the 18 designs, including the Browns Ferry design, and that is 19 what led me to my question, is why should I be comforted 20 by the fact that a study meant to do that did not pick 21 up a design deficiency in one of the plants that it was 22 meant to bound, and I thought you had familiarity with 23 the study by your previous explanation that this is the 24 kind of design deficiency that even a good study would 25 not pick up.
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() 1 WITNESS KASCSAK Well, it seemed to me we 2 broadenad the discussion into the viability of the methodology beyond just this particular study.
{} 3 that is what my comment dealt with, was the I think 4
5 methodology.
6 JUDGE BRENNER: Well, I'm working with this 7 study. It may be looked at as an example just as your 8 testimony cited it as an example, but I didn't mean any 9 of my questions to go beyond the study.
10 If you're done, maybe we should let Mr.
11 Riegelhaupt comment.
12 I didn't mean to cut you off, Mr.
13 Riegelhaupt.
14 WITNESS RIEGELHAUPT: If you look at our 15 testimony in Section 2, we testified that part of the i
16 design process is the organization of this work on a 17 systematic basis, and we say that these various systems 18 interaction and PRA studies have certain limitations to 19 them as checks of the design process. Now we seem to be 20 arguing around this point and I would just like to 21 reiterste the earlier testimony at Section 2 that it is 22 the comprehensive design process that assures a good 23 design, not just these studies which all have certain 24 liaitations to them and are useful for after-the-fact 25 checks but don't represent the design process.
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() 1 JUDGE BRENNER: Well, Mr. Riegelhaupt, even 2 viewing the study as an after-the-fact check -- and I do
(} 3 recall reasonably well, I believe, your Section 2 4 testimony now that you've mentioned it, although perhaps 5 not in all the detail that you have it firmly in your 6 mind at this moment, but even looking at the studies and 7 after-the-fact check, didn't it f ail in that use by not 8 turning up -- I don't want to get hung up on 9 terminology, and Mr. McGuire will get upset if I call it 10 1 systems interaction -- a dependency stemming from this 11 one common source as a check on the design of the Browns 12 Ferry type configuration?
! 13 WITNESS RIEGELHAUPT: This may be so, but I
( see the panel here having to argue both sides of this 14 15 question, and I have some problems with that. The panel 16 has recognized the limitations of the studies, and even 17 though we quoted some that were done that are useful in l 18 demonstrating the formal published studies of systems I
19 interactions and other types of studies of this sort, I l
20 find problems in arguing that these are essential to the l
21 design process. They are not essential. What is 22 essential to the design process is this -- is the actual 23 functioning of the design process as we've described in 24 Section 2. I just find when we are arguing back and 25 forth against some of our answers to the contentions of ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 the Intervenors, and I find a great problem with this.
2 And I would like you to consider this, Judge Brenner.
3 JUDGE BRENNER: I can understand the context
}
4 better of what you mean now. I will leave you with this 5 thought -- and it is not a question -- as strongly as 6 you feel about the design process, and you did discuss I
7 it quite a bit in your section of the testinony, as did 8 GE in its section, that testinony may be less scrutible 9 than a panel woeld like when applying it to particular 10 issues in a proceeding. Nevertheless, recognizing its 11 existence and these studies were also cited in the 12 testimony in addition, so we are examining them, and at 13 any given point in the hearing you are focusing on one O 14 part of the testimony, it doesn't mean that in the end 15 when you pull the findings together it will be to the 16 exclusion of other parts of the testimony. So that is 17 just a little explanation of the flaws in our process if 18 you will.
19 WITNESS IANNI Judge Brenner, I still find 20 some comfort in the PRA study, even though it has this 21 one clear failure in finding an interaction, and I think 22 that the reason I still think it is worthwhile and I 23 find comfort in it is that if you look at the failure it
( 24 failed to pick up, you will find a clear lack of good 25 data upon which to base your numbers. There wasn't a O
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() 1 great deal of statistical information, for example, on 2 pipes plugging ini things of this sort. ,
1 3 Now, maybe this is a fault of the persons who
}
4 did it. They should have had more sensitivity studies 5 and things of this sort. But nevertheless, that does 8 have a weak data base.
7 Now, in the other areas that it treats, like 8 the logic systems and the relays and the valves, there 9 the data base is much better, in my opinion, anyway, and 10 so I would feel that in those other areas uhere the 11 method was applied, it is more likely to be correct and 12 ve are less likely to be surprised.
13 Now, I might be off by a factor of -- I mean, O 14 being off by a factor of 10 or 100 in these things isn ' t 15 unusual, but being off as much as we were on the scram 16 discharge volume indeed is somewhat unusual. Let's 17 admit that for tha sake of discussion.
18 So I say just because one piece of the method 19 didn't work, I don 't throw the whole method out. I 20 still find comfort from the other parts of it, and time 21 will tell to what extent that f aith is justified. Every 22 design method that we use has certain shortcomings and 23 limitations, and that is why as engineers we take all 24 new approaches, including PRAs, with a little grain of 25 salt. Stress analysis methods and so on, you always f
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() 1 tak e those with a certain grain of salt. And so you use 2 everything at your disposal, including this method, with 3 all of its flaws and all of its good points, hope to 4 Laprove it, and you keep marching along. I 5 And I think that I do draw some faith from e it. I wish it hadn't happened this way, but it doesn't 7 sean that I throw the whole method out and say therefore 8 I will not believe PRAs and I may have missed others.
9 Yes, indeed, we may have missed others. Hopefully they
. 10 are not very serious, and you will have to be on the 11 lookout now. It makes us very much more vary having had 12 this happen to us.
s 13 So it is that kind of thing that gives me a 14 certain amount of confidence and faith in the process.
15 It is not perfect.
16 JUDGE BRENNER One reason we are pursing 17 it -- and perhaps this should be a question for Mr.
18 Robare, along with anybody else who wants to join in --
19 is that beyond a possible underestimation in the study 20 of the probabilities of multiple f ailures, and Mr.
21 Robare, you described it a number of times now as 22 multiple failures.
23 Was there also a failure to recognize that
() 24 what we are dealing with were not multiple failures but 25 dependent failures which therefore should have been O
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() 1 (Whereupon, the witnesses conferred.)
2 JUDGE BRENNER4 It is that possible problem in 3 the methodology or application of the methodology that 4 raises a question.
5 WITNESS ROBARE: Do you mean that we might 6 have characterized this as three multiple or three 7 failures, independent failures, when indeed they were 8 dependent, a single event?
9 JUDGE BRENNER: Yes, and I guess part of your 10 answer may require you to comment on Dr. Jordan's prior 11 characterization of one blockage in the vent line 12 leading to this event, recognizing that doesn't mean 13 that with the actual cause of the Brown's Ferry 14 incident, there are seversi suspected but as part of the 15 inquiry in tha t incident this f ailure mode was 16 recognized as a possibility, and it may be significant 17 for that. I don't want to get too hung up on whether 18 tha t was the actual one that caused the Brown 's Ferry 19 incident.
20 WITNESS ROBARE4 I am not quite sure. Do you 21 have a question of me right now?
22 JUDGE BRENNER4 I will try again. Was there a 23 failure in the methodology or application of the )
() 24 methodology in the 1976 study, in that it failed to 25 recognize a dependent failure mechanism, and therefore O
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() 1 underestimated the probabilities because it assumed that 2 there would have to be two or three multiple independent 3 failures in order to cause the problem?
4 (Whereupon, the witnesses conferred.)
5 MR. ELLIS: Judge Brenner, it is with great 6 trepidation that I ask, but I am confused. The three 7 failures that were mentioned in the testimony, I 8 believe, were leakage, flow, and detection.
9 JUDGE BRENNER: According to my notes -- I 10 don't want to divert the panel from answering too much, 11 but leakage, blockage, and failure of detection.
12 MR. ELLIS: Right, failure of detection.
13 JUDGE BRENNER: It was f ailure of flow, not b
V 14 flow.
15 MR. ELLIS: Do I understand your question to 16 ask them to assume that those are dependent?
17 JUDGE BRENNER: No. I think they understand 18 the question. Let me try this for your benefit, Mr.
19 Ellis. One of the possible failure mechanisms uncovered 20 as a result of inquiry into the Brown's Ferry incident, 21 not necessarily the one that caused it, but a
! possibility nce th-t the inciden t has stimulated study, 22 23 is what I call the dependent failure. Your technical
() 24 witnesses may not like my terminology, but that is the 25 common failure stemming -- dependent failure stemming l (
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() 1 from blocksge in the drain line, one of the drain lines, 2 causing at the Brown 's Ferry type designed plant the 3 failure to scram due to the failure of the scran 4 discharge volumes to be completely empty, and I will let 5 the witnesses answer more fully, but the possibility 6 that that type of dependent failure would always lead to 7 a failure to detect, that is, it wasn't two independent 8 failures -- well, always is a rather strong word, but it 9 would not be a completely independent f ailure.
10 I am not testifying. I am willing to let them 11 do it.
12 (Whereupon, the witnesses conferred.)
13 JUDGE BRENNER: Also, Mr. Ellis, in case you b
\/
14 are getting nervous about the line, we have tried to 15 indicate from time to time that what we have in mind is 16 following up on the direct testimony, the check on the 17 methodology. I do not intend to move these hearings to 18 Athens, Alabama, tomorrow, to spend any more time there 19 than I already have.
20 (General laughter.)
21 (Whereupon, the witnesses conferred.)
22 JUDGE BRENNER: Perhaps this would be a good 23 time for the midafternoon break. It is a little after 24 3:20 on that clock. Let's take 20 minutes, to give you 25 a chance to relax, in addition to thinking about the O
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O 4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 O
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2 A, I hope you don't ask me to repeat the question. B, 3 if you would like more time to consider it, we could 4 come back to it tomorrow, with no adverse inference 5 whatsoever. It was perhaps a complicated question, and 6 the time during the break was short, so if you would 7 like to consider it longer, even if you think you have 8 an answer, that would be fine.
9 WITNcSS ROBARE: We have reviewed the fault to tree in this report for the scram discharge volume, 11 inadequate operation. I would like to state that the 12 methodology used in this fault tree, we believe, is 13 perfectly appropriate and adequate, and is used 14 elsewhere in the plant and in the PRA approaches. We 15 have no question in our mind about the adequacy of that 16 methodology.
17 Specifically, for this particular fault tree, 18 in this particular report, we have identified what we 19 f eel are four estimates of the reliability of some of 20 this equipment that we verified after the Brown's Ferry 21 event, and we have also identified the possibility.
22 However, we are not sure, since we haven't completely 23 assessed or we haven't fully identified exact scenarios 24 at the Brown's Ferry event. There inay be a problem in 25 the dependency of multiple failures in this fault tree O
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() 1 also, but since we do not know exactly what the failure 2 mechanisms were at Brown's Ferry, we cannot be sure of
~h 3 that, but certainly your comment tha t multiple f ailures, (V
4 dependent failures may not have been improperly 5 evaluated is a possibility. We can't be sure of that 6 today, because we are not sure of the exact scenario'of 7 failures of these events.
8 JUDGE BRENNERa You said, may not have been 9 improperly evaluated. Did you mean, may not have been 10 properly evaluated?
11 WITNESS ROBARE: Yes.
12 JUDGE BRENNERa What I don't understand is, 13 given that the precise scenario that caused the Brown's O 14 Ferry incident is not known, why do you have to knov 15 that so long as the study of that incident has led to 16 the conclusion that the dependent failure or that a 17 dependent failure scenario which might not have been 18 previously recognized could have led to the failure?
19 Isn 't that enough to require going back to look at the 20 methodology or the application of that methodology in 21 the 1976 FMEA?
22 (Whereupon, the witnesses conferred.)
23 WITNESS ROBARE: That is certainly enough to n 24 reconsider that point. Unfortunately, I don't have the 25 new fault tree, and I am not sure whether they consider O
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() 1 those dependent failures or independent. That would 2 have to do with their interpretation of what happened or 3 wha t would be likely to happen for equipment of this
(}
4 design.
5 JUDGE BRENNER: But that type of look-back, if 6 you will, at the report has not been done?
7 WITNESS ROBARE: No, it hasn't been done by 8 me. It has been done, yes. I am just not aware of how, 9 or whether they considered these to be single failures to or dependent failures. I know in this report they 11 consider them to be single failures, and it may be 12 appropriate, depending on the evaluation of the design, 13 in consideration of the Brown's Ferry event, to make O 14 them dependent failures. I really don't have that fault 15 tree available before me today.
16 JUDGE BRENNER: You say that fault tree. I am 17 not sure what you mean.
18 WITNESS ROBARE: The revised fault tree after 19 the design was modified, and in light of the Brown's 20 Ferry event, which would change the probabilities.
21 JUDGE BRENNER: And that fault tree has been 22 prepared by General Electric?
23 WITNESS ROBARE: Yes. We didn't really knov 24 ve were going to get into this kind of detail on this 25 particular subject.
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() 1 JUDGE CARPENTER: I would like to ask a few 2 questions continuing in the same vein, either in the 3 sense of making the record more complete or kicking a 4 dead horse. I am not sure which.
5 (General laughter.)
6 JUDGE CARPENTERS Mr. Robare, turning to 7 Suffolk County Exhibit 20 on Page 111, there appears the 8 abstract. Would you confirm for me that the first 9 sentence of the third paragraph states, "Despite to extensive investiga tion and analysis by TVA and others, 11 a unique cause has not been established?"
12 WITNESS B0 BARE: Yes, I would agree with that, 13 and that is why I wasn 't sure about the dependent t ;
'- 14 multiple failures and the independent. It is my 15 understanding we ha ve still not exactly detailed the 16 scenario of that event.
17 ( Whereupon, the witnesses conferred . )
18 WITNESS ROBARE: I am sorry if I overreacted.
19 Was your question, is that what it says?
20 JUDGE CARPENTERa I asked if you would confira 21 for me with either a yes or a no that what I read was 22 what the piece of pa per says.
23 WITNESS ROBARE: Yes.
() 24 JUDGE CARPENTER: Thank you, sir.
25 JUDGE BRENNER: He was just surprised at
() .
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() I having an easy question.
2 (General laughter.)
3 JUDGE CARPENTER: I allowed some time for the 4 shock to wear off.
5 (General laughter.)
6 JUDGE CARPENTERS In light of your response, 7 if no csusa was identified, would you say that a system 8 interaction was identified at Brown's Ferry?
9 WITNESS ROBARE4 No, I wouldn't say that.
10 JUDGE CARPENTER: Thank you. We ere in a 11 portion of the testimony that talks about systems 12 interaction and we have been talking about Brown's Ferry 13 for several hours. I wanted to see whether it was your 14 opinion that a systems interaction was identifieG in the 15 Brown's Ferry incident, and I am sorry for the 16 rambling. Apparently your response was no. Is tha t 17 correct?
18 WITNESS ROBARE: Correct.
19 JUDGE CARPENTER: Therefore, anything that we 20 might talk about with respect to Brown's Ferry is 21 entirely speculative in the sense of looking at systems 22 interaction since no interaction has been identified.
23 WITNESS ROBAREs That is correct.
() 24 JUDGE CARPENTER: In the spirit of 25 speculation, I would like to pursue some speculations O
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() I identifying that they are just speculations. In the 2 same Suffolk County Exhibit 20, on Page 4, in the middle 3 of the first full paragraph, could you confirm for me
{}
4 that the third from the last sentence reads, "It has 5 been suggested that the obstruction could have been 6 formed by the accumulation of solid crud."
7 WITNESS ROBARE: Yes.
8 JUDGE CARPENTERS Was crud accumulation 9 considered in the 1976 GE study of systems interactions 10 with respect to scram discharge reliability?
11 (Whereupon, the witnesses conferred.)
12 WITNESS ROBAREa The fault tree assumes a 13 blockage. It doesn't really give the source of that O 14 blockage. It just assumes that a blockage is present 15 and relates a probability to that.
16 JUDGE CARPENTER: What was the source of the <
17 probability estimate for that blockage?
18 WITNESS ROBARE: I just don't know that 19 detail. I can tell you the number that was shown in the 20 figure.
21 JUDGE CARPENTERS Out of curiosity, I would 22 like to hear it.
23 WITNESS ROBARE: Less than one times ten to
() 24 the minus seven.
25 JUDGE CARPENTERS Are you familiar in general O
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() I with the sources from the probability estimates used in 2 tha 1976 study?
3 WITNESS ROBARE: No, I am not.
4 JUDOE CARPENTER: Are you now at the point 5 whether the people who did that study had many data 6 bases, many sources of probability estimates, or did 7 they have to generate them in the course of the study?
8 (Whereupon, the witnesses conferred.)
9 WITNESS ROBARE: We would expect that there to would be a combination of special information derived 11 fro this report plus the accumulated knowledge within 12 General Electric at that time, reliability, and defense 13 of this type.
14 JUDGE CARPENTER: Did the 1976 report include 15 a sensitivity analysis?
16 WITNESS ROBARE: I am not quite sure what you 17 sean by that.
18 JUDGE CARPENTER: In a sense of looking at the 19 consequences of making an error in estimating 20 probability, if I thought the probability vns some 21 number and in fsct the truth were a tenf old d if f erence.
22 (Whereupon, the witnesses conferred.)
23 24 25 O
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() 1 (Panel of witnesses conferring.)
l 2 WITNESS ROBAREa The report does not make any 3 specific statements other than the general one that
)
4 estimates s re intended to represent conservative upper i
5 bound values in all cases. It is a qualitative 6 statement.
7 JUDOE CARPENTER: That is almost* responsive to 8 ny next question. Let's see if it is. Were confidence 9 limit estimates put on the probabilities, other than 10 asserting that they were upper bounds?
11 WITNESS ROBAREa That information is not in 12 the report. I assume it was available to the people who 13 produced the report, and it is simply not stated in the 14 report, from my immediate information.
15 JUDGE CARPENTER Well, do you think that 16 those considerations would be important?
17 WITNESS ROBARE They would be important to me 18 in evaluating the conclusions of the report, to have 19 some feel for the accurateness of the numbers.
20 JUDGE CARPENTER: And I finally come to --
21 earlier you testified that the engineers decided tha t 22 the numbers in that report were not conservative, and 23 that is what I was trying to get some feel for; whether
() 24 this was based on the numbers were outside of the 25 confidence limits that they had previously established.
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5310
() 1 WITNESS ROBAPE: I think following the Browns 2 Ferry event, the engineers had to reassess their 3 reliability numbers as the data base changed, so to
)
4 speak.
5 JUDGE CARPENTER: Based on one occurrence, one 6 data point, there is now a revised probability estimate 7 that is very, very different from the original?
8 WITNESS ROBAREa I think it is based on more 9 than one occurrence. I think that occurrence initiated to a more indepth look at the system and its failure modes, 11 and the reliability numbers were changed based upon that 12 additional analysis and review.
13 JUDSE CARPENTER: Let me be sure I 14 u nd e rsta nd. Earlier, I got the implication that it was 15 almost exclusively as a result of this one event at 16 Browns Ferry that the estimated probabilities were 17 changed. And you are now testifying that apparently, 18 something different from that happened; that there was a 19 complete fresh look and other factors other than the 20 occurrence of the Browns Ferry event were considered.
21 (Panel of witnesses conferring.)
22 WITNESS ROBARE: I guess to clarify my 23 statement, as a result of the event, our engineers
() 24 resssessed the probability of this occurrence, and I am 25 not exactly sure of all of the factors they considered.
l
()
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5311
() 1 Certainly, they considered the fact that it happened. I 2 really shouldn't speak to the details of how they
(~T 3 reassessed that. I do not have personal knowledge of U
4 that.
5 JUDGE CARPENTER: Would you say that the 6 failure to anticipate the Browns Ferry event was a 7 failure of the methodology, or of the data base that was 8 applied in applying that methodology?
9 WITNESS ROBARE: I think.the methodology is a to good approsch to evaluating these systems. We have no 11 doubt about the validity of the methodology. The only 12 question was the appropriateness of the reliability 13 numbers that is independent of the methodology -- the 14 way I think you are asking it -- the fault tree 15 methodology.
16 WITNESS IANNIs Judge Carpenter, possibly, as 17 was pointed out earlier, the way they modeled the 18 dependencies may not be entirely correct, but the 19 methodology is oksy. It should be okay for that 20 particular situation that they had at Browns Ferry.
21 Maybe they should have more dependencies built into it.
22 From our logic diagrams here, it does not look 23 like they included dependencies, so it is the
() 24 application of the method and the raw data that is used 25 for failure rate. I think those are the two things that l
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() 1 most likely happened here to come up with that number.
2 JUDGE CARPENTER: What I am trying to get to ,
3 understand a little better is -- you say flow blockage
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4 was considered in the fault tree. Then I am curious as 5 to flow blockage due to crud, which would give some 6 basis for picking a probability vis a vis some other 7 mechanism for producing a blockage.
8 WITNESS ROBARE: That kind of detail is just 9 not in the report. I am sure when they put a number on to the blockage probability, they must have considered 11 sources of blockage and experience of blockages, and 12 unfortunataly, we just do not have that information with 13 us today that backs up that number.
O 14 JUDGE CARPENTER: Is the production of crud 15 rather uniform in all BWR's, or is there considerable 16 variation from plant to plant?
17 WITNESS ROBARE: Do you.mean crud in the area 18 of the scram discharge volume or inside the reactor?
19 JUDGE CARPENTERS In the sense that it is used 20 in Suffolk County Exhibit 20.
21 ( Panel of witnesses conferring.)
22 While they are conferring, Mr. McGuire, you 23 say you participated in the review at Browns Ferry?
24 WITNESS MCGUIRE: I consulted with Mr. Rosen 25 who was the manager of the analytical group at INPO.
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() 1 JUDGE CARPENTERS Did you get any basis for, 2 or any understanding that they felt that crud was a 3 strong possibility because of some indications of
)
4 sources of crud?
5 WITNESS MCGUIRE: No, sir. The only reason 6 the blockave came up was that when they dissssembled the 7 components that made up the system, they could not find 8 snything wrong with them. And what they had done was 9 they had scrammed the reactor, I think it says, four 10 times there. That in itself could have freed anything 11 up that was blocking a line.
12 JUDGE CARPENTER: But you do not know anything 13 about the previous Browns Ferry operations that would 14 make crud accumulation an unusually suspicious 15 candidate, let's call it?
16 WITNESS HCGUIRE: No, sir, I would not.
17 JUDGE CARPENTER: Thank you. That really ends 18 my exploration of this hypothetical discussion. Thank 19 you very much.
20 JUDGE MORRISs Now, Mr. Robare, I have just a 21 couple of quick questions. Has a new number been 22 calculated f or tha f ailure probability of the scram 23 discharge system?
() 24 WITNESS ROBARE: Yes. I do not have it with 25 me today. I understand that a new analysis has been O
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() 1 completed.
2 JUDGE MORRIS And did I understand you
{} 3 4
correctly that this 1976 study was really done as part of the ATWS investigation?
5 WITNESS ROBARE: Thst is correct.
6 JUDGE MORRIS Do you know whether the nev 7 number affected the final number on scram system 8 reliability in any way?
9 WITNESS ROBAREa The totsi?
10 JUDGE MORRIS: Right.
11 WITNESS ROBARE: I am not sure.
12 JUDGE BRENNER4 I suggested making the 13 connection to the upcoming ATWS contention more 14 explicit, but Judge Morris is turning into a good 15 lawyer, to his consternation, and indicated that you are 16 on notice. We can go back to the cross now.
17 55. LETSCHE: Judge Brenner, I think at this 18 point I would like to move what has been ma rked as 19 Suffolk County 20 for identification into evidence, and 20 I would bind it into the record at this point.
21 JUDGE BRENNER: You want to move it into 22 evidence? Are there any objections?
23 (No response.)
24 Well, in the absence, I am not going to object 25 sua sponte, but why don't you tell me the purpose for O
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- ( ) 1 which you rely upon these excerpts in evidence as 2 distinguished from your use on cross examination, when 3 it was just an identified exhibit?
4 MS. LETSCHEs Judge Brenner, I think it would 5 be helpful in connection with the testimony of the pa nel 8 concerning their application of the various postulated 7 causes for that Browns Ferry event. In their 8 methodology and the studies that they have done, they 9 were ref erring to this study, and Mr. Kascsak indicated 10 that he vss fsmiliar with the study. And Mr. McGuire 11 has indicated his involvement with the study, and I 12 think --
13 JUDGE BRENNER: You went beyond my question.
14 I was not asking about the foundation. I do not think 15 that was exactly Mr. Kascsak's testimony, but putting 16 that aside, he was familiar with it in the sense he 17 indicated.
18 But putting that aside, I am worried about the 19 same problem on a lesser scale quantity-wise than I have 20 expressed before with the FSAR. That is, I do not want 21 to admit a document into evidence and then find out 22 three months from now there is a sentence in there that 23 nobody has focused on here. He have certainly admitted
() 24 many documents into evidence without the authors being 25 present. That is not my problen. But the use of it was O
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() 1 much more inherent to the testimony elicited either on 2 direct or on cross than this document has been.
3 My perception, with which I invite you to
)
4 differ, is that the full use made of this document is 5 quite well laid out on the record already. But all 6 right, I have expressed my reservations. So with no 7 objection, we will admit it. And certainly, any 8 proposed findings that suddenly focus on something that 9 was not focused on here will be treated accordingly.
10 BR. ELLIS: May we have an opportunity -- we 11 did not review it. With that in mind, we thought it was s ,
12 being used for the limited purpose that it was used. Is 13 .i t going to be admitted for the truth of the matters O 14 asserted, including the matters not referred to in cross 15 examination?
16 JUDGE BRENNER: I have indicated the 17 limitation that we would place on it, and we will not 18 rely on it for anything that was not focused on in cross 19 examination. That does not mean portions of this might 20 not be usei for the truth of the matters asserted. I do 21 not want to get hung up on procedures. She moved it 22 into evidence and there was no objection. The only 23 reason we stopped this long was my own musings, and if 24 You wanted to object -- well, do you want to object?
25 MR. ELLIS: Well, I wanted to review the O
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() 1 document. I did not think the document was going to be 2 moved into evidence. I have not read it for that 3 purpose, and I do not know whether it might be more 4 spproprista, for example, to introduce the entire 5 document rather than just portions of it.
6 JUDGE BRENNER: That exacerbates the problem.
7 I indicated I did not expect it to be moved into 8 evidence either, but she made the motion about five 9 moments ago, and as I say, the only reason we stopped is to the dialogue I wanted to have.
11 MR. ELLIS: I was vsiting for the conclusion 12 of that dialogue.
13 JUDGE BRENNER: Yes, bu't the starting point 14 for the dialogue was the absence of any objections from 15 anybody. Why don't you take a moment and consider 16 whether you want to object or not.
17 (Pause.)
18 MR. ELLISs We have now reviewed it and have 19 no objection .
20 JUDGE BRENNER: In the absence of objection, 21 we will admit it into evidence as Suffolk County Exhibit 22 20, and it has been identified; that is, it is not the 23 complete report, it is just the excerpts previously 24 identified. I would like to bind a copy in, also, but 25 You will have to give the reporter a fourth copy to do O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5318 O i ta t- a <111 ataa it ta et tai ==1at-2 (The document referred to 3 was marked Suffolk County 4 Exhibit No. 20 for 5 identification.)
6 (Suffolk County Exhibit No. 20 follows s )
7 8
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. _- _c+w - m_ *n 7 Nuclear Safety Analysis Center '
Instituto of Nuclear Power Operations hb( 0
c a Analysis of Inconiplete Control Rod g ,
insertion at Browns Ferry 3 NSAC-20llNPO-s December 1980 e
Prepared by institute of Nuclear Power Operations Atlanta, Georgia e
aM Nuclear Safety Analysis Center Palo Alto, California 0
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ORDERING INFORMATION Copies of this report may be ordered from Research Reports Center (RRC). Box 50490, Palo Alto, CA 94303. (415) 965-4081.
a Keywords: Browns Ferry 3. Incomplete Control Rod inserton. Water Accumulaton in SOV, Comrnon Mode Fedure of Scram Systems NOTICE TNs report was prepared by the Nuclear Safety Analysis Center (NSAC) operated by the Electre Power Research Institute. Inc (Erno and by the institute of Nucreat Power Operatens (INFO) Neitner NSAC. EPRt.
INPO members of EPHI or INPO. Other persons contrcuting to or assistmg en the preparation of the report, not any person octeg on the benait of any of these parties (a) rnakes any warranty or representaten, empress or en-paed. with respect to the accuracy, conveteness or usetuiness of ine informaton conta.ned in tnes report. or that the use of any cr omsat.on, apparatus. metnod or process amciosed in this report may not mirmgo privatery owned rights, or (c) assumes any haboit cs with respect to the use of or for damages resulting trorn the use of.
any informaton, emaratus, method or process dischosed m this report.
. _ _ _ _ . _ . _ ._ _ _,.____. -, m . . __
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ABSTRACT The failure of 77 control rods in the Browns Ferry 3 reactor to scram completely on June 28, 1980 has been analyzed. It is concluded that the cause of the incident was that one half of the scram discharge volume, which should have been empty in order to receive'the water from the control rod drives, actually was almost full of water.
Any one, or a combination, of several rechanisms can contribute to accumulation of water in the 50V under certain conditions. It appears possible that there was an obstruction or a trap in the scram discharge volume exit line which impeded its drainage. Condensation of steam from other parts of the clean rad waste drain f-~ system in the scram discharge volume may also have contributed to water accumula-k- tion.
Despite extensive investigation and analysis by TVA and others a unique caus'e'has not been established. Possible ways in which the above cited mechanisms could have been operative are pointed out, and suggested ways for guarding against them are given.
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Contents
~
Analysis of
' Incomplete Control Rod Insertion at Browns Ferry 3
- 1. Introduction
- 2. Executive Sumary
- 3. Sumary Description of Incident
- 4. Findings and Conclusions 4.1 Principal Findings and Conclusions 4.2 Cause of the Incomplete Scram 4.3 Evidence for the " Obstruction Hypothesis" 4.4 Evidence for the" Vent Hypothesis" 4.5 The " Stuck Valve Hypothesis" 4.6 Effect of Scram on Fuel 4.7 Operator Response .
4.8 Role of the Vent and Drain Valves 4.9 Ancillary Questions 4.10 Sumary of Conclusions Appendices ,
SOE Sequences of Events DES System Description and Operation CON Reactor Response and Consequences OPS Operator Actions and Procedures References e
Glossary -
/
y O e
Analysis of Incomplete Control Rod Insertion at Browns Ferry 3 O
- 1. Introduction This report presents the results of a study by NSAC and INPO of the June 28, 1980 incident at the Browns Ferry Unit 3 reactor in which 77 of the full complenent of 185 control rods inserted only partially when a manual scram was attempted. The purpose of this report is to present a description of the incident, and some possible causes.
In carrying out this analysis, NSAC and INPO performed a preliminary review at the site on July 3, 4, and 5. Team briefings and meetings were held with General Electric and Tennessee Valley Authority, and individual consultations were held with GE, TVA, and several utilities. NSAC and INPO also participated in several industry and NRC meetings on the incident.
O NSAC/INPO contributors to this evaluation were:
Mr. R. S. Baker Mr. D. L. Gillispie I
Mr. W. H. Layman Dr. M. C. Leverett Mr. J. W. Power
~-~
Mr. S. L. Rosen Utility representatives who also contributed were:
Mr. B. L. Clark, Philadelphia Electric Mr. B. B. Palagi, Commonwealth Edison Mr. John Stetz, Northeast Utilities
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9
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Executive Summary Event O-During a routine manual scram of the Browns Ferry 3 reactor, 77 control rods failed to insert completely.
Background
On June 28, 1980, a manual scram of the Browns Ferry 3 reactor
- was attempted in conjunction with a planned shutdown for repair of a feedwater line in the turbine building. Aside from the need for this repair, plant conditions were normal.
The shutdown procedure involved first lowering the reactor power level to 36% by reducing the recirculation flow and inserting a number of control rods to decrease the neutron chain reaction; and secondly pushing the manual scram buttons to insert all control rods completely to terminate the neutron chain reaction.
Complete control rod insertion is normally accomplished in less than 3 seconds after both scram buttons are pushed. In this incident, normal control rod O insertion did not occur when the scram buttons were pushed.
Description of Event ' -
Of 185 control rods,10 were fully inserted prior to the manual scram. 77 rods failed to insert fully upon manual scram, with insertion ranging from position 02 (95% inserted) to position 46 (5% inserted). Observing this, the operator reset the scram; this procedure allows recharging of nitrogen-pressurized accumulators and draining of the scram discharge instrument volume. Manual scram was repeated. Insertion progressed somewhat, but 59 control rods remained only partially inserted. After a third reset and manual scram, 47 remained partially inserted.
Recharging and draining of the scram discharge instrument volume was repeated and the scram instrumentation automatically initiated a fourth scram. All rods were
([]) now fully inserted, placing the reactor in normal shutdown condition. This was accomplished within about 14 minutes of the first scram.
- Unit 3 is a 1067 Mw(e) net. General Electric boiling water reactor, in commercial operation since March 1, 1977.
. 2
> . n The following observations are significant:
The fir.st scram' decreased the chain reaction so that the smeared average fission power level was about 27. of full power. The second scram terminated the chain reaction so that the only remaining heat generation was normal decay heat generation.
[
There were no indications that delay of full insertion until the fourth scram caused any damage to fuel, to the reactor, or to any other part of the plant. .
Natural circulation core flow provided more than adequate overall core cooling.
General Electric calculations indicate that no fuel operating limits were exceeded. -
Scope of Analysis This is the only known instance of a large number of control rods failing to, insert completely on depand. Because of the crucial importance of being able to shut the reactor down quickly and reliably when needed, the reactor owner, the reactor designer, the NRC, and a joint NSAC-INP0 team attempted to determine the causes of this failure to achieve full insertion on the first scram.
Efforts were also directed at identifying measures to prevent a repetition of this
.J or similar failures in this and any other boiling water reactor. The failure was of further interest to NSAC and INP0 as a possible precursor to more serious events. ,
Findings ,
After the first scram attempt, the operators observed that all but one of the l O control rods which failed to insert were on the east half of the reactor.* This behavior of the system led plant personnel and others to believe that the east scram discharge volume (50V), a void into which reactor water is displaced when
- . The scram hydraulic system is shown diagrammatically in Fig.1. The arrangement of the scram discharge volume is shown in Figs. 2 and 3.
3
high pressure water drives the east side control rods into the reactor, was for-some reason already almost filled with water prior to the scram. The SDV could not accomodate the additional water discharged into it during a normal scram and O thererare '#sertio" s i=neded- this co"c'es'o# aes s'#ce bee" re-exe='"ed e#d stands generally accepted. Other possible causes of the incomplete scram have been analyzed and largely ruled out. The origin of the water in the SDV and the cause of its accumulation have not been firmly established, but several possible explanations have emerged. None individually can be confirmed, and a combination of them is also a possibility: , ,
There may have been an obstruction in the 170' long 2" pipe which connects the east scram discharge volume to the scram discharge instrument volume (SDIV). This line has only a very slight slope for drainage, and a slight obstruction would have been sufficient to back up water into the scram discharge volume prior to the scram. It has been theorized that such an obstruction could have been disturbed and relocated by the violent hydraulic action in the SDV af ter the multiple s, crams which took place. It is not possible to state with assurance, th6 ugh, that such an obstruction actually did exist. It has been O suggested that the obstruction could have been formed by the accumulation of solid crud. Solid crud has been found in level switches on the scram ,
discharge instrument volume. However, no positive evidence of an obstruction in the 170' long 2" line has been found.
A combination of trapping action in the east SDV vent line and in the east SDV-SDIV 2" connector pipe, together with condensation of steam in the east SDV, may have produced a partial vacuum. The occurrence of such
- a partial vacuum has been observed in the SDIV of Browns Ferry 1, which 3 is very similar in piping configuration to Browns Ferry 3, and on at least two other BWRs. There is no proof, however, that this was the cause of the incident. .
Either of the foregoing may have been aggravated by momentary pressure or vacuum surges in the clean radwaste (CRW) drain system caused by large influxes of water from sources other than the SDIV. Both the SDV vent lines and the SDIV drain line discharge into the CRW drain system. This hydraulically complex system receives intermittent drainage from approximately 50 other sources. Some of that drainage is frequently hot water, which could increase pressure or suction surges.
- 4 ,
t I
l Conclusfons ,
$1nce it has been impossible to determine whether any of these possibilities or combinations of them were responsible for the incident, corrective action recom-mendations should be comprehensive enough to guard against all of them. It is concluded, therefore, that appropriate steps should be taken by all BWR plants to guard against:
An obstruction in the SDV-SDIV connection pipes.
A configuration of the SDV-SDIV connector or vent pipes capable of producing a trap or loop seal. Such a trap or loop seal could possibly be the result of thermal expansion during hot conditions although it may not be present in a cold environment.
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Interference by the CRW drain system with the operation of the SDV- -
D '
Failure of the SDV vent line valves to open.
Too slow drainage of the SDIV due to inadequate vent or drain capacity.
The review team also examined the procedures available to the operator for an event of this type, and the response of the operators to those procedures, par-ticularly with respect to the criteria for deciding whether to inject sodium pentaborate from the standby liquid control system. It is concluded that these criteria should provide more explicit guidance in determining the need for sodium pentaborate injection.
The conclusions outlined above are intended to apply to all BWRs with hydraulic control rod drives, operating or in construction. It is recognized that the g specific corrective measures which should be taken will vary from plant to plant because of design variations and differing procedures.
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5319 O ' 8' "s ts:scas cae== ino) 2 0 3entlemen, I would like to direct your 3 attention to page 64 of your pre-filed testimony, 4 Section 0, labelad, " Common mode fsilures and protection 5 and control instrumentation." Who conducted this study 8 referenced in this section?
7 A (WITNESS ROBARE) That was a General Electric 8 study.
9 0 Is this also a generic study?
10 A (WITNESS ROBARE) Yes, it is.
11 0 When was this done?
12 A (WITNESS ROBARE) It was published in July of 13 1970.
14 0 Does it have a name?
15 A (WITNESS ROBARE) An Analysis of Functional 18 Common Mode Failures in GE BWR Protection and Control 17 Instrumentation. Its number is NEDO-10189.
18 0 Was this study done in response to a 19 regulatory requirement?
20 A (WITNESS ROBARE) No, it was not. This was a
, 21 study to evaluate the effect of common mode failures in l
! 22 the reactor protection system. In essence, they looked 23 at the transients and accidents, those as represented in l
() 24 Chspter 15 of the Shoreham FSAR, and they a ssumed 25 failures of sensors that had a common design, such as O
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5320 O i **er 1 11 a 11 or ** ter 1 v t ia tra at tioa 15 it 2 was of identical design and then they evaluated the 3 impact of that failure upon the resulting accident or 4 transient.
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) 1 0 Has the study been updated subsequent to the 2 July 1970 date you mentioned?
() 3 4
A (WITNESS ROBARE) No, it has not.
hasn't bean a per eived need to updata it.
There The 5 conclusions of the report were that the systems were 6 very well designed. And particularly, this report is 7 directly spplicable to Shoreham and there has been no 8 design change that would invalidate the analysis of this 9 report or its conclusions.
10 Q You just stated that the report is directly 11 applicable to Shoreham. How did you determine that?
12 A (WITNESS ROBARE) It is a generic report in 13 that it evaluated a typical plant for purposes of the O 14 analyses. A worst-case plant was utilized that bounds 15 the consequences for the Shoreham-type design. We 16 utilized FMEAs and logic diagrams and considered, as I 17 said before, the common-mode failure effects and 18 failures.
19 0 SE has not done any kind of a walkdown of the 20 Shoreham plant in making the determination you just made 21 -- or you just stated, has it?
22 A (WITNESS ROBARE) A walkdown for what 23 purpose?
24 0 To determine that this repor,t is directly 25 applicable to Shoreham.
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() 1 A (WITNESS ROBARE) There would be no no naed to 2 do a walkdown to determine that. The way the report was 3 prepared, it was assumed that all equipment of the same 4 design failed concurrently and the assessment was made 5 as to the increase in severity of the event with that 6 common-mode failure.
7 0 But how do you know the effect of that 8 particular failure in the Shoreham plant if you have not 9 looked at the particulars of the Shoreham plant?
10 A (WITNESS ROBARE) The var the study was 11 performed, an assessment was made of the ef fect of the 12 failure of these multiple sensors or instruments,'and a 13 mechanistic analysis was performed to assess that f' 14 impact.
15 (Counsel for Suffolk County conferred.)
16 (Panel of witnesses conferred.)
17 A (WITNESS ROBARE) I think I misunderstood your 18 question. Do you mean when we made the assessment, how 19 did we know we were looking at the Shoreham design 20 specifically?
21 0 Well, I guess that is one question. I am not 22 sure if that was the one I just asked you. My real 23 question was, or is now, at any rates when you made 24 this assessment of the effects of the failures that you 25 assumed in the study, how did you know the particular O
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() 1 equipment that was going to be in the plant that you 2 were determining the effects on?
3 (Panel of witnesses conferred.)
4 A (WITNESS ROBARE) The reactor protection 5 system utilizes for plants like Shoreham utilizes the 6 same sensor. It senses the same functions, and it 7 causes scrams identically in all plants. So there was 8 no need to look specifically at Shoreham drawings or to 9 go to Shoreham.
10 We wouli just assume that all the water level 11 instrumentstion failed, or we would assume that all of l
12 the containment pressure signals failed, or we would 13 assume that all of the reactor pressure signals failed.
I ' There would be no need to look at a Shoreha m-unique 14 15 plant arrangement. The trip f unctions are identical for 16 all plants covered by the study.
17 DR. JORDANS But it seems to me that she is 18 asking what are the effects, and the effects have to do 19 surely with the number of safety valves that open, I
20 whether the opening of the safety valves would prevent 21 uncovery of the fuel elements and things like that.
! 22 Those are the things that are unique to Shoreham, and I i 23 think that she is getting at thats did you include the
() 24 Shoreham-unique things to recover from this ATWS event?
25 WITNESS ROBARE: By the way, it was not ATWS.
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() 1 Specifically, it was 111 of the transients and accidents 2 and not ATWS. But as I stated previously, we utilized a 3 worst-case plant when we did the analysis to be sure 4 that we were bounding a plant like Shoreham as far as 5 the consequences of the event with the multiple-failure 6 1ssumption.
7 (Counsel for Suffolk County conferred.)
8 BY MS. LETSCHEs (Resuming) 9 0 Nr. Robare, what systems did this study 10 analyze?
11 A (WITNESS ROBARE) The reactor protection 12 system.
13 0 That is all?
14 A (WITNESS ROBARE) Yes.
15 0 Did the study include any analysis of the 16 interface with that system with other systems that might 17 not have been within the GE scope of supply?
18 (Panel of witnesses conferred.)
19 A (WITNESS ROBARE) No, it did not.
20 JUDGE BRENNER: Mr. Robare, is your answer the 21 same if we remove the limitation within the GE scope of l
22 supply at the end of that question? More directly, did 23 the study involve interactions with any other systems, 24 even those within the GE scope of supply?
25 (Panel of witnesses conferred.)
O l
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5325 1 WITNESS ROBARE The reason I characterized it 2 as a systess interaction study is becsuse the reac to r 3 protection system takes signals from all around the 4 plant and utilizes those to determine the need to 5 scram. So there are sultiple systems involved in the 6 input to the reactor protection system.
7 (Counsel f or Suf folk County conf erred.)
8 BY MS. LETSCHE: (hesuming ) )
l 9 0 Mr. Robsce, can you tell me what -- I am a j 10 little confused with the answers to the interf ace 11 questions -- what the boundaries of the study were? j 12 A (WITNESS ROBARE) We looked at all of the 13 transients and accidents in Chapter 15. Then we looked 14 specifically at the reactor protection system, which is 15 the system that determines the need for scram. And then 16 we systematically assumed common-mode failures of all 17 identical sensors that feed the reactor protection 18 system, and they might have come from various other 19 systems. -
20 And then we ran an analysis, as we do in 21 Chapter 15, that showed the consequence. We modeled the 22 event with those common-mod e f ailures and analyzed the l
23 results.
24 DR. JORDAN: I think I understand now what you ,
25 are saying, and I did not before. You were saying you ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() I were not assuming that the scram does not occur ; you are 2 saying tha t if all of the pressure switches, say, fail 3 or all of the high-flux switches fail one by one, all of 4 the instruments of a given kind, then what you are 1
5 saying, I think, is that they will be backed up, and it 6 is sometimes called functional diversity, that the scram 7 will still occur? Is that not right?
8 WITNESS ROBAREs I wish I did it as well as 9 you did it.
10 BY MS. LETSCHEs (Resuming) 11 0 Mr. Robare, I just want to clear up, you said 12 that the study vis done of all of the Chapter 15 13 accidents. Let me tell you the reason for my 14 confusion. You state in your testimony a study was made 15 of the BWR 4 response to various operational transients 16 and accidents.
17 A (WITNESS ROBARE) Are you auestioning whether 18 it was exactly all that are in Shoreham?
/ 19 0 What I wanted to know was if they are the 20 Chapter 15, the ones that are in the Chapter 15 analysis 21 for Shoreham, or if they were ones that were in
, 22 existence in 1970 when you did the study, or what ones 23 they are.
() '
24 (Panel of witnesses conferred.)
25 A (WITNESS ROBARE) It would be all of the
)
.i !
/' ALDERSON REPORTING COMPANY,INC, 400 VIRGlNIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
5327 O ' tr te t a* c=14 =t= 1= the c=rre=t shorea rsaa 2 that utilize the reactor protection system scram for 3 mitigation. So it would not be events such as a 4 fuel-handling accident. Any time a scram is called for 5 in a Chapter 15 analysis, this report will show the e effect of losing the common-mode equipment.
7 (Counsel for Suffolk County conferred.)
8 Q And the point of the study was to demonstrate 9 that if you did have these failures, you would still be 10 able to achieve the scram? That was the purpose of the 11 study?
12 A (WITNESS ROBARE) No, that was not the purpose 13 of the study. We know by design that that is the case.
O 14 The purpose was to evaluate the severity of the event 15 with these common-node failures. In other words, the 16 common-sode failure of all of your water level 17 instrumentation or all of your pressure instrumentation 18 is outside the design-basis approach of the plant. But 19 in order to assess the sensitivity of the plant to that 20 unlikely occurrence, this report was prepared so we 21 could assess the sensitivity.
22 (Counsel f or Suff olk County conferred. )
23 JUDGE BRENNER: Is there an outstanding 24 question?
25 MS. LETSCHEa No, there is not.
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2 0 Mr. Robare, just clear up one thing. You have 3 explained the things that you fail in doing the study.
4 With respect to the water level transmitters, do you 5 fail all of the water level transmitters that are in one 6 train?
7 A (WITNESS ROBARE) No, we failed all of the 8 water level transmitters in the plant vessel water 9 level.
10 11 12 13 f
0 14 15 16 17 18 19 20 21 1
22 23 24 25 O
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() 1 [ Counsel for Suffolk County conferring.1 2 0 Were there any changes made in the design as a 1
3 result of this study?
4 A (WITNESS ROBARE) There were no changes deemed 5 necessary from the report conclusions.
6 (Counsel for Suffolk County conferring.]
7 Q Okay, I would like to move on to the next 8 section, which is P, wa ter level instrumentation, also 9 on page 64 of youur testimony.
10 Who conducted the study that is reference here?
11 A (WITNESS ROBARE) General Electric.
12 Q When was this done?
l 13 A (WITNESS ROBARE) This was done approximately J l
J 14 last September, plus or minus two months.
l l
15 0 Where is the study documen ted?
16 A (WITNESS ROBARE) The study is documented for 17 Shoreham in the response to WRC Question 223.91. I 18 should say the results of the study.
19 Q Was that study on water level limited to a 20 study of the flashing problem that happened in the 21 Pilgrim event?
22 A (WITNESS ROBARE) The response to Question 23 223.91 is limited to the boil-off type problem. It is
() 24 not the Pilgrim scenario. It is a small break LOCA.
25 But it is the boil-off phenomena.
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400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5330 O i 0 raet t ar ata ot 1 c1=ae trei or -
2 cold reference lake failure such as mentioned in Suffolk 3 County Exhibit No. 17 J
4 A (WITNESS ROBARE) No, that particular study 5 did not. However, an assessment was made of the 6 reference lake failure also for Shoreham.
7 0 Where is that documented?
8 A (WITNESS ROBARE) That has not yet been placed 9 on the docket since the NRC has not requested it.
10 0 When was that study done?
11 A (WITNESS ROBARE) Approximately last November.
12 0 Was that also done by GE?
13 A (WITNESC ROBARE) Yes, it was.
14 0 What techniques were used in doing that study?
15 A (WITNESS ROBARE) Which one, now? We have 16 been talking about two.
17 0 The latter one, the dealing with the problem 18 referenced in Suffolk County Exhibit 1, the failure, the 19 reference lake failure.
20 A (WITNESS ROBARE) The technique there was to 21 assume the break of one reference lake and then to 22 avaluate all conceivable worst single failures in the 23 plant and to assure that a safe shutdown was attainable.
24 [ Counsel for Suffolk County conferring.]
25 0 How did you go about doing this? I think you O
ALDERSON REPCRTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5331 just told me what the scope of the study was.
(]) 1 What did 2 you do in order to find this out?
3 MR. ELLIS: Judge Brenner, I may be mistaken, 4 and it may be because there has been a platoon system 5 here. I thought we had been all through both of these 6 studies before with Mr. Lanpher, the reference lake 7 break and the boil-offs, at some length.
8 JUDGE BRENNER: Do you mean the particular 9 study referenced in subpart P?
10 MR. ELLIS: Yes, sir.
11 JUDGE BRENNERa It has come up. I don't think 12 we have been all through it.
13 MR. ELLISa Well, the question that has just 14 been asked is a reference lake break, and tha t certainly 15 was explored. It is in the latter part of our 16 testimony, in any event.
17 JUDGE BRENNERa If you can point me some 18 pisce. I am not saying you are incorrect, Mr. Ellis; I 19 just don't recall the particular question or the 20 context, that is, what methods did you use to assess j 21 it. We have certainly talked about what occurred. We 22 have talked about Suffolk County Exhibit 1. We have 23 discussed the difference between two different types of
() 24 water level instrumentation problems. But I certainly 25 hope we haven't explored it, and the reason I indicate O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345 l
5332 O i ta t 1 tae se ra a 1ot or aue tioa e e or waica .
1 were held of f, you might recall, from the other week I 2
3 with respect to Suffolk County Exhibit 1 so that Judge 4 Jordan could review it.
5 MR. ELLISs All right, sir.
6 WITNESS BOBARE: The approach used to evaluate 7 the scenario was to assume a break in the one reference 1
8 lake and then to look at all possible worst concurrent 9 single failures, and then to assure that the plant could to be safely shut down either through an autoastic scram or 11 through an automatic emergency core cooling system 12 function for the first ten minutes.
13 BY MS. LETSCHE (Resuming)s O
14 Q Okay. I think that is what you told me 15 before. What I want to know is what techniques did you 16 use in order to do these things, to look at all the 17 worst concurrent single failures to identify those 18 failures and to get the assurance that you wanted to end 19 up with ?
20 A (WITNESS ROBARE) Well, there were two 21 techniques. The first technique was to prepare a matrix 22 specifically for the Shoreham plant using the Shoreham 23 documents, a matrix of single failures and systems 24 available. A second technique would be to utilize the 25 computer to assess that event much as we do in Chapter O
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() 1 15 transient and accident analyses to assess the water 2 level change and pressure, and primarily those two.
3 (Counsel for Suffolk County conferring.]
[ )
4 0 Mr. Robare, in your study was the reference 5 lake break and the subsequent heatup considered a single 6 failure and then an additional single f ailure was 7 assumed following that or in addition to that?
8 A (WITNESS ROBARE) Yes. We assumed the 9 reference lake break and the consequences of that 10 environmental change in that area, and thcn we looked 11 for the worst single failure throughout the plant.
12 (Counsel for Suffolk County conferring.)
13 0 . Did your consideration of other single 14 failures include the possibility of a failure of the 15 other lake?
16 A (WITNESS ROBARE) No, it did not. That would 17 be considered a double event, not a singla failure.
18 0 So the other single failures you were looking 19 at after your assumed failure of the reference lake 20 wouldn't include looking at any other part of that 21 system, part of the water level system, because then it 22 would be a double event?
23 [ Panel of witnesses conferring.]
24 A (WITNESS ROBARE) We looked at the failure of 25 one reference lake break and then the worst single O
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5334
() 1 failure, which could include the other water level line 2 instrumentstion, yes, but we did not consider breaking
/ 3 both reference lakes concurrently. We would take a 4 failure of the other instrument in the other lake but 5 not the line break itself in both lakes.
6 JUDGE BRENNERs Ms. Letsche, we are coing to 7 break the testimony, at least soon, in about five 8 min utes from now. So anyplace you find that is 9 convenient.
10 BY MS. LETSCHE (Resuming):
11 0 Mr. Robare, did your analysis assume a heatup 12 and possible misleading water level in the other lake 13 and then assume a failure?
14 [ Panel of witnesses conferring.]
15 A (WITNESS ROB ARE) We did consider the 16 environmental effect of the break in the reference lake, 17 ye3.
18 0 I just want to clarify one thing. The study 19 that you have been discussing just now is not the one 20 that you reference as a systems interaction study in 21 your testimony; is that right?
22 A (WITNESS ROBARE) That is correct. However, 23 there is a reference to the scenario we are discussing 24 in the testimony.
25 JUDGE BRENNERs Section 7C? Take a look O
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5335 1 between 150 --
(~}
2 WITNESS ROBARE It is on page 158 of our 3 prefiled testimony. It starts on page 157, Footnote 39.
L 4 BY MS. LETSCHE (Resuming):
5 0 But you haven 't docketed this other study in 6 this proceeding, right?
7 A (WITNESS ROBARE) That is true.
8 0 This is a Shoreham-specific study?
9 A (WITNESS ROBARE) Yes, it is.
10 0 Have any equivalent studies for other plants 11 been docketed anywhere else?
12 A (WITNESS ROBARE) Yes, there is a docketed 13 study on the Grand Gulf plant, Mississippi Power and 14 Light.
15 Q With respect to a study that you do reference te in your systems interaction section of your testimony 17 here, were FEM As done in connection with that study?
18 A (WITNESS ROBARE) No, that was strictly a 19 mechanistic evaluation of plant parameters.
20 JUDGE BRENNEBa Ms. Letsche, I wonder if I 21 could back up one question for a moment.
22 Mr. Robare, is Grand Gulf a BWR-6?
23 HITNESS ROBARE: Yes, it is.
() 24 JUDGE BRENNERa Is that difference material in 25 the context of the water level study, the difference O
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() 1 between Grand Gulf and Shoreham?
2 WITNESS ROBARE: They are different enough to 3 require a plant-unique evaluation for this particular 4 scenario. The nunber of diesels vsry and the number of 5 sensors vary.
6 BY MS. LETSCHE (Resuming):
7 0 Mr. Robare, were any changes made in the 8 Shoreham pisnt is a result of the study you reference in 9 your systems interaction testimony?
10 A (WITNESS ROBARE) No, no changes were deemed 11 necessary.
12 0 Were there any changes in the procedures
, 13 developed as a result of that study?
\s- 14 A (WITNESS ROBARE) There were no changes as a 15 result of that study. There have been as part of the 16 emergency procedure guideline effort and the emergency 17 operating procedures for Shoreham. There have been 18 incorporated in those documents a write-up to alert the 19 operator of this potential condition.
20 0 The boil-off problem?
21 A (WITNESS ROBARE) Yes.
22 0 Do you anticipate that there will be any 23 changes made as a result of the other study that you and h 24 I were discussing relating to water level?
25 A (WITNESS ROBARE) No, that study confirmed the l
O 1
l t
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() 1 adequacy of the design.
2 [ Counsel for Suffolk County conferring.]
3 MS. LETSCHE: Judge Brenner, that is all I
)
4 have on this subsection.
5 JUDGE BRENNER: Fine. We will break the 6 testimony for today.
7 Mr. Ellis, I didn't want to interrupt the 8 questioning to pursue your point earlier as to previous 9 testimony. I certainly recalled the area, and I went 10 back to my notes, and what you undoubtedly had in mind 11 was the cross examination by Mr. Lanpher on the morning 12 of June 18th, starting, I think, just before the 13 mid-morning break and continuing up until the lunch O 14 break on this subject, and you also undoubtedly had in 15 sind Section 7C of the direct testimony, of which we are to cognizant and I assume Ms. Letsche is, but I didn 't hear 17 those particular questions in the context. It may have 18 been an individual question or two that was a repeat, I 19 am certainly not sure.
20 But in the absence of your pointing to 21 anything, you got the ruling you got. In addition, even 22 if there had been one or two questions that were the 23 same, it was going in a different direction. You 24 recall also that the Board plans to come back wi th 25 respect to the Michaelson memo.
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() 1 Ms. Letsche, I do hope, however, that you have I 2 read the transcript or at least scanned it to know if 3 you should read it closer for times when you have been
{
4 out of the hearing room on Contention 7B, because there 5 is that interrelationship. I don't think your 6 questioning was red undant, as I just indicated, but that 7 possibility does obtain, and I assume that you and 8 co-counsel are talking with each other and attempting to 9 avoid that problea.
10 MS. LETSCHEs Yes, Judge Brenner, we are.
11 JUDGE BRENNER: Speakiong of the Michaelson 12 memo, which is Suffolk County 1 for identification, some 13 of us are lucky and have through the end, which is page 14 39. Others terminate at page 38. We could use about 15 four copies of page 39 for th e 0 a rd .
16 More importantly, I would appreciate it if the 17 County could ascertain with the Reporter to make sure 18 that the exhibit that goes into the official file is 19 complete.
20 MS. LETSCHE: I can do that, Judge Brenner.
21 JUDGE BRENNER: The Board has no other matters 22 on the record. We have some minor logistical things, as 23 I indicated, which we will do off the record.
24 Is there anything that need be done on the 25 record today in terms of any miscellaneous matters?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVL 3.W., WASHINGTON, D.C. 20024 (202) 554-2345
5339 O ' ("o re aoa e i 2 JUDGE BRENNER: All right. In that case, we 3 will recess the on-the-record proceeding until 9 o' clock 4 tomorrow morning, but we vill still stay in public 5 session off the record.
l 6 The witnesses can and should leave.
7 [Whereupon, at 4: 55 p.m. the hearing was 8 recessed, to reconvene at 9:00 a.m. the following day, 9 Thursday, June 24, 1982.]
10 11 12 13 D 14 15 16 17 18 19 20 21 22 23 24 25 O
ALDERSON REPORTING COMPANY,INC, 4M VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
NUCLEAR REGULATORY COMMISSION Tcis is to certify that the attached proceedings before the l BEFORE THE ATOMIC SAFETY & LICENSING BOARD i
in the matter of. Long Island Lighting Company (Shoreham Nuclear Power l
$tation)
- Date of Proceeding: June 23, 1982 Docket Nu::tber: 50-322 OL Place of Proceeding: Riverhead, New York were held as herein appears, and. that this is the original transcM.pt '
thereof for the file of the Commission., ,
Ray Heer Official Esporter (Typed) 0 0 A 2 OfficiaM aporter (Signature)
F S
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