ML20054L584
| ML20054L584 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/06/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8207080267 | |
| Download: ML20054L584 (133) | |
Text
__ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- NC"'M REGULATORY CO.50CSSICN q -
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BEFORE THE ATOMIC SAFETY,AND LICENSING BOARD I I l ,
In ~e Mat: 2 r cf: :
LONG ISLAND LIGHTING COMPANY :
- DOCKET NO. 50-322-OL (Shoreham Nuclear Power Station) :
CATE: July 6, 1982 PAGzg: 5701 - 5832 AT: Riverhead, New York
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5701 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 - - - - - - - - - - - - - - - - -x 5 In the Matter of a e LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL 7 (Shoreham Nuclesr Power Station) :
8 - - - - - - - - - - - - - - - - -x 9
10 ,
Riverhead Town Hall 11 200 Howell Avenue 12 Riverhead, New York 11901 13 Tuesday, July 6, 1982 14 The hearing in the above-entitled matter 15 convened, pursuant to notice, at 10:37 a.m.
16 BEFORE:
17 LAWRENCE BRENNER, Chairman 18 Administrative Judoe 19 JAMES CARPENTER, Member 20 Administrative Judge 21 PETER A. MORRIS, Member 22 Administrative Judge 23 WALTER H. JORDAN, Assistant to the Board O 24 Admin 1=tretive Judoe 25 0
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 ,
5702 1 APPEARANCES:
2 On behalf of Applicant:
3 ANTHONY F. EARLEY, Esq.
4 W. TAYLOR REVELEY III, Esq.
5 T. S. ELLIS III, Esq.
6 3 unton & Williams 7 707 East Main Street 8 Richmoni, Vs . 23212 9 On behalf of the Regulatory Staffs 10 EDWIN REIS, Esq. l l
11 RICHARD RAWSON, Esq.
12 Washington, D.C.
13 On behalf of Suffolk County:
14 LAWRENCE COE LANPHER, Esq.
15 KARLA J. LETSCHE, Esq.
16 Kirkpatrick, Lockhart, Hill, 17 Christopher C Phillips 18 1900 M Street, N.W.
19 Washington, D.C. 20036 20 21 22 23 24 25 O
ALDERSON REPORTING COMPANY,INC,
-400 VIRGIN 1A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5702-A O .
E o. E T " E T. s.- - -
2 WITNESSES: DIRECT CROSS REDIRECT RECROSS BOARD 3
Q 4 Vogin Joksimovich, Edward T. Burns and' Robert M. Kascsak'(Resumed) 5 By Ms. Letsche 5719 6 (Af ternoon Session. . . . . . page 574 3) 7 Vogin Joksimovich, 8
Edward T. Burns and Robert M. Kascsak (Resumed) g By Ms. Letsche 5743 to
.E _X _H _I _B .I T .S NUMBER IDENTIFIED RECEIVED ,
i 13 Suffolk County No. 24 5741 14 Suffolk County No. 25 5773 15 Suffolk County No. 26 5792 16 17 18 RECESSES:
19 Noon - 5742 20 Afternoon - 5787 21 22 23 O 24 25 O
A1.DERSON REPORTING COMPANY. INC.
400 VIRGINf A AVE., S.W, WASHINGTON. D.C. 20024 (202) 554-2345
5703 IEQcgIoIggg Q 1 2 (10:37 a.m.)
3 JUDGE BRENNER: Good morning. We have some O 4 preliminary miscellaneous matters with respect to the 5 schedule for hearings this week. We are going to 6 adjourn at 4 :00 o' clock today, and at 2:30 on Friday.
7 We will give some consideration to starting at 8:30 in 8 the morning on Friday, and we will let you know on l
9 Thursday.
10 We have last week received three motions to 11 stribe filed by LILCO with respect to portions of 12 Suffolk County's or intervenor's testimony on Suffolk 13 County Contentions 3, 21 and.27. We would like to set a ,
O 14 schedule for responses to those motions.
l I
15 If parties wish to file a written response, it 16 should be received at the hearing by the Board by 17 Thursday, July 15. We will hear argument on responses -
18 to the motion probably on Friday, July 16. If you do 19 not wish to file a written response, that is acceptable, 20 and we will just hear your oral argument on the day set 21 f or oral a rgument which will probably be July 16.
22 I think , given the extra time we are 23 providing, at least a brief written response might
() 24 . assist us, but it is not mandatory. If you file a 25 written response, we would appreciate a separate page O
ALDERSON REPORTING COMPANY, INC, l
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 1 1
5704
{} 1 for each motion.
2 With respect to emergency planning, this 3 morning we received the status report of counsel, and I O 4 don't have the title in front of me, but I believe it is 5 the First Amended Joint Contentions, or something to 6 that effect.
7 MR. LANPHER: That is correct. I think 8 actually, af ter you gentlemen went in the back, LILCO 9 submitted something also on emergency plannig to your 10 mailbox.
11 MR. REVELEY: We did, Judge. We put some 12 objections in your mailbox. -
13 (Laughter.)
14 MR. REIS: The staff also has objections. The 15 staff would prefer to orally address it, in that written 16 pleadings were not called for in this matter. However, 17 the staff still objects to large portions of the revised 18 emergency planning contentions.
19 JUDGE BRENNERs We need a written pleading on 20 that because we are not ready to grapple with it today 21 and we need to conf er, and it was certainly our 22 intention, if we didn't say so expressly, that we 23 receive a written response. That is the way it worked
() 24 the first round.
25 I don't want to take hearing time away from l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345 l
5705 1 it. We may well have oral argument on the objections.
/~ )
2 When do you think you could get a written pleading in?
3 MR. REIS: I would say on Friday.
O 4 JUDGE BRENNER: The first thing Monday morning 5 would be all right, too, if you also fot it to the 6 opposing parties and LILCO.
1 7 MR. REISs Fine. l 8 MR. LANPHER: Judge Brenner, could I inquire l 9 as to the time for filing of written. This is the first to time we have seen these particular written objections 11 from LILCO, which we received this morning. We were not 12 expecting them. We were planning to, if appropriate, to 13 file a written response to try to focus the issues so 14 that oral argument, when you do have that, is as short 15 as possible. So in light of this filing next Monday, 16 when shou 11 our written response be filed?
17 JUDGE BRENNER: Let's try this. In the spirit 18 of the informal dialogue that has been ongoing and is 19 going to continue as contenplated from my brief reading 20 of the sta tus report and as we had discussed previously, 21 let's get your response to the objections to the extent 22 you can on Monday morning. Hopefully, you can talk with 23 the staff, and since they are apparently ready orally
() 24 and off the record, get their position.
25 To the exten t something surprises you in their O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
5706 1 written filing that we receive on Monday we will handle 2 that as appropriate, depending upon how large a surprise 3 there is, if any. If it is not much, we vill just take o
U 4 it up during the oral discussion.
5 We would like to try to come to g rips with 6 this next week, if possible. It depends upon our 7 ability to focus on it in the interim, also.
i 8 MR. REIS: Your Honor, if I may say, the staff 9 has written notes thtt I can give to the intervenors.
10 They expected, staff expected, in light of the .
11 discussions that there would be considerable change in 12 the submitted contentions and findings, and they were 13 disappointed in that. We d o ha ve written notes we can 14 give to them. There may be some change in position from 15 the written notes, but at least it will give them a 16 start.
17 JUDGE BRENNER: Fine. And hopefully, you can 18 all discuss it, also. The only thing I was going to 19 say, other than the obvious fact that we are not ready 20 to take up the matter, is we also received a filing from 21 Mr. Shapiro at the end of last week, and that confused 22 se totally since the idea is to bring the filings 23 together, which the initial filing had, and not separate O 24 them. and 1 aust den t went to dea 1 with a seperate 25 filing.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5707
() 1 How is tha t taken care of in the filing we 2 received today?
3 MR. LANPHER: We received tha t filing at the 4 end of last week at the same time you did, Judge 5 Brenner, and my understanding is that my colleagues in 6 Washington spent a substantial portion of the weekend 7 taking Mr. Shapiro's filing and putting it in what we 8 served on you today. And my understanding is that it is 9 all in there. I can confirm that by phone later this 10 morning. That is my understanding. .
11 JUDGE BRENNER: All right. If you can let us 12 know tomorrow or the next day, that would be helpful.
13 And we are hoping we can focus on one document.
O 14 We received the written filings of LILCO and 15 the staff with respect to the question we raised of the 10 cole of Science Applications, Inc., SAI. S taf f 's filing 17 contemplates an openended, unscheduled further filing.
18 Obviously, we cannot leave it at that. We have a 19 schedule in mind, but I will ask the staff first.
20 MR. RAWSON. Judge Brenner, as we indicated in 21 the pleading, we are continuing to investigate and 22 gather facts on this matter. Part of the difficulty is 23 caused by the fact that some of the contacts that both 24 LILCO and we have discussed are in the context of 25 subcontracts under some of the national laboratories.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554 2345
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{} 1 We have f ound that it that is very difficult to try and 2 track down the particulars on.
3 I would anticipate that we could file'our O 4 final report on this by the beginning of next week.
5 JUDGE BRENNER: That would be acceptable. It 6 would be helpful if we could receive it first thing 7 Fonday morning so that the Board can confer and deal 8 with it on Monday.
9 HR. RAWSON: Judge, we will make every 10 attempt. And if we are going to have a prohlem with 11 that, I will let you know by telephone on Friday.
12 JUDGE BRENNER: All right. We won't require 13 it before Tuesday up here, but we would appreciate it i
14 first thing Monday morning in the offices. And you l
l 15 don't have to let us know. If we don't have it, we -
I
! 16 won't have it. .
17 I do have a few concerns regarding the 18 direction the staff has taken in their response. LILCO, 19 to some extent. The staff a little more graphically.
20 Although the staff recognizes that our inquiry was not 21 limited to just an out-and-out legal conflict of 22 interest; that is, whether SAI had worked on Shoreham l
23 for both parties, starting at the bottom of page 2 and
() 24 continuing over to page 3 of the staff's response there 25 is the assertion "At this time and subject to the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5709 staff's further review..." that SAI played no role
(]) 1 2 direct or indirect in the staf f 's analysis of the 3 Shorehsm spplication and certainly was not involved in O-4 the preparation of the staff's testimony for this 5 proceeding.
6 Obviously, we expect a further response not to 7 be limited just to that aspect. We would have been very 8 surprised had we found out differently on those points.
9 However, the key point is not these long lists of to contracts, which I suspect is the thing taking you the 11 most time to gather up. But esther, "We hsved work on f2 the same subject for both parties; that is, systems 13 interactions in nuclear power plants," and that is what O 14 we had hoped to hear more about in this filing, and that 15 is what we want to hear about in the next filing".
18 That is the salient point. We are not -
17 troubled by the fact that you have an organization that 18 may be workina on contracts for the staff and utilities 19 on unrelated matters. But here, there is a prelimina ry 20 indication that the work is on the same type of matter, 21 and the fact that it is not Shoreham per se does not 22 necessarily remove the problem.
23 Particularly coupled with the assertions in
() 24 the testimony that the PRA is fine because it is similar 25 to other PRAs in the industry, and it turns out that SAI O
ALDERSON REPoRilNG COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON. D.C. 20024 (202) 554 2345
5710
() 1 has had their fingers in all of the PFAs, in one form or 2 another, or many of them.
3 The staff also does not directly address the 4 point as to whether we should have been informed. I 5 will not beat a dead horse, but I will just note that 6 the staff does not address that, other than obliquely.
7 MR. RAWSON. Judge Brenner, we intend to 8 add ress that at greater length. As you will see at the 9 bottom of page 3 and 4, we presented some preliminary 10 thinking on that subject.. But naturally, we will have 11 more to say after we have all of the facts completely.
12 I would like to point out that in our response 13 on page 4 there is some discussion of the f act tha t 14 SAI's involvement with the staff's interaction program 15 has been both generic and very preliminary, and that the 16 reports are ongoing. And the staff's decisions as to 17 wha t it will be doing with the information provided by 18 SAI, among others,.has not yet been made. And for that 19 reason, we are an additional step removed, we believe, 20 on the basis of present knowledge, from a possibly 21 conflicting situation. But we will be pursuing that 22 further and letting the Boa rd know.
23 JUDGE BRENNER: Well, I will reiterate that if
() 24 the work was generic, that does not necessarily remove 25 the problem when you are talking about the same area we ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5711
() 1 are focusing on here. And secondly, it has not been 2 limited to generic work. They have done wo rk 3 particularly on Indian Point.
4 In terms of notif ying Board, since the staff 5 is the one link, other than two members of this Board, 6 between this proceeding and Limerick, we would 7 appreciate -- in fact, we will request -- that the 8 staff, presumably through staff's counsel in Limerick, 9 we would appreciate it, Mr. Rawson, if you could pass 10 this ons that you would serve the papers from Shoreham 11 along wi th the pertinent transcript excerpts when those 12 would be, too. Those would be 542828 and the other i 13 would be the brief dialogue I had with Mr. Ellis at.
14 approximately 5420222 and the written filings.
15 It might be convenieht to wait for the staff's 16 further filing and then file the whole thing, pe rha ps 17 along with this transcript or some cover letter 18 indicating that it was our request that it be served in 19 Limerick in the interest of full disclosure for the 20 information of the parties to that proceeding.
21 MR. RAWSON: That is no problem, Judge 22 Brenner. Of course, staff counsel in the Limerick 23 proceeding has been jnvolved in this investigation, and
() 24 ve will see that those matters are all served on all of 25 the parties in Limerick.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5712 JUDGE BRE!!NER: Thank you, we appreciate
(]) 1 2 that. I will leave it to the staff as to what it wants 3 to do with respect to Indian Point and any other 4 proceedings that might be involved.
5 Also, with respect to the same subject, there 6 is a general admittedly preliminary discussion of the 7 staff's contract review procedures being designed to 8 look at possible conflicts and the fact that contractors 9 are required to update information and so on. It would 10 be helpful in that context if the further report 11 disclosed whether or not staff's review was aware of 12 S AI's role f or LILCO and also f or Philrdelphia Electric 13 with respect to their respective applications, in terms 14 of their review. And if there are any written findings 15 or summaries of that Teview, we would appreciate knowing 16 tha t. -
17 MR. RAWSON: I will investigate that as well, 18 Judge Brenner.
19 JUDGE BRENNER: Changing subjects now, unless 20 somebody else has a comment on the previous subject, we 21 received, -- at least I have seen nothing from Suffolk 22 County with respect to a need for any further inquiry of 23 Dr. Lucks, so I assume there is no such need.
() 24 MR. LANPHER: I sent you a letter last week to 25 that effect, Judge Brenner. You must not have received O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
5713 it yet. I apologize. It was mailed on Wednesday night.
({} 1 2 JUDGE BRENNEP: If I received it, I didn't see
- 3 it, but thank you for the information.
4 MR. LANPHEE: That is correct.
5 JUDGE BRENNER: We received from Suffolk 6 County a revised cross examination plan of the staff's 7 panel of witnesses on Contention 7(b), not including the 8 last piece of testimony by Mr. Conran, understandably 9 because they had just received it at the time they filed 10 the plan.
11 The cross examination plan is voluminous, 12 partly because it gives a full indication of what the 13 examination is going to be, so it would be wrong for us 14 to judge relative length of different cross examination 15 plans, and We do not do th a t . However, it is at least a 16 preliminary indication of rather long cross examination.
17 I guess I would like to ask the county if they 1
1 18 have an estimate as to how long that cross would last.
19 Not including whatever additionally you might have on l
20 Mr. Conran, unless you could also give us a separate 21 indication of that.
22 MR. LANPHER: Judge Brenner, I wouldn't judge i
23 the length of cross examination necessarily by the
() 24 length of the plan. You will note I put some things in 25 there just for my own convenience; a great deal of
()
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5714 Ha ving a week, I
{} 1 material for my own convenience.
I would be hopeful 2 thought it maybe would speed it up.
3 --
O 4 JUDGE BRENNER: Yes, I had that in mind in my 5 comments.
6 MR. LANPHER: I would be hopeful that the 7 entire examination would be completed this week.
8 JUDOE BRENNER: Assuming you could start it 9 tomorrow?
. 10 MR. LANPHER: Based upon the assumption that 11 we started tomorrow, or maybe we could even get the 12 testimony in evidence today. I had forgotten the 4:00 13 o ' clock adjournmen t. But hopefully, starting tomorrow 14 morning, yes.
15 -
JUDGE BRENNER: That would be helpful. We 16 were hoping that it could be completed this week, also.
17 And we would like to see that it be completed this 18 week. We would be very unhappy if it goes past the 19 first day of next week.
20 But let's see how it goes. If you have a plan 21 for Mr. Conran's testimony, we would appreciate it. We 22 wouldn't require it until just before you are coing to 23 ase it, because of the time limits. And if you don't
() 24 have one, we will valve the requirement. But it would 25 be helpful if you could do that.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5715
(} 1 (Board conferrinc.)
2 MR. LANPHER: Judge Brenner, I have two short 3 preliminary inquiries. First, to inform the Board that 4 I put another document in your mailbox af ter you lef t, 5 and it is a written response by Suffolk Coanty to 6 LILCO's motions to supplement witness panels; a 7 four paged document. And it is over there and I served 8 it on the other parties.
9 The second thing, I would like to clarify in 10 my own mind the schedule after 7(b). My understanding 11 is we are going to go to 28(a)(1), then to 24, and then 12 back to 31. Is that a correct understanding? I know it 13 is complicated,by Judge Carpenter's schedule, but 14 someone else is handling 31, snd I just wanted to have 15 the best understanding possible, understanding that, 16 again, we may have to change it.
17 JUDGE BRENNER: You said it correctly.
18 MR. LANPHER: Thank you.
19 JUDGE BRENNERs And in another week or so, I 20 guess we would appreciate the parties informing us of 21 confirming the schedule previously announced with the 22 adjustments you just indicated, and informing us of the 23 schedule for the contentions through the last ones that
() 24 have been filed now. I know we are going to do some 25 switching so that the SRV matters are taken up together ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5716 1 or in sequence and that type of thing, so if you could
[}
2 inform us.af that, I guess, by the beginning of next 3 week it would be helpful. Subject to some adjustments, O 4 depending upon where we go.
5 MR. EARLEY: Judge, as long as we are on 6 scheduling, a couple of matters that we would like to 7 brino up. I gather from the county's comments on the 8 length of the cross examination of 7(b), that it is ,
9 their estimate we won't reach 28(a)(1) this week.
10 We are interested because we have some General 11 Electric witnesses from San Jose who would have to come 12 East and it would be inconvenient for them to come just 13 to sit and then have to come back again next week.
( 14 JUD2E BRENNER: I think we are going to be 15 lucky to get in any questions LILCO might have of the
. 16 staff's witnesses, plus any redirect, let alone get to 17 the other contenti~on. That is my own opinion. Perhaps 18 Mr. Lanpher would like to address that.
19 MR. LANPHER: We are in the same boat as LILCO 20 in tetas of a witness who is in San Jose who is 21 sponsoring 28(a)(1) testimony, Mr. Bridenbaugh. And so, 22 I don't think we will get to 28(a)(1) this week, 23 particularly given the earlier adjournment on Friday,
() 24 also.
25 MR. EARLEY: I think from our standpoint, we O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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{} 1 need to make a decision, say, by early Wednesday.
2 MR. LANPHER: You had be'tter make it now. I 3 don 't thin < it can help by early Wednesday.
O 4 JUDGE BRENNERs I think you will be pretty 5 safe not bringing them down. That is my opinion, but 6 you will be able to take another look at it tomorrow 7 morning.
8 MR. EARLEY: The other question on scheduling 9 comes up with 7(b). We have our PRA witnesses here. We 10 would very much like to have them available while the 11 staff witnesses discuss PRA, and it would be most 12 convenient if in doing the staff's testimony, we handle
,13 any aspects of PRA and systems interaction first for'the 14 staff.
15 JUDGE BRENNER Until you added the last term 16 you were okay. Systems interactions is going to 17 permeate everybody's questions.
18 MR. EARLEY: Well, I guess systess interaction 19 as it relates to PRA.
20 JUDGE BRENNER: Well, that sounds like a 21 reasonable request to me. I think the parties could 22 have discussed that off the record, if you haven't l
23 already. Why don't you do that?
() 24 MR. EARLEYs Well, we have raised the point 25 with the county.
O ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASH;NGTON, D.C. 20024 (202) 554 2345
5718 1 JUDGE BRENNER: Mr. Lanpher?
2 MR. LANPHEP Well, they did raise it two 3 weeks ago or a week and a half ago, whenever we were O 4 last here together, and I will be honest. I had 5 forgotten about that request, and so I am reminded this 6 morning and will have to go back and look a t my 7 materials. And I will do everything possible to 8 accommodate that. But let me just look at my. materials.
9 JUDGE BRENNER4 I think, as I recall your 10 cross plan, you do have a segment or two that you can 11 focus on first. One is pure PRA, if you will, and the 12 other is the transition. And if you could focus on 13 those first, I think that would be good. We won't 14 preclude you from any questions that touch on PRA 15 thereafter, but the idea would be a good faith attempt 16 to get as much as possible up front.
17 (Board conferring.)
18 19 20 21 22 23 O 24 .
25 O
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{) 1 JUDGE BRENNER4 '4e are ready to continue with the litigatien of this contention, and we left in the 2
3 middle of the County's cross examination of LILCO's O 4 panel with respect to the FRA aspect of Contention 7B.
5 Whereupon, ,
6 V0 GIN J0KSIMOVICH, 7 EDWARD T. BURNS and 8 ROBERT M. KASCSAK, 9 called as witnesses by counsel for Long Island Lighting to Company, having been sworn previously, resumed the stand 11 and were examined and testified further as follows:
12 CROSS EXAMINATION -- Resumed 13 BY MS. LETSCHE:
l O
\/ Mr. Burns, in the construction of f ault trees 14 0 15 and event trees that were done in connection with the 16 Shoreham PRA, did the modeling of instrumentation and 17 control systems include location-dependent common mode 18 failures?
19 A (WITNESS BURNS) There are a number of aspects 20 to that problem. The instrumentation that measures, 21 that senses several of the important parameters in the 22 reactor is either located on the primary system or 23 nearby inside containment. Some of the cables then
() 24 penetrate the primary containment and many of the ,
25 electrical cabinets are in the reactor building and some O
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W,. WASHINGTON D.C. 20024 (202) 554 2345
5720
(~ 1 of the power sources are then in the control building.
2 So there see several locations that are important for 3 the instrumentation to operate correctly.
O 4 The items that are considered important or 5 were considered in the PRA as potential common cause 6 failures for the instrumentation included adverse 7 environment in th e resctor building and adverse 8 environment in the drywell inside containment. So frca 9 that standpont the spatial -- the loca tion of the 10 instrumentation and the necessary components within what 11 I would call the block as instrumentation were treated 12 in a spstill sense.
13 Some spstial interactions were not included, 14 as the PRA notes. Not all spatial interactions are 15 included. Pipe whip, for example, was not explictly 16 included in the PRA, and there is a determininstic 17 evaluation that vss done by Stone and Webster for LILCO 18 that did treat that problem separately.
19 0 Were there other spatial interctions that were 20 explictly excluded? You said like a pipe whip, you just 21 mentioned.
22 A (WITNESS BURNS) I guess the other major one i
23 that I would include in that group would be fire. We l
() 24 did include the potential human coupling between 25 instrumentation interactions or common cause failures O
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
r 5721 tha t could lead to failure of multiple trains of
{) I instrumentation.
2 3 0 Could you explain what you mean by that? You O 4 considered the human coupling? Could you just explain 5 your last answer s little more? I didn't understand it.
6 A (WITNESS BURNS) As we have talked about in 7 the testimony and in the PRA itself, there are several 8 potential ca tegories of systems interactions that can 9 occur, functional, spa tial, hunan, and then there are 10 some other divisions that the PBA guide uses as a way of 11 easily identifying types of interactions, and I just 12 referred to an example of how we included human 13 interactions in addressing potential multiple failures 14 of instrumentation that may be used in safety system 15 initiation or operator information systems, and that was 16 done by assessing a potential common mode failure either 17 due to miscalibration or maintenance error in the 18 maintenance of instrumentation of a similar type, 19 pressure sensors, level sensors, all of the same type.
20 (Counsel for Suffolk County conferring.]
21 A (WITNESS BURNS) We did try to ' outline some of 22 those in the testimony, Attachment Table 3.1. There is 23 an outline of what dependencies we did include in the
() 24 event tree / fault tree analysis th,a t could b e considered 25 systems intersction or that are systems interactions and O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5722 I tried to outline by type functional, spatial and human,
)
2 what those were and where they were located in the PRA.
3 O 4 (Counsel for Suffolk County conferring.]
5 JUDGE JORDANS Excuse me. Did you say Table 6 3.1?
7 WITNESS BURNS: Yes, sir, Table 3.1 of the 8 testimony, which is in --
9 JUDGE JORDAN: Is that in the attachment?
10 WITNESS BURNSs That is the attachment, 11 section -- it is Tab 6.
12 JUDGE JORDANS Oh , yes, Tab 6, I'm sorry.
13 BY MS. LETSCHE: (Resuming)
() 14 Q Mr. Burns, did your methodology include a 15 consideration or an evaluation of diverse 16 instrumentation signals to one system?
17 A (WITNESS BURNS) I'm not sure I could answer.
18 You have to help me out a little bit. I'm not sure 19 where, what specific question you are asking.
20 0 I'm talking about a situation where there 21 would be more than one signal, instrumentation signal 22 indicating the condition of a particular system. l 23 (Counsel for Suffolk County conf e rring. ]
() 24 Maybe rsther t,han an indication of a system, 25 an indication of a particular parameter, more than one O
ALDERSON REPORTING COMPANY,iNC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5723 1 instrumentation indicating a parameter.
2 JUDGE JORDAN: Are you thinking of possible 3 conflicting information that the operator might receive?
O 4 MS. LEISCHE: Yes, or the lack of a dual 5 indication, a diverse instrumentation.
6 JUDGE JORD AN : All right.
7 WITNESS BURNS 4 We tried to consider all of 8 .the instrumentation that the operator had available to 9 him for the initiation signal for all of the safety 10 systems. Is there a specific system or parameter that 11 you are interested in? Maybe that will help focus the 12 discussion.
13 (Counsel for Suffolk County conferring.] ,
14 BY MS. LETSCHEa (Resuming) 15 0 One example would be indications of reactor 16 power level.
17 (Pause.]
18 A (WITNESS BURNS) At this moment I can't think 19 of any itens that we considered in the PR A other than 20 the PRMs that would lead to reactor scram on demand to 21 give us power level. So the power range sonitors which 22 they use for both scram signals and for ietermination of 23 potential ATWS conditions for the power range monitors.
O 24 o Mr. Burns, did your ana1ysis =ensider -- end 25 we are talking about the reactor power level here --
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
5724 consider the fact that there was only this one
{) 1 instrumentation that you mentioned to provide 2
3 information on that to the operator?
/~T U 4 A (WITNESS BURNS) The only direct indication 5 would be from that or to the automatic systems.
6 However, t h e re sra indirect indica tions of the ef fects 7 of high power level under certain conditions that could 8 lead to either trips in the system, an initiation of 9 safety systems, so there are other instrumentation that 10 comes into play beyond what one might consider Chapter 11 15 accident evalustions.
12 3o there are, in fact, other instrumentation 13 in the reactor systems that can provide protective .
14 functions to the reactor and to the initiation of safety 15 systems other than just the power rance monitors.
16 Q I understand tha t. My question was did your 17 analysis, your fault tree and event tree analysis take 18 into account -- you said before, unless I misunderstood 19 you, that in terms of reactor power level, the only 20 thing you considered were the power range monitors as 21 providing inf orma tion to the opera tors. Maybe I 22 misunderstood you. My question was did your analysis 23 include any consideration of the fact that that was the only instrumentation that you are considering or the
(]) 24 25 fact that there migh t be other indications to an O
ALDERSON REPORTING COMPANY,INC, 400 VIRGtNIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5725 1 operator that would conflict with what the power range
)
2 monitors told him or confirm it?
3 MR. ELLIS I'm sorry, but I'm not sure how O 4 many questions there were in there. For my own purposes 5 I ha ve to register an objection because I didn't 6 understand the question. If the witness esn answer the 7 question, I have no objection.
. 8 JUDGE BRENNER: Well, as you recognized in 9 your objection, ce normally discourage that type of 10 objection, but I had trouble following that one, too, as 11 a subjective criteria, and perhaps you could put it 12 together again, Ms. Letsche.
13 BY MS. LETSCHEs (Resuming) .
14 0 Mr. Burns, did the f ault tree and event tree 15 analysis that you did with respect to reactor power 16 level take into account the fact that there might be 17 indications of that parameter to the operator other than 18 those afforded by the power range monitors?
19 [ Panel of witnesses conferring.]
20 A (WITNESS BURNS) Now I'm conf used. We didn't 21 do a' fault tree / event tree analysis of the reactor power 22 level. The reactor power level is one important 23 parameter that is monitored, and it does establish the
() ,24 initial conditions for many accidents, and there are a 25 number of parameters available to the operator to ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5726 l 2 a
w establish what his power level is beyond just the power Q 1
,,-7, 2 range monitors. But we did not do a fault tree analysiv 3 of the power level of the reactor. >
0 4 [ Counsel f or Suf folk County conferring. ]
'" ., a
_l
-d'
, . ' fi -
5 0 The reactor power level is an item'of input.,,o, _
./
.#. y 6 into the fault tree and event treesit,haf. you did
/
N ' ,j 7 construct; correct? ,
'/
/
8 A (WITNESS BURNS) Yes. ' --
9 Q
./
I guess my question is.411' the input rela ted
.- d .l .
~~
10 to that parameter take into account'the possib lity of a 11 different instrumentation available to the operator to 12 tell him that information? -
13 A (WITNESS BU.53). Yes. ~
'e, ,
O' 14 0 How did it do tha[t? ,
, . v >! ,a 15 A (WITNESS BURNS) Well, in IGist cf the analysis A
- < ,s 16 tha t we are doing, we are carrying this to .th'e ulti$ ate < ~ ,
, , j 17 capability of the plant to. rea'cE ?,
.t'o' certain c"ond itions
- -c.
e 18 and within that context the ini'tial. power that the pla n,t "
- a; e-19 is at can vary by sone P. mount, let's say 10 to 15s
./ i
/
20 percent, without affecting the results of eitherfthe ,
3 21 accident consequence,'soerce terms, or the pr ,babilities d '-~-
22 of gettina to those source terms... - .
23 So, in much op the PRA,'the' initial power d'
. 24 level is assumed to be within 10 to 5 percent of its' .
25 nominal value as recorded on the power range monitocs s .
j
- 7. .
, / , f .!
- l
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ALDERSoN REPORTING COMPANY,INC,
- s 400 VIRGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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5727 a 7 o,
9 * * *
. ,. t m .s 1 and as co71tirmed by"the other methods that the opera tor 2 has available to him.
3 ~
This is similar to the approach taken in O , 4 WASH-14IO and in the IREP studies that I have seen. The 5 exception to ttat would be when we are trying to 6 determine the scrsm reliab ility .
We have done a fault 7 tree' enalyils otV the scram system in order to isolate y .; ,jy , .-
_. [' ' .
< thos/F'ptotective f unctions that could be initiated by G
, , f.-
, ,;,e s
F- // 9 ,several' instruments under transient demands. But that
' +
, , l .
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10 is not the determination of steady state power, that is
, ' ,e ; >
,, i ; .:.
. . ; /. ,, > ' ,11 a transient, What perception the scram system has of
.. / , . . , ,
/ ~~7' . ,' j.
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12 wha t', p s rameters a re in the reactor and whether a trip r
\
f 13 'should, be initia ted. . .
_ 14 0 -In your analysis of systems interaction and 15 p a r ticu l.a rly of human interactions, that su bset , did you s , 3 -
f
, ' ,/ g 16' ' take intb account yhat an operator might do if he
? / ,.
,'/ 17 received :onflicti'ng information with respect to one 18 pa ra m e te,r? ,
( 19 A (WITNESS BURNS) Yes, we ha ve .
K,
_.~0 And how did you do that?
- 20 <
, . . s.
21 , il , (WITNCSS BURNS) We tried to make use of the 7, ,
22 Swain,Fevaluation of operator interface with the system 23 under O ressf ul conditions and designed operator action O 24 presed111 ties essociated wi th th e t per his handsoox.
25 JUDGE BRENNER: Dr. Burns, was that the Los ALDERSON REPORTING COMPANY, INC, 400 VIRG NIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5728
{) 1 Alamos study? I am trying to remember who Swain is.
2 . WITNESS BURNS: It was the Sandia report. It
, 3 is a NUREG report also, 1280, I believe.
O 4 BY MS. LEISCHE: [ Resuming]
5 0 Does that study that you referenced concern a 6 situation where there are conflicting reports available 7 to the operator, or is it in f act limited to what he 8 might do under a stressful situation?
9 A (WITNESS BURNS) The Swain handbook outlines 10 what he would do ander stressful conditions and under
. , . 11 condi.tions were he has conflicting information.
12 [ Counsel for Suffolk County conferring.]
13 Q Dr. Burns, would the value that you come up
) 14 with using the Swain 's handbook be reduced if the 15 operator had available to him a diverse instrumentation i
16 to confirm a particular parameter?
17 A (WITNESS BURNS) If he has multiple 18 indications of the same parameter, if that is going from i
is a single indication of a parameter to multiple 20 indications, then yes, the conditional probability of l
21 the operator successfully performing the correct action 22 would improve when we have multiple indications.
23 JUDGE M3RRIS: Dr. Burns, do you have a litte
() 24 trouble answering that question wi th out specif ying other 25 groundrules and boundary conditions?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5729 1 'JITNESS BURNS 4 Yes, sir. That is what in
/)
2 general his performance of a ta sk would be improved if
_ 3 he had multiple diverse indications of the same V 4 parameter, but yes, sir, the maanitude of the 5 improvement and possibly even if it was improved could 6 change based on what parameter we were talkins about and 7 based upon what other indications would be available to 8 him that could be conflicting.
9 BY MS. LETSCHE (Resuming) 10 0 Dr. Burns, we talked a little about on Friday 11 about the walkdowns that were performed in connection 12 with the Shoreham PRA. I would like to direct your 13 attention to page 102 of your prefiled testimony, and 14 particularly the portion there which discusses the 15 amount of time that was spent in connection with these 16 walkdowns.
17 In the la st full sentence on page 102 it 18 states, "This should be coupled wi th the preparation l
19 time of 15 man days and a report writing time of 10 man 20 days." And this is a discussion of the scope of the 21 valkdown.
22 Can you explain f or me who the people are who 23 were involved in the 15 man days and 10 man days that
() 24 are stated in that portion of your testimony?
25 JUDGE BRENNER: Ms. letsche, there has been a O
ALDERSON REPORTING COMPANY,lHC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5730 1 break of over a week and I don ' t have the transcript in
[}
2 front of me, but wasn't that asked and answered.
3 MS. LETSCHE: Judge Brenner, I don't believe O 4 it was. I did ask about the total number of man days 5 and whether or not that included LILCO employees. I 6 don't have the trsnscript here either, but as I recall 7 from my notes, that was the question I asked.
8 JUDGE BRENNER: I thought we went through 9 quite a few questions as to who was on the trip. Mr. .
10 Kascsak didn't like th e term " tour guide" and so on and 11 so forth. What is left to find out about this?
12 MS. LETSCHE: Judge Brenner, I think what I am 13 trying to do is to find out in a little more detail how 14 the systems which were reviewed as stated in the PRA 15 were broken down timewise, and the other time that is 16 referenced in his testimony, report writing time, who in 17 fact did that, if that included the LILCO employees, if l
18 it included all of the fault tree analysts. I am just 19 looking for a total of all of the walkdowns and all of 20 the days. In reviewing the transcript, I felt that 21 there was not sufficient detail, and I probably should 22 have gone into it on Friday but I didn't.
23 JUDGE BRENNER: Okay, but it presumably would
() 24 be just foundation for where you are headed with that 25 proposition, so let's see if we can get through this l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5731 f'N 1 part quickly as to who participated in what and how long V
2 it took?
g- 3 MS. LETSCHE Tha t's fine. I don ' t intend
\s 4 this to be extensive a t all.
5 JUDGE BRENNER: Perha ps due to my interruption 6 you should repeat the question f or the witn ess.
7 BY MS. LETSCHEa (Resuming) 8 Q Dr. Burns, the reference to the preparation 9 time of 15 man days in your prefiled testimony,.can you 10 tell me who was involved in putting in that time?
11 A (WITNESS BURNS) That was principally myself.
12 However, the people who did the other individual system 13 walkdowns also had to prepare by reading the system 14 description and FSAR sections and reviewed their fault 15 trees that they had prepared up to that point, their 16 draf t f ault trees. And so each of the people who are 17 cited as walking down individual systems also 18 par ticipated in tha t, and similarly with the report or 19 the summary of the checklist that was written subsequent 20 to the walkdowns.
21 0 That is what the report writing is referred 22 to, the summary of the checklist?
23 A (WITNESS BURNS) Just the sucimary of the
() 24 checklist and how we were going to incorporate that 25 information into the draft fault trees.
l (2) o ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
5732
(} 1 0 And so the 10 man days reference for report 2 writing time is the total of time put in by all of the 3 SAI fault tree analysts involved in the walkdowns?
4 A ( WITNESS BURNS) Yes.
5 0 These amounts, preparation and report writing 6 time, they are the total devoted for both of the 7 walkdowns that you referenced; is that right?
8 A (WITNESS BURNS) I would have to go add up my 9 numbers again, but I believe that is true, yes.
10 0 How were the particular systems reviewed by 11 the particular analysts set 'out in Section 2.4 of the 12 PRA determined?
13 A (WITNESS BURNS) I'm sorry?
O' 14 0 My question is was there a particular reason 15 why one analyst was given particular systems to review I
16 as opposed to others?
17 A (WITNESS BURNS) The people who did the fault
(
18 trees were the people who walked the system down.
19 0 Did the assignment of who did which fault 20 trees, was tha t related to particular qualifications of 21 the analysis?
22 A (WITNESS Bt 'S ) Yes, it was.
23 0 In the total of four days that you reference
) 24 in the walkdowns, that is, two walkdowns each requiring 25 two days, it was during that time that all of the O
V ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W , WASHINGTON, D.C. 20024 (202) 554 2345
l 5733 l
l ~T 1 systems listed in Table 2.4.1 were walked down; is that (V
2 correct?
g- 3 A (WITNESS BURNS) Yes, tha t 's true.
() 3n Friday, Dr. Burns, we were discussing what 4 0 5 was marked as Suffolk County Exhibit 23 for 6 identification, which contained a table on uncertainties 7 and a table of frequencies of core vulnerable conditions 8 by accident class. Do you have that exhibit handy? It 9 is made up of pages 3-172 and 4-3 of the Shoreham PR A.
10 A (WITNESS BURNS) Yes, I do have that.
11 Q I would like to direct your attention tc Table 12 4.1 of that exhibit. I wonder if you could give us a 13 general description of the meaning of the classes that 14 are listed there, Class 1, 2, 3, 4 and 5.
15 NR. ELLIS: My recollection, Judge Brenner, is -
16 that we are now plowing old ground again, and I am going 17 to object on that basis.
18 JUDGE BRENNER: We have been over this table 19 before with respect to what it meant and the mean 20 estimates and so on, but I don't know if this question 21 is different or not. Do you want to address that?
4 22 MS. LETSCHE: Yes, Judge Brenner, I believe it 23 is. We did discuss last Friday the meanings of the
() 24 left-hand column, the generalized class descriptions 25 that are stated there. I did not ask, as I recall, for O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5734 1 a description of what the actual classes were. I think 2 Dr. Burns did describe why the things stated in the 3 left-hand column, what they mean t, but I would like a 4 general description of what these classes are.
5 MR. ELLIS: Judge Brenner, on page 5689, 6 question by Ms. Letsche, "Can you explain, give us a 7 general explanation of what is in Class 1 of that 8 table?" There follows a lengthy answer. It includes 9 Class 2 and so forth, Class 5 and the rest of it.
10 [ Pause.]
11 [ Board conferring.]
12 MS. LETSCHE: Judge Brenner, I don't have a .
13 copy of the transcript.
14 JUDGE BRENNER: Well, maybe I can cut this 15 short. I am going to let you ask the question. It 16 would certainly have been more efficient to ask it right 17 in that same context, and it is going to the same 18 general point, that is, the division of classes, as the 19 transcript reference pointed out by Mr. Ellis confirms, 20 and I glanced at the transcript to agree with his 21 cha ra c te riza tion . But you didn't ask it particularly in 22 terms of how the classes were defined by the frequency 23 of core vulnerability numbers, although you asked other 24 questions aboue the numbers, I recall, although not in 25 that part of the transcript going towards the graphic O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA .'.VE., S.W., W AS.ilNGTON, D.C. 20024 (202) 554 2345
5735
(} 1 description, if you will, of the classes. So I will let 2 you ask it, but I hope the fact that we are allowing the
- 3 question doesn't go back over entirely the same ground.
4 MS. LETSCHE: Thank you, Judge Brenner.
5 MR. ELLIS: What is the question, now?
6 BY MS. LETSCHE: [ Resuming]
7 0 Dr. Burns, can you give us a general 8 description of the meanings of the Classes 1 through 5 9 tha t are accident classes that are listed in Table 4.1?
10 MR. ELLISs Judge, I would at least like to 11 have the witness have in front of him 5689 to 90 where 12 he describes what the meaning of those classes are, each 13 one of them, seriatim.
14 JUDGE BRENNERa Well, why don't you give it to 15 him then? -
16 - WITNESS BURNS: I have it. You wanted the 17 meaning of each class or the reason why there were 18 different classes?
19 BY MS. LETSCHE (Resumino):
- 20 0 The definition of what the classes are.
21 JUDGE BRENNER: Wait a second. D r. Burns, 22 hold on a second. Maybe I only caught a fragment, but 23 that is not the question you asked that I allowed the
() 24 answer to. The question you just asked would have been 25 denied because that was asked and answered. Wh y don 't O
ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5736 1 you start wi th your original question as te -- and I 2 don't recall it exactly either, but it is as to hcw are 3 the classes defined with respect to the numbers in the 4 right-hand column. Is there some mean that is 5 represented there? Where do you draw the line between 6 the classes based upon the numbers of frequency of -- it 7 says core vulnerable, and I assume it is core 8 vulnerability.
9 . JUDGE MORRIS: Dr. Burns, let me ask a 10 clarifying question first. Of what significance are the 1
11 Roman numerals I through V?
12 WITNESS BURNS: Those are just artifices that 13 ve use to identify in shorthand what the general classes .
14 are, and they have no significance in and of themselves.
15 -
16 '
i 17 18 i
19 l
20 i.
21 22 ,
23 24 25 r
O l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
I 5737 JUDGE MORRIS: Thank you.
(]} 1 2 JUDGE BRENNER: You did not ask about those 3 numbers, did you?
4 MS. LETSCHE: I did.
5 JUDGE BRENNER: I guess I missed it. I t
l 6 thought you were talking about the last column.
l
! 7 MS. LETSCHE: No, I was talking about the 8 middle column.
9 JUDGE BRENNER: Well, you got your answer Let .
10 me pursue something.
11 Dr. Burns, this is an excerpt from the draft 12 PRA for Shoreham, page 4-3, particularly. Are there 13 pages before or after or around this that would have
('N explained these charts and the use of the numbers 14 15 similar to the questions you were asked last time and 16 today?
17 (Panel of witnesses conferring.)
18 I am going to ask the county the same question 19 at the same time, to find out if there was a*way to be 20 more efficient. Either one can answer first.
21 MS. LETSCHE: Judge Brenner, as you probably 22 know, the Shoreham PRA is a voluminous document, and 23 when you combine it with the appendices -- . My
() 24 intention in using the summary tables that are provided 25 in there was to eliminate having to go through all of O
ALDERSOr4 REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l 5738 1 the detail that is in the PFA. And my questions for Dr.
{)
2 Burns were not intended to be an inquiry into extensiva 3 detail.
O 4 JUDGE BRENNER: That is not my question. My 5 question is more limited, and maybe I can help you by e f ollo win g up.
7 Is there a reasonably concise section or part 8 of a section that explains this chart, in the context of
. 9 the questions you have been asking about Table 4.1? .And to if so, we can cet that in more efficiently. If not, 11 that will be the answer. Dr. Burns, can you shed some 12 light on that? .
13 WITNESS BURNS 4 Section 4 ci the report refers 14 to other sections to define key parts of these tables.
15 For example, in the description of Table 4.1, it does 16 refer to Appendix C which defines precisely what each of 17 the classes are. But they are not discussed in the 18 section 4, the summary.
19 JUDGE BRENNER: Is the re'ference to Appendix C 20 a reasonably concise discussion, or at least the 21 portions pertinent, to explain Table 4.17 22 WITNESS EURNS: In terms of description of 23 wha t the classes are, yes, sir.
() 24 JUDGE BRENNERs Ms. Letsche, were you aware of 25 that?j O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S W., WASHINGTON, D.C. 20024 (202) 554 2345
5739 MS. LETSCHE4 Yes, Judge Brenner, I have
(]) 1 2 looked over Appendix C. Frankly, as I stated, in order 3 to keep the record of this proceeding a little less 4 voluminous, I was hoping we could get a summary 5 description from this witness who prepared the document, 6 rather than have to have marked as exhibits huge 7 portions, or read into the record huge portions of those 8 explanations.
9 JUDGE BRENNER: Well, you keep going back to 10 huge portions, and the answer I just got is that it is a 11 concise portion. And unfortunately, it just has not 12 been very efficient because we had some questions a week 13 and a half ago, and now, although the questions might be O 14 distinguishable, we are coming back to the area again.
15 And I want to shortan it up somehow. How much more do 16 you have on the table if we restrict it to oral 17 questions, Ms. Letsche?
18 MS. LETSCHEs Judge Brenner, I do not have any 19 further extensive questions right now on this table.
20 JUDGE BRENNER: Okay. I will allow you to 21 proceed on that bssis. Over lunch, I would like either I
22 -- well, any party to consider whether or not the 23 further explanation of this table should also be ma rked A
(_) 24 either for identification or put into evidence, since we 25 have had questions about the table. For now, we will O
ALDERSCN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, n.C. 20024 (202) 554 2345
5740 f) 1 proceed with the questions.
v 2 (Counsel for Suffolk County conferring.)
3 JUDGE JORDAN 4 May I just ask one question ?
4 Dr. Burns, are these classes associated with the release 5 cla sses such as we had in WASH-14007 6 WITNESS BURNS: WASH-1400 called them release 7 Categories and we tried to use a dif f e rent name, and 8 admittedly, it is confusing. But these are essentially 9 subsets or classes tha t f eed in to ,those ca tegories. The to WASH-1400 analysis assigned one class to represent all 11 accidents, where we have five. And then they fed that 12 one class into containment failure modes of different 13 types, and we feed five classes into all containment O 14 failure modes.
15 JUDGE 33RDAN: I see. Okay.
16 BY MS. LETSCHE (Resuming) 4 17 0 Just so I understand, Dr. Burns, the classes 18 are related to the amount or the extent of the release?
19 Is that right? -
20 A (WITNESS BURNS) We tried to identify those 21 Seluences that were closely coupled in both frequency 22 and effects on containment, which included potential 23 radionuclide source term from those sequences.
( 24 0 Thank you. Dr. Burns, in performing the 25 Shoreham PRA, did you compa re the me thodologies used in
()
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
~
5741 C 1 the Shoreham PRA to those used in the WASH-1400?
2 A (WITNESS BURNS) We certainly compared it in 3 performing the analysis. I am not sure if there is a 4 w ri te-u p anywhere that summarizes all of the comparisons.
5 0 Did you also compare the results of the 6 Shoreham PBA to the results of WASH-1400?
2 7 A (WITNESS BURNS) The results as far as we have 8 carried them, Phase 1 and Phase 2.
9 MS. LETSCHE: I would like to have marked as 10 Suffolk County Exhibit, I believe it is number 24 for 11 identification a document which is page 3-150 of the
- 12. Shoreham PRA, on which is a figure 3.6.6 entitled 13 " Comparison of the Contributing Accident Sequences to -
14 the Calculated Frequency of Core Melt f rom WASH-1400 and 15 of the Shoreham Analysis."
16 (The document referred to 17 was marked Suffolk County 18 Exhibit No. 24 for 19 identification.)
20 MS. LETSCHEa I believe the Board has already 21 been provided with copies of this document.
22 JUDGE BRENNER: Yes. We have it. At least, 23 ve had it at one time. Some of us have it now, but it O 24 111 he so merxed for identifi=stion- Do the itneeses 25 have it?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINfA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5742 Q 1 WITNESS BURNS: Yes.
2 BY MS. LETSCHE (Resuming):
3 0 Dr. Burns, does that figure that is contained 4 on Suffolk County Exhibit 24 depict the comparison of 5 the contributing accident sequences at Shoreham to those 6 derived from WASH-1400?
7 JUDGE BRENNER: Off the record. In fact, we 8 are going to be off the record, even though you are on 9 the record. We.were going to adjourn close to noon for 10 lunch in sny event, and we will adjourn at this time.
11 So let's recess now and come back at 1:00 o ' clock .
. 12 (Whereupon, at 11:50 a.m., the hearing in the 13 above-entitled matter recessed for lunch, to reccrnvene 14 at 1:00 p.ti. the same day.)
15 16 17 18 19
- 20 21 22 23 24 25 O
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.. . l
5743 AFTERNOON SESSION
(]) 1 2 [1:001 l
. 3 JUDGE BRENNER: We are ready to proceed.
)
4 Whereupon, 5 V0 GIN J0KSIMOVICH, 6 EDWARD T. BURNS and !
7 ROBERT M. KASCSAK, 8 the witnesses on the stand at the time of recess, 9 resumed the stand and testified further as follows:
10 CROSS EXAMINATION -- Resumed 11 MS. LETSCHEa Could we have the question read 12 back from the end of the morning?
13 [The Reporter read the record as requested.1 14 WITNESS BURNS: This figure'is described in 15 the text of the P9A and it describes what is meant by 16 this comparison, and I would hate to take it out of 17 context to what it was intended to mean. WASH-1400 did 18 an evaluation of a BWR and determined that the sequences
~
19 tha t are depicted here were the dominant contributors to 20 what they callei : ore melt frequency. In the Shoreham 21 analysis, using a similar set of assumptions in terms of 22 the ability to recover systems subsequent to a degraded 23 core condition, the sequences that are depicted in what
() 24 is referred to as Shoreham here are the dominant 25 contributors to what is referred to in the Shoreham PRA Ci l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5744 1 as core vulnerable condition.
/}
2 And speaking very generally f rom a comparative 3 standpoint the assumptions used in generating these two O 4 were roughly conparable, so we can compare these, but we 5 must recognize that the way WASH-1400 interpreted these 6 events, it was to lead directly to core melt, whereas in 7 the Shorehsm PRA these events lead to a state which is 8 called core vulnerable in which there may be subsequent 9 recovery. In other words, there may be cases subsequent 10 to this point in time where adequate core cooling can be 11 ensured, and that was conservatively neglected in 12 WASH-1400.
13 BY MS. LETSCHE. [ Resuming)
() 14 0 What was the purpose of your comparing th e 15 WASH-1400 results to the Shoreham PRA results?
16 A (WITNESS BURNS) Well, when you go through an 17 analysis as extensive and involved as a PRA, you need to 18 benchmark for your own purposes and for'the purposes of 19 people who need to review it at key places in the i
20 analysis where your results compare with other people 21 who have done similar problems, and this particular 22 comparison represanted a useful point of comparison.
23 What it shows, I believe, is that while the makeup of potential sequences that may lead to core melt
(]) 24 25 is different than that in WASH-1400 -- and this is not O
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{} 1 particularly a reflection of Shoreham but more of an 2 evolution in the thinking of accident sequences -- it 3 compared what are the dominant sequences that may lead O 4 to a core vulnersble state as interpreted by WASH-1400 5 and as found in the Shoreham analysis.
6 The other thing that one would like to do is 7 to then compare this to a safety goal. In other words, 8 this comparison is presented in lieu of the fact tha t we
. 9 do not have a safety goal. There are some discussions to as to what the safety goal should be, but if I had a 11 safety goal, I would put that in here also.
12 In addition to that, I think that footnote 13 that is on the figure is important to note in that
) 14 subsequent to WASH-1400, the NRC staff reevaluated 15 accident sequences for BWRs and determined that ATWS 16 could in fact be s larger contributor than had been 17 evaluated at Peach Bottom for WASH-1400, 18 So, in order to get a risk reduction, I guess, 19 from what WASH-1400 as later interpreted by the NRC 20 staff would be, one would have to incorporate this 21 footnote into the diagram to determine how changes at 22 Shoreham regarding ATWAS have led to risk reduction 23 relative to the NRC staff's position.
() 24 (Counsel for Suffolk County conferring.]
25 0 Dr. Burns, can you explain the reason for the O
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{} 1 difference in the size of these pie charts between 2 WASH-1400 and Shoreham on this Figure 3.6.6?
I 3 A (WITNESS BURNS) This is just an aid that I O 4 tried to use. The area of the pie charts is proportional 5 to the frequency of core melt or core vulnerable, and 6 therefore there is a direct corr, elation between the size 7 and the calculated frequency. The fact that sequences 8 do not show up in the WASH-1400 analysis, I think, as I 9* said before, is more of a result of an evolution of to thinking of what is important in accident sequences, and 11 additional data that has been available since WASH-1400 12 and additional containment analysis that has been 13 performed subsequent to WASH-1400 on these specific
() 14 sequences.
15 Q Is that evolution in the thinking that youd 16 described the only reason for the difference in 17 proportionate size for the TQUV event on the two charts?
18 A (WITNESS BURNS) Well, it is a little 19 difficult to compare exactly what WASH-1400 did and did 20 not include in their analysis because everything is not 21 explicitly stated in that report. My interpretation of 22 what WASH-1400 did is that several sequences were not 23 calcula ted correctly, that there were some sequences
() 24 that were underestimated in terms of how the plant did 25 respond during certain transient initiators, O
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5747 r" 1 specifically MSIV closure events, and we have to be a L))
2 little caref ul here because WASH-1400 did not have the 3 amount of data that we have today, so their estimates of O' 4 the frequency of challenges to the pluat, their 5 perception of those challenges was probably not as good 6 as it is today because ve have a substantial amount of 7 data to indicate that MSIV closures may be more frequent 8 than possibly they had anticipated.
9 So if you actually use the data and you follow 10 the t ra n sie n t through its potential numerous sequences, 11 the calculated frequency of challenge to the core was 12 more than they had o riginally calculated. That is 13 basically my interpretation of the comparison, although
() 14 it is a little difficult to do that because it is not 15 summarized in WASH-1400 all of the assumptions that they 16 used.
17 A (WITNESS JOKSIMOVICH) If I may j ust add, when 18 we are talking about a comparison of WASH-1400 versus 19 any other study, we are talking about a comparison of a 20 d o: ume n t which is seven years old versus a study which 21 was done recently, and we have matured a great deal in 22 the last seven years, we have changed secretaries of 23 state, and the process is just not amenable to a
() 24 simplistic comparison.
25 JUDGE BRENNER: Dr. Burns or Dr. Joksimovich, O
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l 1 can you tell me what TOUV stands f or? I don 't knov 2 whether to ask about the others also. It depends upon -
3 where the :;uestioning is going to go. Which event is 4 tha t?
5 WITNESS BURNS: This terminology is similar to 6 that that was.used in WASH-1400, and that is a shorthand 7 way of indicating that there was a transient challenge 8 -- tha t is "T" --
to the system. "O," "U," and "V" are 9 indications that -- "Q" is feedwater is lost, "U" is all 10 high pressure makeup systems are lost, and "V" is all of 11 the low pressure makeup systems are lost, so that there 12 is no ability to get water into the core.
13 JUDGE BRENNER: I guess while we are 14 addressing it, maybe you should tell me what "W" is 15 since TW is also an event.
1s WITNESS BURNS: TW was also a transi,ent 17 challenge to the system, and "W" refers to the inability 18 to remove heat from containment, and that is a coupled 19 failure of both RHR and the power conversion system 20 which is to remove heat through the condenser and 21 eventually into the ultimate heat sink.
22 JUDGE JORDAN 4 Excuse me. WASH-1400 I believe 23 uses a simple "W" failure to remove residual core heat, O 24 aa a t rou r = uaa= ore =ea=161e aa re oaed1e-25 but at least the copy I have of WASH-1400 has "W,"
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() 1 failure to remove residual core heat.
2 WITNESS BURNS: Is that PWR or 3WR? .
3 JUDGE JORDAN: That is BWR accident sequence
() 4 symbols.
5 WITNESS BURNS: I am not familiar with that 6 exact quotation. However, when they refer to accident 7 sequence TW, which is one of the dominant sequences in 8 Class II, what they are forced to ascume is that they 9 lose both power conversion system and the RHP system.
10 JUDGE JORDAN: Well, I am just a little 11 puzzled because what you said about the TOUV is 12 e sse nti a lly a failure to remove core heat. It seems to 13 me that that leads, the IQUV sequence leads to a failure
() 14 to remove co re heat. Isn't that correct?
15 WITNESS BURNS: TOUV refers to an inability to 16 get water, makeup water into the vessel and therefore 17 core melt due to inadequite core cooling.
18 JUDGE JORDAN: Just give me a moment.
19 WITNESS BURNS: TW is residual heat. We are 20 talking about decay heat removal.
21 JUDGE JORDAN. Yes, we are, but you said "W" 22 was failure to remove residual core or containment heat.
23 WITNESS BURNS: To remove Peat from
() 24 con tainment .
25 JUDGE JORDAN Well, WASH-1400 says the "W" is O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5750 1 failure to remove residual core heat. Now, tha t 2 eventually ends up in containment, so without a pretty 3 careful search, I would have to --
O 4 WITNESS BURNS: Are you quoting from one of 5 the --
6 JUDGE JORDAN: I am looking at the WASH-1400 7 document, and perhaps -- this is the reactor safety 8 study, the main report, and could I psss him the copy 9 and see if you can verify what I have said or explain 10 apparently the dif ference in terminology?
11 [ Witness was handed a copy of the document.)
12 WITNESS BURNS: I think that is they attempted 13 to abbreviate the meaning of "W" there to assist people 14 in reading it, but I am afraid what they have done is 15 abbreviated it too much.
16 JUDGE JORDANS You believe they intended it to 17 mean containment heat?
18 WITNESS BURNS: There is no doubt in my mind 19 that is whst it is.
20 JUDGE JORDANS All right. .
21 W IT N ESS J0KSIMOVICH: I can corroborate that.
22 JUDGE JORDAN: All right, fine.
23 JUDGE BRENNER: Just to round out the pie, to O 24 to epeex here, meybe yeu cen te11 me whet S 1
end S 2
25 and " A" is f or the sequence of the WASH-1400 pie?
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5751 l
1 WITNESS BURNSs Those were accidents that were
(}
2 initiated by small, medium and large locas.
3 BY HS. LETSCHEs [ Resuming]
O 4 0 Dr. Burns, in my last question, or relevant to 5 sy last question was there any Shoreham-specific or 6 site-specific reason for the larger size of the TOUV 7 frequency at Shoreham as opposed to WASH-1400?
8 MR. ELLIS: Judge Brenner, I have been, I 9 think, fairly patient through the questioning, because 10 it seems to me this is on results rather than 11 methodology at tnis point and has been, and therefore we 12 would object on the grounds that it is based on results 13 and not on methodology, and I think that this does 14 transgress the line.
15 In addition I think, as we have learned with 16 some of the testimony that was taken last week, it is 17 really discovery for ATWS or some other contention, and 18 we would object on those grounds.
19 JUDGE BRENNER: Well, the second grounds won't 20 help you. If it is otherwise pertinent to this .
21 contention, the fact that it also relates to another one 22 might lead to cut if off as a matter of degree but not 23 totally.
() 24 MS. LETSCHE: Judge Brenner.
25 JUDGE BRENNER: I think I will sa ve you some O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5752 Q 1 time here. I am going to allow the question because, 2 consistent with the ruling we made on the motions to 3 strike, which is what you alluded to, we said we 4 wouldn't delve into the detailed calculations but we 5 would allow an inquiry sufficient to explore what 6 methodology was applied. The witnesses in-both their 7 prefiled testimony and orally keep coming back to the 8 point that they think the Shoreham analysis is a good 9 one because the results are consistent, which I 10 find -- well, I won't say anything, but as long as they 11 have that in their testimony which remains, I think this 12 inquiry is pertinent.
13 The questioner is not delving into the detail 14 of calculations, and I am not sure what Ms. Letsche has i 15 in mind but I am putting it in the pigeonhole I just te indicated as I am listening to the exchange. If the 17 witnesses are going to say their results are consistent 18 and that is why they know they have a good study, to 19 that extent and broadly without going into grea t detail 20 we will allow it, and I think this comparison is quite 21 broad so far.
22 23 24 25 O
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{} 1 JUDGE MORRIS: It has been so long since.the 2' question, 1s. Letsche, let me see if I understood it.
3 Were you asking whether'the~ methodology used in this PEA O 4 had some site-specific fastures in it for the Level 2 5 study that they have done?
6 MS. LETSCHEa I suppose that was part of my 7 question. I think my particular question at that point 8 was a follow-up on my earlier one, which was to attempt 9 to get an explanation for the difference between the 10 size of this particula r f requency in the two studies, 11 and if that was solely rela ted to the change in accident 12 sequence, thinking that Dr. Burns b' stioned if there 13 were Shoreham-specific characteristius or reasons that
) 14 would account for that size difference. /
15 JUDGE MORRIS: So you vere really talking 16 about design differences or methodology differences?
17 MS. LETSCHE I quess both. Either one.
18 JUDGE M3RRIS: But'not site-specific?'
19 MS. LETSCHE4 Well, site-sdecific in terms of 20 the site design specifics. .
21 JUDGE MOR3IS: Well, site to me would mean 22 of f-site cha racteris tics -- meteorology, population 23 distribution and so forth.
\
, t
()
24 MS. LEISCHE. That is not what I,Nas referring
(
25 to, no, Judge Morris. , / l 1
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)
I 1 JUDGE MORRIS: fou are talking about plant
, , ; ,-* r ,,,-,
2 design? g, 3 MS. LETSCHE: that is right. /
0 Yes, l' i, ,
4 WITNESS BURNS: I guess -- I triied to give you 5 a little bit of an explanation of why I f t:1 t .th e'rd were
~;r 6 differences, and apparently, I did not;do a very good 7 job. .
8 There tre no, to my.knowle#ge, si te-specific
'o 9 dif ferences between Shoreham an3 J i'esch, Bottom, as it was t-i 10 evaluated in 1975 in terms of theiT OUV event, other than 11 one particular item which is actual'ly s bene'itJto.
f ,
12 Shoreham. So that does not show up as an, incr' ease in
~ '
13 the area; that would show up ss a decrease. /
14 So the entire dif ference h'e e ,is totall 15 attributable to both data,that is svallable now that was 16 not avaliable then, additional detail in'the event trees 17 tha t are used in the Shoreham PRA, as opposed to what 4
18 was used in the WASH-1400 evaluation and differences in i
19 the fault tree detail. There basically are no systems 20 differences that I know.of.
21 BY MS. LETSCHE (Resuming)a l 22 0 I notice that there is not a specific category 23 in the WASH-1400 circle for loss of off-site power. Cail O 24 ro" ex=1 ta the re ==as ror t" t2 25 A (WITNESS BURNS) To a large extent, WASH-1400 O
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
a v'T.i e y , _j- s - ,
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, - 5755 t .
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f % _/ , 1 lumped that in T, and it would show up in the TOUV part
. 2 of the chart. I wouldn't want to say that -- let me
,1.
~
3 r'a>~
a se it positively.
O 4 I believe tha t their calcula tions may have 5 overestimated the ability to recover from loss of 8 offsite power.
7 Q In your opinion, is there any 8 Shoreham-specific -- the way we defined it earlier --
9 component to explain the difference in size of loss of 10 off-site power as a contributing accident s eq u en ce? -
11 A (WITNESS BURNS) There are differences in the 12 Peach Bottom arrangement significantly different than 13 Shoreham.. However, those particular differences do not
(~)
\m/ 14 result in this difference. This dif ference between 15 Shoreham and WASH-1400 is totally due to the calculation 16 la Shoreham which says that you do need to recover AC 17 power at some point in this sequence, and uses data that 18 is available, that has been available subsequent to 19 WASH-1400, and it was not a vallable at that time and is
, 20 now available to define what that recovery rate would be.
21 JUDGE JORDANS But in part,. loss of off-site 22 power is site : specific, and Shoreham is out on the end 23 of an island. So wouldn't that, therefore, have
(]) 24 something to do with the frequency of the event at least?
! 25 WITNESS BURNS: As far as the initiating event O
l i
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5756 l
1 goes, yes, indeed. And we looked very hard at defining
[}
. 2 what the initiating challenge to the loss of off-site 3 power, because we were concerned -- based upon other O 4 evaluations that we have done and that Oak Ridge has 5 done, we were concerned tha t that could be a dominant 6 sequence.
7 So we wanted to make sure that the initiating 8 frequency that we had was correct. So we used data from t
9 LILCO on a grid-specific basis to define what the 10 frequency of loss of off-site power would be. -
11 JUDGE JORDAN: But that in itself then was not 12 a main contributor to the fact that you come out with a 13 larger slice of the pie? You say mostly it is because 14 of the mis-estimates in WASH-1400 of the consequences of 15 the loss, is that right?
16 WITNESS BUENS: Of the systems that are needed 17 during that particular sequence, yes, sir. In fact, the 18 ini tia ting frequency of loss of off-site power that was 19 used in WASH-1400 was characteristic of the western 20 grids, which have been noted to be higher frequency of 21 loss of off-site power than eastern pools.
22 JUDGE BRENNER: I don't want to go very far 23 dith this, but since Dr . Jord sn a sked the question, I think what he had in mind was an analogy to the Florida
(]) 24 25 utility peninsula type of arrangement. Shoreham isn't O
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5757 1 quite like that in terms of its connection into the
{}
2 grid, as I understand it. Can you enlighten us, Dr.
3 Burns, or Mr. Kas:ssk? There is another hook-up.
O 4 WITNESS BURNS: I can just tell you from my 5 perception that WASH-1400 has multiple lines into the 6 plant, and they are fed from several sites with gas 7 turbines with black-start capability. In other words, 8 they could start without outside power sources.
9 So from that standpoi n t, it is different than 10 the Florida situation. I should let Bob answer that.
11 WITNESS KASCSAK Well, I can only respond to 12 the extent that we historically reviewed the reliability 13 information on the LILCO grid system and looked at where
() 14 we had outages ani what were the reasons for those 15 outages. And we looked at recovery times, and we looked 16 at our ability to bring power into the Shorehsm 17 facility, the amount of redundant lines. We have both 18 the 138 and the 69 kv system that comes into the plant, 19 plus the mutliple gas turbine sites we have distributed 20 through the island. And we supplied SAI with that 21 information.
22 JUDGE BRENNER: I quess my question is: Is 23 Shoreham on a peninsula-type grid arrangement, like the
() 24 southern Florida utilities, or is there a further 25 connection, for example, up through upper New York state?
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5758 .
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{} 1 WITNESS KASCSAK There are inter-ties with 2 ConEdison through tne New York City inter-ties, and 3 there are connections through northeast utilities O 4 through our Connecticut inter-ties. If that is your 5 question. Maybe that is the response to that aspect of 6 it.
7 JUDGE BRENNER: Yes. That explains it.
8 (Counsel f or Suf f olk County conf erring. )
9 MR. ELLIS: Judge Brenner, may I ask the 10 reporter -- I didn 't ask before, but ordina rily in court 11 proceedings there are occacions where you can ask the 12 reporter to mark s place and ask him to read it back at 13 a break. Is that possible with this system? ,
() 14 (Discussion off the record.)
15 JUDGE BRENNER Let's go back on the record.
16 BY MS. LETSCHE (Resuming):
17 0 Dr. Burns, with respect to the changes in data 18 and methodology that you referenced in your earlier 19 ans wers , if the re aren't any system differences between 20 -- significant ones, between Peach Bottom and Shoreham, 21 what was it that caused you to change your event trees, 22 or that caased the change in the event trees between 23 WASH-1400 and the Shoreham PRA?
() 24 A (WITNESS BURNS) I quess I ha te to re pea t 25 myself, but what we were trying to do is we were tryino O
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5759 1 to take all the information tha t we had available after
(}
2 WASH-1400 was done. As Dr. Joksimovich said, it was
~ 3 seven or eight yasts ago --
take all of that
/V ')
4 information, which includes a number of studies that 5 have been performed both by the NRC and the national 6 labs, and other PRA work, try to incorporate that in the 7 way that we analyzed the Shoreham plant.
8 So it wouldn't be right to neglect that 9 information. In order to incorporate that information 10 accurately, we needed to develop additional event trees 11 to a finer level of detail to show all of these 12 different possibilities and reflect the data as it 13 exists. .
() 14 0 So it is really just that the event trees were 15 more detailed than they had been in WASH-14007 16 A (WITNESS BURNS) Yes.
17 0 In discussing the comparison of WASH-1400 to 18 Shoreham PRA, you referenced a discussion in the text, 19 and I would like to direct your attention to page 3-149 20 of the Shoreham PRA which has Section 3.6.3 headed 21 Comparison with WASH-1400 on it, and ask you if that is 22 at least a portion of the text you were referring to in l
23 your answer.
() 24 A (WITNESS BURNS) Yes, it is.
25 0 In reading the text there, I noticed, Dr.
(
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5760 1 Burns, that there seemed to be three terms that are 2 being discussed degraded core canditions, vulnerable 3 core and core melt. There are those three terms that O 4 are used, is that right?
5 A (WITNESS BURNS) Yes.
e 0 In the last sentence in the first paragraph of 7 Section 3.6.3 it sa ys -- a nd I will read it into the 8 record -- "The Shoreham evaluation produces a total 9 estimate of degraded core conditions smaller than 10 WASH-1400." -
11 Now, in light of the comparison that is 12 depicted in Figure 3.6.6, can you explain the statement 13 I just read into the record ? ,
14 15 16 17 18 19 20 21 22 23 O 24 25 O
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5761 Q
\J 1 (Pause.]
2 A (WITNESS BURNS) The choice of that wording 3 migh t be very conf using, and I apologize for that. The O 4 next paragraph I think securately defines what the 5 comparison in Figure 3.6.6, which is Exhibit 24 of 6 Suffolk Coanty, what that comparison actually is, and it 7 is a comparison of the frequency of core melt from 8 WASH-1400 versus the frequency of core vulnerable 9 condition from the Shoreham PRA. And we can say that 10 this comrar1 Son was made ba sed upon similar assumptions 11 for the uer . va tj ot of each frequency.
12 The figure also demonstrates that the 13 f requency of core melt calculated in WASH-1400
() 14 approximates that determined in the Shoreham PRA, in the 15 Shoreham PRA, which represents the frequency of events 16 which could place the core in jeopardy, that is, core 17 vulnerable condition.
18 Now, to return to your question, given th a t 19 understanding of the comparison, if we were to 20 calculate, and we do, a core melt frequency for 21 Shoreham, it is less than the core melt frequency 22 calc ula ted in W ASH-1400, and that is what the sentence 23 that you asked about is intended to say.
() 24 0 So the statement in the sentence I read, or 25 the reference to degraded core conditions is not what O
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5762 1 you meant? You meant to say core melt rather than
[
2 degraded care conditions?
3 A (WITNESS BURNS) I think core melt frequency O 4 is the correct term that we should have used.
5 [ Counsel for Suffolk County conf e rring. ]
6 0 In doing your comparison of W ASH-1400 and the 7 Shoreham PRA, did you separately calculate a frequency 8 of core melt for WASH-1400 or did you just use the 9 number that WASH-1400 came up with?
10 A (WITNESS BURNS) I guess what we have to do 11 here is we have to explain that WASH-1400 assumed that 12 once the core began to be uncovered or once you 13 challenged containment, that that led directly to core 14 melt. In the Shoreham PRA what we are trying to do is 15 we are trying to do a realistic estimate, we are trying 16 to eliminate, if there are any overconservatisms, we are 17 trying to eliminate those and make a realistic estimate 18 and then put uncertainty bounds on that.
19 In order to do that, we have included the 20 possibility of re:overy for cases where con tainment may 21 be challeng61 or core water level may be low or 22 decreasing but the operator still has options available 23 to him to provide makeup water to the core. Therefore,
() 24 the core melt frequency from Shoreham is less than the 25 core vulnarable frequency that is calcula ted, and it is O
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5763 1 less by the ability of the operator and the automatic
[}
2 systems tha t are available to recover the core even 3 after the core has been uncovered or the containnent has O 4 been challenged, either of those cases.
5 [ Counsel for Suffolk County conferring.)
6 0 Did the WASH-1400 analysis -- or was the 7 analysis concerning accidents leading to core melt based 8 upon a realistic analysis or an assumption?
9 A (WITNESS BURNS) It was a realistic analysis.
10 However, engineers tend to be, when they are in doubt, 11 they tend to be overconservative in some cases, and 12 therefore there were cases in WASH-1400 that were 13 assumed to lead directly to core melt that could
("% conceivably have been reversed.
s_) 14 15 A (WITNESS J0KSIMOVICH) If I.may add a few 16 things, at the time WASH-1400 was completed, some 17 Com putational tools tha t we currently have were 18 unavailable, and hence in the absence of those they 19 chose not to distinguish between what we call core 20 vulnerable and core melt.
21 Q I guess my question, Dr. Burns, is: In your 22 comparison of Shoreham against WASH-1400, did you 23 differentiate between core vulnerability and core melt
() 24 with respect to the WASH-1400 numbers?
25 A (WITNESS BURNS) I was only able to report ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5764 1 what WASH-1400 had originally done. So th e ref o re , the 2 numbers that are quoted here for WASH-1400 are 3 representative of what they estimated core melt 4 frequency to be.
5 0 And in your opinion that was a ve ry 6 conservative analysis, the assumptions of core melt? Is 7 that right?
8 A (WITNESS BURNS) No. I said that the -
9 assumption tha t all core melts or all challenges to 10 containment lead directly to all losses of coolant to 11 the core, or a]l challenges to the containment leading 12 directly t core melt, I said that I believe that to be 13 a conservative assumption. I think, as we have
() 14 discussed earlier, there are some cases where apparently 15 now, and we have to be a little careful, but apparently 16 they either missed sequences or underestimated 17 sequences. But I am not sure.
18 I would hate for you to go away with the impression 19 that this particular comparison is any more than what I 20 had originally stated, which was that in order for 21 myself or any reviewer to benchmark himself ac to what 22 we were calculating versus what people have done in the 23 past was to portray it in this fashion, and therefore a
(} 24 peson can go to this chart and see that in fact there are sequences at Shoreham that are different than those 25 O
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5765 1 in WASH-1400.
2 Now, if he is interested in why there are 3 those differences, he can read Oak Ridoe reports which O 4 talk about loss of offsite power and how you recover 5 from those and whether they are important or not. He 6 can read other PRAs or IREP and dec. ' whether that is a 7 real case, whether WASH-1400 missed it o whether 8 WASH-1400 was right and this is incorrect.
9 But all this is is an attempt to place before to the reviewer a particular point in the analysis so that 11 he has a logical place to compare to evalua tions that 12 have been ione in the past.
. 13 [ Counsel for Suffolk County conferred.]
() 14 0 Dr. Burns, you have said that both Shoreham 15 and WASH-1400 used a realistic analysis. Would you 16 agree, however, that the WASH-1400 assumption of core 17 nelt was more conservative than the assumptions used in 18 the Shoreham PRA? ,
19 A (WITNESS BURNS) I guess I would say that the 20 assumptions are very similar. The calculated 21 frequencies of W ASH-1400 I guess I would not 22 characterize necessarily as conservative in light of the 23 fact tha t there may be some sequences which were not
() 24 included, in light of the fact that the NRC staff has 25 subsequently said that their estimate of ATWS was O
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5766 I
1 I
1 greatly underpredicted. I guess I could never 2 characterize their number as overly conservative.
3 0 I guess I wasn't asking, I don't think I was l
O- 4 asking about the number, although my question could have 5 been unclear. I am confused as to why WASH-1400 talks 6 about core melt and Shoreham's PRA talks about core 7 vulnerability if you both used a realistic analysis. I 8 understood you to say that WASH-1400 a~ssumed a core melt 9 would result from more conditions than the Shoreham PRA
- 10 did, and maybe I misunderstood you.
11 But that is my question. If that was the 12 assumption at WASH-1400 and that is why they are talking
. 13 about core melt, is your use of core vulnerability
() 14 rather than core melt less conservative than the 15 analysis used at WASH-1400?
16 A (WITNESS JOKSIF.0VICH) I tried to point ou 17 earlier that at the time WA SH-1400 was completed , which 18 was 1975, that the computational tools that are 19 available to us now did not exist, and hence the leaders 20 of WASH-1400 chose not to distinguish between core 21 vulnerable and core melt, deliberately, and so ther 22 converted core vulnerable into core melt simply to be on 23 the conservative side because they couldn't support it 24 with some kind of sophisticated analysis that we can do
(}
25 today.
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5767 1 JUDGE JORDAN Are you saying that had they
)
2 used core vulnerability, that they would have come up 3 with larger numbers?
O 4 WITNESS J0KSIMOVICHs If WASH-1400 used the 5 term "co re vulnerability," that would have been 6 different from core melt, the number that is quoted in 7 the report and in this table.
8 JUDGE JORDANS Different f rom wha t?
9 WITNESS J0KSIMOVICH: If W ASH-1400 was to be to redone and if the difference between core vulnerable and 11 core melt was an issue, then in a reevaluation of that 12 they would have arrived at two dif ferent numbers, one 13 for core vulnerable and one for core melt.
() 14 JUDGE JORDAN: And I ask you which is the 15 largest.
16 WITNESS J0KSIMOVICH That is obvious. The 17 core vulnerable is the larger number than the core melt 18 is, and that would be an order of magnitude.
I 19 JUDGE JORDAN: Yes, and I believe that does go 20 to the questions that you have been asking. If that 21 helps, fine. If not, go ahead.
l 22 BY MS. LETSCHE (Desuming):
23 0 Dr. Burns, I got the impression you were going
() 24 to add something earlier to Dr. Joksimovich's answer.
25 Do you agree with his answer to my last question?
?
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5768 O ' ^ ("ttssss Suass) 'es- 1 eoree- 1 oue== 1 2 would just cha racterize the dif f erence in that -
3 particular assumption, and now again, we have to be 4 careful. You have isolated one particular segment of 5 the analysis, and thst is the conditional probability of 6 given that you challenge containment or core, can you 7 then recover.
8 If we isolate our look at just that particular 9 assumption, what the Shoreham PR A has attempted to do is 10 to refine the original WASH-1400 analysis to account for 11 wha t happens in that period of time. And so I would 12 characterize it more as a refinement. In that 13 particular assumption one can say that W ASH-1400 was O 14 conservative , more conserva tive than possibly the 15 Shoreham analysis, but only in that particular 16 assumption, not necessarily in the entire evaluation.
17 0 Dr. Burns, going back to the sentence at the 18 end of the paragraph on page 3-149, the Shoreham 19 evaluation produces a total estima te of deg raded core 20 conditions smaller than WASH-1400, and you said that 21 should read " core melt frequency" smaller than WASH-1400.
22 A (WITNESS BURNS) Yes.
23 0 How can you say that when it seems to me you O 24 a re te1xino about epp1e= end orenoes with core me1t in 25 WASH-1400 and core vulnersbility in Shoreham?
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5769 (WITNESS BURNS) I guess we are trying to do
(]) 1 A 2 the best job that we can here. The only yardstick that 3 is available to us, the only thing that is out there is 4 WASH-1400. If there was anything else, you can bot it 5 would have been here. The safety goal is not verified i
6 or confirmed or it is not yet available so it is not 7 there. There are virtually no other studies that are 8 available to place on this chart to compare the two 9 calculations with. If there were, I would have put them 10 here.
11 A (WITNESS J0KSIMOVICH) I think there are other 12 studies that haven't reached the status of WASH-1400 as 13 far as popularity amongst the nuclear safety community.
14 A (WITNESS BURNS) The reason that this 15 particular comparison was made, as I have tried to 16 state, is that the assumptions that went into these two 17 are comparable. We could have compared core melt 18 frequency. We could have compared the calculated core 19 melt frequency for Shoreham and that f or WA SH-1400 and i 20 the values would have indicated that the frequency for 21 Shoreham was less than that esiculated for WASH-1400, 22 but it would have included this assumption, and I 23 conuidered it to be more important to the reviewer to i
() 24 compare comparable assumptions rather than comparble 25 -core melt frequency. We could also do that and we are, l CE) .
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5770 O ta e et- teriev to so thet 1a the aext revis1oa, io .r 2 update. But this was what we chose to present at this 3 time.
4 5
6, 7
8 9
10 11 12 13 O 14 15 16 17 18 19 20 ,
21 22 23 O u 25 O
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5771
() 1 0 Dr. Burns, you said earlier that you were the 2 lead analyst on the Limerick PRA, is that right?
3 A (WITNESS BURNS) Yes.
4 0 What is the status of that PRA? Has it been 1 5 completed?
6 A (WITNESS BURNS) I guess I was the lead analyst 7 at the original filing of the Limerick PRA. I am not 8 presently intimately involved in the details of the 9 Limerick PRA. I know some of the items -- I do have 10 some review capacity, still.
11 0 The one that you were involved in as lead 12 analyst, is that the one -- the version that is dated 13 March 19817 14 A (WITNESS BURNS) I believe that is correct.
15 0 Was the methodology used in performing the 16 Limerick PRA the same as that used in performing the 17 Shoreham PRA?
18 A (WITNESS BURNS) Yes, it is very similar.
19 0 Were there walkdowns performed in connection 20 with the Limerick PRA? -
21 A (WITNESS BURNS) The term walkdown is a little 22 troublesome to me, because I think it is ill-defined in 23 the litersture and in people's perceptions of what a
() 24 valkdown is. At the time of the Limerick PRA, there was 25 no PRA procedures guide issued. The study was directed O
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5772 1 by the NRC to be completed within 120 days. The study
(}
2 was not started for 30 days, and then it took 30 days to 3 7et the information available.
O 4 We did convince Philadelphia Electric that one S of the important parts of doing the PRA would be for us 1 6 to visit the site, to familiarize ourselves with the 7 systems and how they are situated in the plant, and to 8 observe whether there are any potential common causes or 9 dependent f ailures that we could not pick up from the 10 design drawings.
11 So Philadelphia Electric did provide at least 12 two plant familiarization tours of the plant f or the 13 principals involved in the analysis, both in the
/~T 14 consequence and the fault tree / event tree analyses.
~
15 There were not checklists per se, but the ir. tent of the 16 familiarization I believe was accomplished.
17 0 Were you involved in those plant tcurs?
18 A (WITNESS BURNS) Yes.
19 0 I believe you state in your testimony that one 20 of the things you reviewed in connection with.your 21 performance of the Shoreham PRA was the Limerick PRA.
22 Is that right?
23 A (WITNESS BURNS) Yes.
() 24 Q Did that review include a review of the 25 results of the Limerick PRA?
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5773
(} 1 A (WITNESS BURNS) Yes.
2 MS. LETSCHE: I would like to have marked as 3 Suf folk County Exhibit No. 25 for identification a pa;e O 4 taken from the Limerick PRA dated March 1981. It is 5 page 3-96 on which is contained Figure 3.5.2, antitled 6 Summary of the Accident Sequence Frequencies Leading to 7 Degraded Core Canditions Summed Overall Accident 8 Sequences within a Class.
9 JUDGE BRENNER: All right, it is so marked.
10 (The document referred to 11 was marked Suffolk County 12 Exhibit No. 25 for 13 identification.)
s
~
14 JUDGE BRENNER: Ms. Le tsch e , even though you 15 are not moving many of these individual pieces into 16 evidence -- and I realize why not -- at the completion 17 of your cross exsiination of this panel, perhaps we i 18 should bind those documents in, emphasizing again at i
19 that point that they are not in evidence.
20 I am afraid the reader of the transcript might 21 be confused unless we make th a t poin t again , but so we l 22 can have all of these separate pieces of paper in one 23 place. And to do that, we will need one additional copy
() 24 for the reporter, when you have completed.
25 MR. ELLIS: Judge Brenner, I think we may well O
~
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5774 1 put them into evidence when it comes time for redirect.
(G~T 2 . JUDGE BRENNER: '4 hy don't you discuss it among 3 yourselves and usybe you can shorten it up by moving O 4 some or all of them into evidence upon the completion of 5 the county's cross examination, and that may well serve 6 your purposes also, Mr. Ellis, to put it all in one 7 place, if that works out.
8 MS. LETSCHEa Tha t is fine, Judge Brenner.
9 BY ES. LETSCHE (Resuming):
10 0 Dr. Burns, do you have before you a copy of 11 what has been marked as Suffolk County Exhibit 25 for 12 identification?
13 A (WITNESS BURNS) Is that Figure 3.5.27 s
14 0 From the Limerick PRA, yes.
15 A (WITNESS BURNS) Yes, I do.
16 0 Dr. Burns, I recognize that the depiction is 17 not the same, but is the da ta represented in Figure 18 3.5.2 roughly comparable to that reflected in Suffolk 19 County Exhibit 23 for identification, which is from the 20 Shoreham PRA? .
21 3R. ELLIS: I don't know if I understand that 22 question. One relates to Shoreham and one relates to 23 Limerick. I don't know how they could be comparable,
()
24 unless what she means is the same nature of the data. I 25 would object to the question as it stands.
l
()
l ALDERSoN REPORTING COMPANY,JNC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5775 JUDGE BRENNERa I will overrule the objection,
(]) 1 2 particularly since your caveat, if you will, is already 3 in the record. And let's let the witness explain it. I 4 think there was some ambiguity in the question, and I 5 think, given your objection , the witness is geared , so 6 to speak, to clarify it in his answer.
7 WITNESS BURNS: Is Exhibit 23 Figure 4.1 from 8 the Shoreham PRA?
9 BY MS. LETSCHE (Resuming):
10 0 res, that exhibit does include the Table 4.1, -
11 and tha t is the one I was referring to. And maybe I can 12 clarify tha question.
13 I am talking about the frequencies of core 14 vulnerability which are stated in Table 4.1 with respect 15 to Shoreham. Are those the same type of data as the i
16 probabilities of degraded core conditions reflected with 17 respect to Limerick in Suffolk County Exhibit 25?
18 A (WITNESS BURNS) The figures are approximately 19 the same. The intent is to demonstrate the same or 20 convey the same type of information. However, one has 21 to read both the Limerick PRA and the Shoreham PRA in 22 order to make sure they understand what goes into the 23 calculation of each of those, since they are slightly l () 24 different.
25 (Counsel for Suffolk County conferring.)
()
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5776
() 1 0 Are the classes that are indicated in the 2 Li.m e ric k figure and in the Shoreham figure comparable?
3 I am talking about the accident classes.
4 A (WITuRSS BURNS) As I said, they a re 5 approximately equivalent. There are some differences 6 betwe9n 'he two analyses. The Limerick analysis, as I 7 said, was originally intended to be a very short 8 analysis of 120 days, and it was an initial attempt, one 9 of the first attempts, to pull together a BWR PRA to subsequent to WASH-1400, and therefore, much of the work 11 that was done in the Limerick PRA was really research
, 12 and development work that was done along the way.
I 13 Subsequent to the Lime:,1ck work, when we
() 14 performed the Shoreham PRA, the it. formation that we had 15 available to us was then much greater. We were able to 16 more clearly define what important classes we wanted to 17 calculate, using MARCH CORRAL to calculate what the 18 thermal hydraulic conditions inside containment were.
19 So from that standpoint, I would say that the 20 Shoreham analysis has built upon what was done for 21 Limerick.
I 22 0 Bearing that in mind, is it nonetheless 23 possible to compare the probabilities for a given class
() 24 of accident from the Shoreham study to the equivalent 25 probabilities or the simila r probabilities f or the O
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.- - , - . = _
5777
{
() 1 Limerick study?
2 MR. ELLISs I object to this question. It is 3 cleary an effort to gain discovery for the ATWS 4 contention, and it has no relation at all to methodology 5 of PRA. And we have seen this last when we reviewed the 6 transcript last time and reviewed the ATWS testimony 7 that was submitted, and I think that is the plain intent 8 of this. It has nothing whatever to do with the PRA 9 methodology, in fset.
10 MS. LETSCHE Judge Brenner, if I mich t 11 respond, number one, there has been no mention at all in 12 this testimony or this questioning of the ATWS issue.
13 And number two, I think this is an obvious follow-up to 14 the comparison which Dr. Burns said he did of the 15 results of the Limerick PRA in performing the Shoreham 16 PRA. And I am merely trying to determine the extent of 17 that comparison and wha t conclusions he drew f rom that.
18 JUDGE BRENNERs Give us a moment.
19 (Board conferring.)
20 . We are going to overrule the objection as 21 stated. However, I am going to use the opportunity to 22 jump in with something. I was going to jump in as the 23 line proceeded. One reason I am overruling the
() 24 objection is we do not understand part of it; that is, I 25 don't see how the question is discovery for ATWS or even O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5778 geared tha t way.
(]) 1 2 And again, I will repeat our earlier comment.
3 Even if in the course of it it discloses things 4 pertinent to other contentions, that by itself does not 5 necessarily make a question objectionable. The analogy 6 to be to where we did limit the detail that we permitted 7 the questioner to go into on inadequa te core cooling 8 when we are in the context of Contention 7(b), knowing 9 we were going to come back to the area. But 10 nonetheless, questions were permitted which would 11 obviously be pertinent to both areas.
12 And I also recognize that you were following 13 up on your previous questions. However, I am troubled .
O 14 as to how this line is going to help the Board or the 15 county, for that matter, in findings or a decision on 16 the contention. That is, the allegation that there is 17 an impropar classification of systems in part because 18 systems interactions were not properly accounted for. I 19 don't know how the answer to this comparison is going to 20 help us.
21 It is the same problem I have with the 22 witnesses' assertion that they looked at the results of 23 the other studies. And because the results were t
() 24 generally similar with the preliminary results of the 25 Shoreham PRA, they think they have taken care of systems
()
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5779 interaction. And I think -- I have reference to tha t
(]) 1 2 page that is somewhere scound page 60. And it was not 3 actually in these witnesses' section of the testimony, 4 and there were some questions about tha t before. I 5 think they used the term positive results.
l 6 So maybe you can help me with that.
7 MS. LETSCHE. Yes, Judge Brenner, that is 8 really exactly the point. If we are to, or this Poard 9 is to, take comfort from the positive results of these 10 other PRAs and we are told that the Shoreham PBA is --
11 or he methodology of that PRA is good because it has 12, built upon the positive results of other PRAs, I think 13 it is important and it is certainly very relevant to .
14 test the basis for that conclusion.
15 And in order to do tha t, it seems to me you 16 have got to find out what the comparison was and wha t 17 was done, if anything, with the results of that 18 comparison or what the conclusions were as a result of 19 that comparison.
20 The thrust of my cross examination is to test 21 the basis of that statement and to find out if any 22 changes in Shoreham methodology with respect to the PRA 23 resulted from that comparison. Or if they anticipate
() 24 any such changes.
25 JUDGE BRENNER: Even if I4 arguendo, agree O
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5780
(} 1 with your general proposition, it is still a very 2 abstract proposition, and the questions asked are very 3 broad and abstract. And if somebody doesn't ask, I am l
() 4 going to ask at some point to find out the relationship 5 of the PP.A as a confirmatory check, which is what LILCO 6 claims it is, to classification of systems and systems 7 interactions.
8 And I think if you focused your questions that 9 way, we would get quicker questions, quicker answers and 10 also, the transcript would contain things that are more 11 directly pertinent. Certainly, you don't write a 12 finding on each and every question, and you don't know 13 precisely which ones are going to be good for findings 3
14 from your point of view until you put the whole record 15 together.
16 But nevertheless, I think we can predict that 17 as long as you stay this abstract, it is not going to be 18 helpful to some extent. The reference in the direct 19 testimony, as I indicated, was rather abstract, but we 20 can focus on it a little more. And I would like you to 21 think about doing that, as we permit you to pursue the 22 line. And tha t is, as you discussed, why they are 23 drawing comfort from the comparison but focused that
() 24 comfort in the context of classifica tion of systems, 25 which is what the contention is all about.
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s.
s I
5781 While we are on that subject -- and this
(]) 1 2 relates at least peripherally to our ruling on the 3 motion to strike and it has come up a few times. There 4 is an error in the transcript, or at least I think it is 5 a transcript error because I believe I said it correctly 1
6 in our rulings on page 4332, line 24; and again on page '
l
( 7 4333, line 6, thu word " qualitative" should be 8, " quantitative" and I hope everybody understood that at.
9 the time, and that was the whole point of our s
(
10 distinction in trying to explain the anbiguous term 4 ,
11 " application of the me thod ology. "
12 And to give you the con' text'if you don't have ,
13 the transcript, it is the term "appli:ation of the 14 methodology can evoke two distinct concepts; one is the l 15 correctness of the quantitative..." not qualita tive ,
l l 16 .. .the qua n tita tive analysis performed pursuant to a 17 defined methodology. The other is a more cverall 18 detemination of scope and content to ascertain what 19 methodlogies are used, and in fact, to ascertain whether 20 two different parties are talking about the same thing 21 by. their use of the same label."
22 And in the next phrase there is the same t
- 23 correction for the same reason. I think we are in the
() 24 area of the portion of that definition that we allow, 25 however, for reasons of abstractness, that'by itself is
()
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5782
() 1 not very helpful. And let's see if we can focus in.
2 MR. ELLIS: Judge Brenner, may I, for the 3 record, ssy just a few things in response?
4 First of all, much has been said about taking 5 comfort from the results. As I recall, most of our 6 results were stricken as a result of the motion to 7 strike. For example, the result we have been talking i
8 about about core melt frequency was a specific result 9 that was stricken.
! 10 If the interest is in wha t methodology is 11 different between Shoreham and Limerick, the question 12 ought to be asked directly. In fact, if the Board will 13 look at pages 6, 7 an onward in the ATWS testimony, we t
b 14 see exactly what the purpose of this is, which is 15 discovery to permit comparison of the ATWS frequencies 16 to support arguments on automatic actuation of SLC. And 17 I predict that that is the cain thrust of this testimony.
16 I think that what we have done is to have 19 imported into the te stimon y some of the conclusions 20 which we agreed to have stricken, pursuant to the motion l
21 to strike.
22 JUDGE BRENNEP: If I would grant your 23 objection, what would you to support your conclusions on
() 24 page 60 and 104 of your direct testimony where comfort 25 is drawn from the comparison? I recognize that some of i
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5783
() 1 what you agreed to strike bears upon this matter. I 2 think we pointed out in our ruling that the portions 3 that talked about it as being a state-of-the-art study 4 was a close call, but as long as you were willing to 5 strike it, we would.
i 6 But we attempted to give the guidelines in our 7 ruling anyway, and I suggest those limited portions 8 could have fallen on the other side of the ruling. But 9 ve didn't want to get into detailed word engineering of -
10 keeping a sentence out of a whole paragraph that you 11 were willing to strike, when we made that point.
12 In addition, even if you have correctly 13 identified the motive in county's questioning -- and I
_O 14 say that arguendo -- again, if it is also pertinent to 15 the subject, the fact that it is going to come up again l 16 is interesting, and in fact, on a close call, maybe it 17 would weigh in f avor of hearing it since we will only 18 have to hear it again anyway.
19 If it was irrelevant to this portion, the fact l
20 thst it is pertinent to ATWS wouldn't save it. But if 21 it is relevant to both, we will let it in and try to 22 draw pragostic guidelines as we did in the inadequa te 23 COCO C00lin7*
() 24 But you have got conclusions in there. Mr.
25 K2scsak orslly testified st some length tha t his O
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5784
('s 1 knowledge of the other studies, including Limerick, V
2 again, that the Shoreham PRA is a good check for a 3 proper classification of systems. It is open to the O 4 questioner to find out why that is. That is, if you 5 have the same problems going in, the same results coming 6 out, it might not necessarily give you comfort.
7 I do think the questions can be asked more 8 directly. The example you just gave, Mr. Ellis, would 9 be one more direct approach, and that was the reason 10 that even though we overruled your objection, I went 11 into the rather lengthy dialogue I did with Ms.
12 Letsche. And I want to see what she does in response to 13 that. .
14 But do you see what I mean about portions of 15 your testimony that stayed in on the pages I cited, that 16 go to that point?
17 MR. ELLIS: I think they can be asked about 18 why those positive results give them comfort, but we are 19 now talking about a comparison of the results, and I
(
20 submit that it is for another purpose and irrelevant to 21 systems classification or to systems interaction. To 22 put it in the vernacular, they haven't laid a glove on 23 whether we investigated systems in t e r a ctio n s .
() 24 JUDGE BRENNER: The problem I indicated was I 25 am not sure whether direct testimony lays a glove on l
n l
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5785 that either when it just says, we rely on these positive
(]} 1 2 results. And that is one reason I am allcwing the 3 questioning. Eut I do want it to be more direct. You O 4 Can put that phrase in your findings.
5 MR. ELLIS: I respectfully submit that the 6 direct testimony goes into considerable detail on the 7 extent to which systems interactions have been addressed.
8 JUDGE BRENNEPs In the PRA?
9 MR. ELLIS: In the PRA, yes, sir. In the 10 Shoreham PRA there is extensive testimony on how the 11 systems interactions are considered and if the Board --
12 we can put in the entire draft PRA, if the Board would 13 . find that helpful.
14 WITNESS KASCSAK Maybe I could --
15 JUDGE BRENNEE: Wait a minute. We are just 16 having argument of counsel and not testimony. You will 17 get your chance through counsel on redirect. It is 18 frustrating to sit there while everybody talks, and th e y 19 probably have it all screwed up, but that is the process.
20 (Laughter.)
21 MR. ELLIS: But I think this is helpful.
22 JUDGE BRENNER: I tell you, this is a hint for l
l 23 your redirect. If you want to focus your witnesses back l
() 24 on where the Shoreham PRA is a helpful confirmatory 25 check on systems classification, including systems O
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5786
(} 1 i n te ra c tio n s , you would help me a great deal, as one 2 Board member.
3 MS. LETSCHE: Judge Brenner, all I can say is O 4 that I certainly do intend to get into some of the 5 specific differences in results between the Shoreham and 6 Limerick studies. And frankly, what I am doing at this 7 point is getting the information before us all to enable 8 me to do tha t. And I don 't frankly think ~ there is 9 anything at all improper about it. Maybe it is slower 10 than some people would like, but that is what I am doing.
11 JUDGE BRENNER: Well, we are going to cut if 12 off if it doesn't focus along the lines I just discussed
. 13 on the contention. And that is, even if you are on the 14 right side of the motion to strike, you still have that 15 problem about being too abstract to be useful.
16 In addition, I will note that you have 17 severely underestimated your time estimate. We have 18 stayed at your questioning at length today, and your 19 original estimate was a couple of hours, and then you 20 revised it and we are above the revision even now. So I 21 hope we can finish up today. That is, by 4:00 o' clock.
22 I was going to take a break around 2:30. With all of 23 these interruptions, should we take it now or would you
() 24 like to ask some questions before?
25 MS. LETSCHE I think there is a pending O
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5787 1 question that we sight want to get answered , but other
)
2 than th a t , whenever you would like to go.
3 JUDGE BRENNER: Well, let's take the break now O 4 and you can be ready to come back and repeat the pending 5 question after the break. Wait just one minute.
, 6 (Board conferring.)
l l
7 Let 's sta y on th e re c o rd . Judge Jordan has 8 one thing he would like the witnbsses to consider over 9 the break.
- 10 JUDGE J3RDAN: Do you have a copy of WASH-1400 11 with you today? I will loan you my copy. I see some 12 nods. I do not have Appendix 5 which is referred to, 13 but I want you to look during the break at page 65 of 14 the main report. I know there have been two or three 15 additions to this, but this has to do with Section 16 5.3.4.3, Transient Events, T. And look at that section 17 because it seems to me that that section does indicate 18 strongly that in the WASH-1400 the use of the tern "W" 19 was for the removal of heat from the core. So just look 20 at it during the break.
21 JUDGE BRENNER: All right, we will come back 22 at 2: 40.
23 (A short recess was taken.)
() 24 25 O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5788 1 JUDGE BRENNER: Let's go back on the record.
2 I will note that this is turning into the kind of g 3 hearing day that I strive very hard to avoid, and I U 4 think I mentioned that at the beginning of th e 5 proceeding. Ihat is, we have gotten more lawyers' talk 6 than testimony today, or at least the percentage is 7 wrong. And hopefully, the lenathy comments and dialogue 8 that we have had will h'elp in the long run.
9 Let's go back to the questioning now.
- Walter ,
to do you want an answer to yours now?
11 JUDGE JORDANa If they wish.
12 JUDGE BRENNER: Let's get an answer to Judge 13 Jordan's questions now.
14 WITNESS BURNS The question refers to what TW 15 implies in WASH-1400. In the main report, they talk 16 about W which is the probability of failure of the decay 17 heat removal systems. In Appendix 5, there is a 18 description of what the decay heat removal systems 19 consist of, and as we talked about this morning, it is 20 failure to remove decay heat, but it is decay heat from 21 containment as a whole, and WASH-1400 considered either 22 the RHR system as capable of doing that or the power 23 conversion system.
24 Now, th e postulated failure that they are 25 'asling with is if decay heat cannot be removed via ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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{} 1 either of those sources, then even though you can 2 maintain the core recovery via either LPCI, core spray, 3 HPCI, RCIC or the service water intertie, or any of O 4 those, even though you can do that, the decay heat will 5 eventually cause the suppression pool to heat up, to l
6 boil, and the containment will ultimately fail.
i i 7 And the ultimate f ailure of containmen t is 8 then linked in' WASH-1400 directly to a core melt because 9 of the NPSH requirements on the low pressure pumps and 10 because of the potential structural failures when the 11 catastrophic failure of containment is postulated to 12 occur, and becaus? of potential compromises of the 13 environmental qualification equipment that might be in 14 the reactor building when this release of steam occurs 15 into the reactor building.
16 So W in the context of WASH-1400 is called 17 decay heat removal systems. They are really talking 18 about trying to get the heat out of containment entirely 19 that can be either directly out of the core or the 20 suppression pool or via the power conversion system.
21 JUDGE JORDAN. Well, I guess the thing that 22 concerned we was the sentence which reads, "The 23 probability of failure of the deca y heat removal system
-6
() 24 was determined to be 1.6 times 10 when combined with 25 the 10 transients that occur per reactor year. This O
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-5
(} 1 yields about 2 times 10 for the TW sequence."
2 Well, the 10 transients I remember, of 3 course. They assumed 10 scrams --
f-U 4 WITNESS SUENS: Seven scrams and 3 shutdowns.
5 JUDGE JORDAN: Right. And those would not be l 6 challenges to removal of heat from containment. Those I
! 7 would be challenges primarily to the removal of heat 8 from 'the core.
9 WITNESS BURNS: Thef are challenges to both in 10 the sense that once you shut the plant down, you now 11 have to get that heat. You are constantly producing 12 decay heat and you have to get that heat out of 13 containment.
/ 14 JUDGE JORDAN: Are you saying, then, that by 15 removal of heat from containment, the removal of heat 16 from, say, the suppression pool -- and I was thinking in 17 terms of containment gas, and I think perha ps I was 18 getting mixed up then with the PWR systems, whereby it 19 is the containment heat or the coolers. You are talking 20 a little different system.
21 WITNESS BURNS: Right.
22 JUDGE JORDAN: I see.
23 WITNESS EURNS: Yes, this is much different
() 24 than the PWR system.
25 JUDGE JORDAN So it includes the removal then O
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(} 1 of the heat from the suppression pool.
2 WITNESS BURUS: Yes.
3 JUDGE JORDANS Thank you very much. I think O 4 thst does explain it.
5 BY MS. LETSCHE (Resuming)s 0 0 Dr. Baras, the question I asked before the 7 break wass Are the accident classes that are set forth
~
8 in Suffolk County Exhibit 25 f or identifica tion with 9 respect to the Limerick PRA roughly comparable to the 10 accident classes in Table 4.1 of Suffolk County Exhibit 11 23, which is from the Shoreham PRA?
12 A (WITNESS BURNS) No, the classes are not 13 directly equivalent. The Shoreham PRA has rearranged 14 different sequences and re-identified potential releases 15 based upon additional calculations that had been done 16 subsequent to the Limerick PRA.
17 (Counsel for Suffolk County conferring.)
18 0 Are the definitions of those classes of l 19 accidents used in th'e two studies -- the name of what is 20 in class 1 and what is in class 2, setting aside the 21 differences in data? Are they the same, the definitions 22 of the classes?
23 A (WITNESS BURNS) No, the definitions of the
() 24 classes are not the same.
25 0 Are the definitions in the Limerick PR A of the O
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(} 1 classes , the accident classes, consistent with those in I
2 the PPA procedures guide?
i 3 A ( WITNESS BURNS) The procedures guides were I
(
4 issued prior to the Limerick PRA. There is no 5 standardized definition of what should be in a class.
6 This invention of classes is a totally new innovation 7 since W ash-1400 and is not in the PRA procedures guide, 8 and was only an attempt to make the calculation of 9 potential s6urce terms to release to the environment l 10 more accurate than was done in WASH-1400.
11 MS. LEISCHEs I would like to have marked as
[
12 Suffolk County Exhibit 25 f or identification a page f rom -
13 the Limerick PRA. It is page 3-100.
l
> 14 JUDGE BRENNER: This would be 26.
15 MS. LETSCHEs I am sorry, 26. This contains 16 Figure 3.5.4 entitled Comparison of the Contributing 17 Accident Sequence to the Calculated Frequency of Core 18 Melt from WASH-1400 and the Limerick Analysis.
19 JUDGE BRENNER. It will be so marked.
20 (The document referred to 21 was marked Suffolk County 22 Exhibit No. 26 for 23 identification.)
1
() 24 BY MS. LETSCHE (Resuming):
4 25 0 Dr. Burns, do you have a copy of what has been l
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE, S.W., WASHINGTON, D C. 20024 (202) 554-2345
l 5793 marked as Suffolk County Exhibit 26 for identification
{} 1 2 before you?
3 A (WITNESS BURNS) Yes.
O 4 Q Does Figure 3.5.4 on that document represent a 5 comparison between Limerick and WASH-1400 that is 6 comparable to the one contained in Suffolk County 7 Exhibit 24 which compa res Shoreham and W ASH-1400 ?
8 (Witness conferring.)
g
- A (WITNESS BURNS) As I stated before, the 10 Shoreham calculation was for core vulnerable condition, 11 and these two are calculations of frequency of core melt.
12 0 When you say these two, you are referring to.
13 the Limerick and the WASH-1400 probabilities on Suffolk 14 County Exhibit 26?
15 A (WITNESS BURNS) Yes.
16 A (WITNESS J0KSIMOVICH) I think you can view 17 Limerick as comparing apples and apples and Shoreham as .
18 apples and oranges.
l 19 JUDGE CARPENTER: Ms. Letsche, if I may, let 20 me be sure that I understand exactly. Looking at Figure i
21 3.6.6, are you saying to me that the legend should not 22 read simply " Core melt" but should read something else?
23 WITNESS BURNS: The legend reads " Frequency of
() 24 core melt from WASH-1400," that is true, in the Shoreham 25 analysis. And in order to get the definition of what O
ALDERSo*J REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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5794 the Shoreham analysis is, ! quess we.have to refer back
['} 1 2 to the text which states that the figure 3.6.6 provides 3 a comparison of the frequency of core melt f rom 7
(_) 4 WASH-1400 versus the frequency of core vulnerable 5 condition from the Shoreham PRA.
6 JUD3E CARPENTER. Where core vulnerable 7 includes those things that would lead to core melt in 8 addition to just core vulnerability?
9 WITNESS BURNS 4 Core. melt would be a subset, 10 yes, sir, but it would be a conditional probability that 11 given this set of circumstances f or Shoreham, that 12 additional recovery actions could take place prior to.
13 JUDGE CARPENTER: Recognizing that this piece 14 of paper that I have is labeled Draft Preliminary, since 15 I as a reader was confused, you might consider changing 16 the wording of the legend.
17 WITNESS BURNS: Yes, sir. .
18 WITNESS J0KSIMOVICHa If the pie were to be to cedrawn to be comparable , a pples to a pples, then this l
20 pie would have been smaller for Shoreham.
21 JUDGE CARPENTER: Thank you.
22 BY MS. LETSCHE (Resuming):
23 0 Would the pie, if redrawn for Shoreham, have
() 24 been smaller than the Limerick pie? That is, in Suffolk 25 County 26?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D C. 20024 (202) 554 2345 l
5795 l {} 1 A (WITNESS BURNS) I haven't drawn it. I am not 2 sure. I think maybe I should clarify the perception of 1
l 3 these comparisons. The f act that one circle is larger 4 or bigger than the other may be a little deceptive in I
5 that the uncertainty bounds on these calculations are l 6 larger than these diff erences.
l 7 So to draw a conclusion that the differences 8 .are large, I believe would be incorrect. I believe 9 these numbers are all.approximately the same. One might 10 get some relative feel, by comparing them, but I think 11 that in total, the overall conclusion is that these 12 numbers are low, and as low as was calculated in 13 WASH-1400. And at that time, that estimate was judged 14 to be somehow acceptable, an acceptable measure of risk 15 for the operation of nucicar power plants. And the fact 16 that these numbers are similar, one can interpret that 17 these also are acceptable measures. .
18 Again, I want to emphasize that the 19 differences here are small compared to the uncertainty 20 on these values.
21 A (WITNESS J0KSIMOVICH) May I add, if I were to 22 draw the pie for these type of purposes, then the 23 Shoreham pie would have been smaller than the Limerick
() 24 pie for these type of purposes.
25
(
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{} 1 0 I-guess I don't know what you mean, for these 2 types of purposes.
3 A (WITNESS J0KSIMOVICH) For the type of O 4 comparison that you are making in your head.
5 0 I'm not sure that I know what compa rison I am 6 making in my head.
7 A (WITNESS J0KSIMOVICH) Then maybe that is why 8 we are confused.
9 [ Laughter.)
10 0 If we were to ta lk sbout numbers rather than 11 the size of the pies, would the mean probability for 12 core melt at Limerick be larger or smaller than that 13 mean probability for Shoreham, roughly, Dr. Burns?
14 A (WITNESS BURNS) I'm sorry, I missed the 15 beginning of that.
18 0 If we tre talking about numbers rather than 17 the size of these pies, would the mean probability for 18 core melt at Limerick, which is on this exhibit, as I 19 understand it, be larger or smaller than the same 20 figure, the mean probability for core melt at Shoreham?
21 A (WITNESS BURNS) The calculated core melt 22 frequency for Shoreham would be less than either 23 WASH-1400 or Limetick.
() 24 JUDGE CARPENTER: Do you know the number?
-6 25 WITNESS BUPNS: It is between 5x 10 O
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-5 1 and 1 x 10 . It is in that range. I can't give you
[' }
2 a number off the top of my hesd.
3 JUDGE CARPENTER: You are saying you simply O 4 don't remember the comparable value?
5 WITNESS BURNS: Yes, sir.
6 JUDGE CARPENTER: Thank you.
7 BY MS. LETSCHE (Resumino):
8 Q Dr. Burns, in doing the analysis, the PRAs of 9 Limerick and Shoreham, was that based on an assumption !
! 10 that both of those plants complied with various NRC ,
11 regulations that were applicable?
12 A (WITNESS BURNS) Complied in the sense that in 13 the PRA we did not actually verify that all of the cable O( / 14 was placed in the correct cable trays. We did not 15 ve rif y tha t any environmental qualifications would have 16 required that that actually be done. We did not '
17 actually -- th a t there was in f act the required 18 separation of divisions. So in that sense the NRC has 1
, 19 required and the utility has a program to verify that ,
l 20 things like separation of electrical divisions are in ;
21 fact carried out. And yes, we did assume that, for 22 example, electrical divisions were separate and that P
23 electrical shorts in one division would not :suse
() 24 failure in a second division. [
j 25 0 Dr. Burns, since we don't have apples and l l
l i I
i ALDERSON RLPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W.. Y/ASHINGTON, D.C. 20024 (202) 554-2345
5798 apples to talk about in these pies with Shoreham and
(]) 1 2 Limerick, maybe you can tell me anyways did the 3 distribution of the contributing accident sequences vary 4 as to which ones were dominant between Limerick and 5 Shoreham?
6 A (WITNESS BURNS) Limerick as analyzed in the 7 original draft PRA, which this is a copy of and as was 8 published in March of '81 was substantially different 9 than the Shoreham plant in at least two areas, so 10 therefore one would expect that -- in three areas. One 11 would expect that the distribution of dominant sequences 12 would, in fact, be different.
13 0 Mr. Kascsak, in your analysis and review of 14 the Limerick PRA, did you review any of the hardware 15 differences between Limerick and the Shoreham plants?
16 A (WITNESS KASCSAK) If you are referencing back -
17 to Section 5 of the testimony, which I am assuming you 18 are in the question you are directing to me, which is 19 the previous location where the Limerick analysis came 20 up, the reason for that, the feeling of comfort we had 21 in that Limerick analysis was rela ted to the 22 confirmatory aspects of that analysis in terms of the 23 design process and that we are familiar with the methods
() 24 that were used in the analysis at Limerick, and that we 25 did evaluate or model a plant similar to Shoreham in O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5799 l
design, and at least many of the features tre similar
(]} 1 2 and certainly the design relative to the G.E. design l 3 process. The G.E. design processes that were used at 1
( Limerick were the same processes that were used at
, 4 i i
5 Shoreham.
l 6 The fact that the PRA methodology does look at 7 how systems functionally interact, how they spatially ,
8 interact, and to the extent tha t if the support systems ;
)
9 functionally or the ventilation systems spatially would ,
10 affect the probability of how the plant sequences 11 contributed to risks and if~there were dominant 12
- sequences where those interactions took place and they l 13 would be discovered through tha t analysis.
l 14 And in reviewing the analysis it was ;
l 15 determined that those types of interactions did not take 16 place in an atypical or a disproportionate way. We took 17 comfort in knowing that the design process does produce 18 a plant that does tot give you the types of systems 19 interactions that would be evaluated through this 20 methodology.
21 So it wasn't an explicit, detailed familiarity 22 with the Limerick design that gave us comfort; it was 23 the matching of the two methodologies, the fact that the
() 24 PRA assessment methodology verified the design process 25 and, in fact, produced a good design and that there was O
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() 1 no system interactions that gave you atypical results.
2 That is how it was used in the context of Section 5.
3 JUDGE BRENNER: Mr. Kasesak, that was a rather 4 long ansvar and perhaps it would be appropria te as an 5 explanation to you answer to the question, but I don't 6 think you answered the question, and I don ' t think the 7 question calls for that long of an answer. We are 8 having trouble grappling with generalities in questions 9 and we also have trouble grappling with generalities in 10 answers. .
11 Could you restate your question, Ms. Letsche?
12 And I just want an answer to the question. We have 13 heard the explanation now. Go ahead.
O 14 BY MS. LETSCHE. [ Resuming) 15 0 In your review of the Limerick PRA results, 16 did you consider any hardware differences between the 17 . Limerick plant and the Shoreham plant?
18 A (WITNESS KASCSAK) We didn't perform an i
19 explicit review of the Limerick results. We are aware 20 of the fact that there are some differences in design 21 assunptions in the two analyses, but we did not review 22 those results in any great detail.
23 0 Well, Mr. Kasesak, you said tha t you a re going 24 to use this PBA for design verification, right?
25 A (WITNESS KASCSAK) The Shoreham PRA, that is O
ALDERSGN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 correct.
2 0 And that the Limerick PRA gives you comfort as 3 to the quality of the design; is that right?
4 A (WITNESS KASCSAK) That is true, and that is 5 what I was attempting to clarify, that the methodology 6 and processes that are used in doing the analysis is 7 what gives us comfort, not in th e re sults itself.
8 Q Can you explain to me how you know that any of 9 those results are even applicable to Shoreham if you 10 don't know that there are differences in the design?
11 A (WITNESS KASCSAK) As I said, we are familiar 12 with some of the dif f erences in the design, but it is 13 the fact that there was nothing unusual that came out,of O'~ 14 the results. There were no interactions that were 15 unusual. Certain of the dominant sequences, ATWS being 16 one, is the result that would be expected. So in that 17 respect we would expect ATWS to be one of the dominant 18 contributors to risk. And now you have to look at the 19 overall effect of that risk on the plant and consider 20 the site aspects of how that particular event sequence 21 affects the overall risk of the plant.
22 But in considerstion of unique-type sequences, 23 sequences that may not be typical or that may be unique l () 24 to a BWR-IV design or whatever, it is those types of 25 things that in looking at tne results we did not see, O
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5802
()
1 and because we did not see those types of results, it 2 gave us comfort that the design was in fact, from G.E.'s 3 point of view, at least, and how those design processes 4 influenced the Shoreham design were in fact producing 5 good results.
6 A ( WITNESS J0KSIMOVICH) May I add we take 7 comfort --
8 JUDGE BRENNEP4 As f ar as I am concerned, you 9 can.
10 .MS. LETSCHE: I would prefer to pursue this, 11 at least that last question, and maybe a little further 12 with Mr. Kascsak.
13 JUDGE BRENNER: And then we will come back.
O 14 MS. LETSCHE Certainly, we can come back to 15 Dr. Joksimovich. -
16 JUDGE BRENNER: Let's do it that way, if you 17 can save it.
- 18 BY MS. LETSCHE (Resuming)
l l 19 0 Mr. Kascssk, what is it you were looking at in 20 making and reaching your conclusion that --
I forget l
l 21 Your exact words, but that there wasn't anything in the 22 design that you needed to worry about?
23 A (WITNESS KASCSAK) Well, as I just stated, if i
( 24 the results of the analysis concluded there was some 25 unique sequence of events that produced a risk that O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINfA AVE., S.W., WASHINGTON, D C. 20024 (202) $$4 2345
5803 1 would not have been expected, a support system, for
(}
2 example, or a ventilation system produced a failure that 3 led to core melt, that wouldn't have been expected, and 4 you would have further evaluated why that had occurred 5 and looked at the design that produced that r e s ul t.- and 6 you would have further evaluated the design process to I
7 see why that in fact took place.
8 0 Well, if you didn 't look specifically a t any 9 design differences between Limerick and Shoreham, how do 10 y.ou know that something unusual didn 't happen at 11 Limerick?
12 A (WITNESS KASCSAK) Well, because the analysis 13 shows the dominant sequences that 1.ead to core melt, and 14 if those dominant segunces would have showed something 15 that was, as I say, disproportionate or unique in terms 16 of what you would.have expected, then you would have 17 further evaluated why that would have occurred.
18 MR. ELLIS. Let me, if I may, just interject 19 an objection to the question, in part because I don't 20 think an answer has been given but the question assumed 21 that Mr. Kascsak did not look a t dif ferences, and Mr.
22 Kascsak I don't think answered that question but has 23 said that he is aware of differences. Therefore, I am
() 24 not sure tha t the question as Ms. Letsche stated it 25 accurately reflects the testimony.
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5804
(} 1 JUDGE BRENNER: Well, that is the question she 2 has been trying to ask hin in a series of questions.
( 3 MR. ELLIS4 I understand that, and I think I
l
() 4 wha t he has said is that he is aware of it, and I l
5 acknowledge that he has not directly answered it.
i l 6 JUDGE BRENNER: Well, if that is an objection, 7 I am going to overrule it. There wa sn ' t a pending 8 quastion at the time. You can figure out later whether 9 you think he answered it or not. He purported to answer
(
l
. to it, and I have got my own view of what he said and I j' 11 think the questions were a reasonable follow-up.
12 Maybe I had better be less elliptical. I 13 think he said he didn't look at differences, and if you O 14 think he did, you had better come back on redirect.
15 MR. ELLIS: I will because I think he 18 testified that he said he was aware of differences.
17 JUDGE BRENNER: That is different than what I 18 said. But go ahead, Ms. Letsche.
19 BY MS. LETSCHE (Resuming):
20 0 Mr. Kascsak, there are differences in the l
21 dominant sequences between Limerick and Shoreham; isn't 22 tha t right?
23 A ( WITNESS K ASCSAK) That's correct.
() 24 0 And have you analyzed the* reasons for those differences? O 25 O .
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5805 O i ^ ( *1rs tss x^s cs^t< > we te ere or ar taere 2 are differences, yes.
3 Q Are any of those related to hardware 4 differences?
5 A (WITNESS KASCSAK) Yes, they are.
6 0 What ones are those? What are the hardware 7 differences that you are aware of?
8 A (WITNESS KASCSAK) Well, the two main 9 differences are that the Limerick PBA assumed that they
. to would have an ATWS-3-A mitigation system and that they 11 would have containment vent.
12 JUDGE JORDANS I am sorry. They would have an 13 ATWS what?
O 14 WITNESS KASCSAK: ATWS-3-A. That is an
- 15 autoboron injection system.
16 JUDGE JORDAN: At Limerick?
17 WITNESS KASCSAKs At' Limerick, that is correct.
18 JUDGE JORDAN: And the other one?
19 WITNESS KASCSAK Was at least initially they 20 had considered adding a containment venting system where 21 they would vent the containment for overpressurization 22 concerns.
23 (Pause.)
24 I think, again, maybe the reason you ibat you 25 are not assuming I am snswering the question is because O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5806 again I guess I am trying to stress, and maybe not doing
(]) 1 2 a very good job at it, that the importance is the 3 dominant sequences and how the plant responds to these 4 accidents and tra n sien ts , and the analysis through its 5 methodologies shows you which ones of those sequences 6 are important contributors to risk, and we can look 7 quickly to see what those important contributors to risk 8 are relative to WASH-1400 or other analyses to see if 9 there is anything unusual coming out of the analysis 10 without even having to know the intricate details of the 11 plant.
12 Now, we are aware of some of the differences 13 between,Shoreham and Limerick, but I am saying you don't A
\l 14 have to be intimately aware of those differences to see 15 that these other sequences, the ones that would be 16 atypical, do not exist in terms of the results of the 17 analysis. So th a t to reach the conclusions we reached, 18 we didn 't have to be intimately f amilia r with Limerick.
19 But the fact is that we are in fact familiar 20 with the differences, some of these major design 21 differences. Well, not major, but some of these 22 different assumptions that went into the analysis that 23 do contribute to why the pie and the contributions to
() 24 frequency of core melt are different between the 25 plants. But even with those differences, the dominant O
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() 1 sequences in terms of the entire context is not that 2 much different.
3 BY MS. LETSCHE (Resuming):
4 Q Let's talk about the sequences.
5 3R. ELLIS: May I ask whether this is an 6 appropriate time to let Dr. Joksimovich adi ? Are you 7 going on to something else?
8 MS. LETSCHE: Tha t is fine. If you want to add 9 something, go ahead.
10 WITNESS J0KSIMOVICH Thank you. The issues 11 of comfort that we take f rom the Limerick study, we take 12 the comfort from the Limerick study because the Limerick 13 study has not identified any major risk outlier which, O 14 if they did do that, then that would have been ringing -
15 the bell all over the country and everybody would have 16 known about it, and in particular since the study now is
~
being scrutinized by a couple of national labs working I 17 18 under the NRC's direction, and it is in that direction 19 that we take the comfort.
20 We take the same comfort that no major risk 21 outlier has been identified in the Shoreham study that I 22 put into my original prefiled testimony, and I still 23 stand by that.
() 24 Bf MS. LETSCHE (Resuming):
25 Q Mr. Kas:sak --
O j
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' I O i avoct satsuza, aust eme me eet.
2 0 4 5
i
(
7 8
9 10 11 12 13 O 14 15 16 17 l
l 18 19 i
20 i
21 22 23 24 .
25 O
ALDERSON REPORTING COMPANY, INC, l
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5809 1 (Board conferring.)
{}
2 JUDGE CARPENTER: If I could ask a question 3 while the Board is conferring. Is your poirt, sir, tha t 4 the Limerick study's review process is much nore 5 advanced than the Shoreham study?
6 WITNESS J0KSIMOVICH: Obviously, because the 7 study was completed in March of 1981, and it is on the 8 docket for the Linerick application. The Commission --
9 JUDGE CARPENTER: As I said two weeks ago at 10 427, I am not very familiar with the Limerick study, and 11 I am not sure it is being litiga ted here. I just simply 12 wanted a yes or no answer. Is the review of Limerick 13 substantially completed, or is it much more extensive 14 than Shoreham?' That is the basis for your using it as a 15 point of reference.
16 WITNESS J0KSIMOVICH: It is more advanced than 17 Shoreham is, simply because of the time difference.
18 JUDGE CARPENTER: Fine, thank you.
19 BY MS. LETSCHE (Resuming):
20 0 dr. Kascsak, hardware differences could result 21 in different -- let me rephrase that.
22 If there were different equipment at twc 23 different plants, they might react to a given transient in a different way, isn't that true?
(]) 24 ,
25 A (WITNESS KASCSAK) You would have to look at O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON, D C. 20024 (202) 554-2345
5810 1 the detailed design of the plant to see how systems
(" }
2 would respond to different sequences of events.
3 0 Depending upon the differences, one might O 4 recover quickly from a transient, whereas another might 5 recover more slowly. Is that right?
6 A (WITNESS KASCSAK) Hypothetically, I guess that 7 is true.
8 0 And in one case there might be systems 9 interaction that would go on, whereas in another case 10 there might not be, right?
11 A (WITNESS KASCSAK) Conceivably.
12 0 And in some cases, a systems interaction might 13 result in making the plant recover quicker, and in 14 another it might end up making the transient go on a lot 15 longer or be a lot worse, is that right?
16 A (WITNESS KASCSAK) Again, you would have to 17 look at the specific model of that plant. That is true.
18 0 Have you looked a t the Limerick plant to 19 determine if there are any differences that would result 20 in any of these things we just talked about, compared to 21 Shoreham?
22 A (WITNESS KASCSAK) In a limited sense, yes.
23 Not in a complete sense.
() 24 0 What did your review consist of? ,
25 A (WITNESS KASCSAK) The review of the two lines O
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{) 1 of the Limerick PRA plus discussion with the electric 2 personnel.
3 0 Did you ssk them about any specific hardware O 4 dif ferences in the plant?k 5 A (WITNESS KASCSAK) Yes, we discussed some 6 differences between systems at Shoreham and Limerick.
7 0 And what did you conclude based upon those 8 discussions?
9 A (WITNESS K ASCS AK ) There are some differences.
10 0 Did you make a determination as to whether or 11 not any of those differences would be -- would result in 12 systems interactions in one plant and not in the other?
13 A (WITNESS KASCSAK) I would say generally, the 14 ones we talked about, there would not be any 15 differences. The reason we are doing a Shoreham PRA is 16 to evaluate the Shoreham-specific response and to take 17 into account the Shorehas-specific design relative to 18 systems interactions. We can take comfort in the I
i 19 Limerick analysis relative to the adequacy of the GE 20 design processes and how that produces a plant, again, l
21 that appears to have no unacceptable risk.
22 And we wanted to confirm that that was, in 23 fact, true also for Shoreham, and that is why we are
() 24 doing the Shoreham analysis. ,
l 25 0 But you were really looking at the GE designed
)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5812 parts of the plant? Is tha t all you were looking at?
(]) 1 2 A (WITNESS KASCSAK) No, we were looking at the 3 overall plant.
O 4 JUDGE BRENNER: Ms. Letsche, at some point are 5 you going to ask the other witnesses on the panel as to 6 why they can draw comfort -- if you use that ph ra se , or 7 perhaps somebody could come up with a better phrase --
8 from the results of the other PRAs that are cited in 9 their testimony -- that was Limerick, among o th ers --
10 given the differences?
11 MS. LETSCHE: Yes. If you would like to ask 12 that now, we could do that.
13 JUDGE BRENNER: Yes, I would like to. Well, 14 that is the q'uestion, Dr. Burns, or Dr. Joksimovich.
15 The direct testimony, not necessarily your sections, 16 although I don't think it is inconsistant with your 17 sections, but in any event, portions of the direct 18 testimony refer to the Limerick PRA as one of the 19 probabilistic approach studios.. In the context of 20 d ra wing comfort from the results, that there were no 21 surprises there, to use my term.
22 Given the fact that the two plants have some 23 differences and the PRAs, in fact, have some
() 24 differences, some of which ,were stated here today by Dr.
25 Burns, how can you draw comfort from that comparison.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S W., WASHINGTON. D C. 20024 (202) 554 2345
5813 1 And then my further question is what does all of that 2 tell anybody in the context of ascertaining whether the 3 PRA is a proper check of system s classifica tions, taking O 4 into account systems interactions? That is a 5 long-winded question, but I will leave it at that. If 6 you want me to break it down further, I will.
7 WITNESS BUPNS. I guess I would rather not 8 hav.e you say I took comfort from. My direct testimony 9 on this issue said that we have used or read or examined 10 other studies that have been performed in order to give 11 us additional information on what other people have 12 found regarding systems interaction and potential common 13 cause failures. And in that context, Limerick was
( 14 reviewed to see if any systems interactions, common 15 =ause failures, have been found at that plant which 16 would also be applicable at the Shoreham plant.
17 The Shoreham study itself I think should be 18 viewed sepsrately from these other studies. There is no 19 information in the Shoreham PRA that is dependent upon 20 any of these other studies. The methodology has evolved 21 along various paths over the years since WASH-1400.
22 There has been a great deal of development in both the 23 national laboratories and the reactor vendors and other
(]) 24 consultants to dev,elop these techniques.
25 And I don't think that the limerick PRA has D)
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{) 1 any direct impact on the Shoreham PRA, other than it was a forerunner or a place where this methodology was 2
3 applied on a separate plant. The plant happened to be O 4 very similar to Shoreham, and therefore, to a arge 5 extent, one can view those as similar. But u' a t is not 6 a necessary conclusion; it is not even -- it may not 7 even be relevant.
8 The systems interaction portion of the PRA, or i 9 the event tree / fault tree analysis that was performed 10 for Shoreham, was discussed in the pre-filed testimony 11 and identifies in the attachment, Attachment and Tab 12 Number 6, which is a table -- it defines how we 13 proceeded in establishing what the dependencies would. .
14 be, and we did focus on functionally Ocupled systems 15 interaction to a very large extent, since this is where 16 PRA methods ha ve been used in the past most .
17 successfully. And this table lists the event trees that 18 were used and the initiating events that were examined.
19 In sddition, it also discusses what the shared 20 systems were that were examined, using primarily fault 21 tr?e tachniques as a method of examining, both 22 qu alita tively and quantitatively, what were the systems, 23 what were the components within those systems that could
() 24 lead to failure of multiple systems.
25 We also looked at potential failures of A
%)
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5815
() 1 components because they were all the same. In other 2 words, diesel failure rate may have a higher -- multiple 3 diesel failure rates may be higher than single failures O 4 because as the industry data has shown, there have been, 5 in fact, multiple diesel failures, and similarly, 6 nultiple component failures of the same type. That was 7 all incorporated in the model in order to calculate 8 whether tha t increased frequency of multiple failures 9 would, in fact, result in degradation of the systems to 10 the point where a potentially dominant risk may result.
11 In addition, we added human coupling into the 12 fault trees to define where the operator interfaces with 13 each of th e systems. Where is he required to initiate 14 the system, is it possible for him to adversely impact 15 the system during a maintenance operation that would 16 defeat the system when it is required; and then also, 17 whether the systes could be out for maintenance during a 18 required demand.
19 We also did do some spatial dependencies, 20 although this was probably the area where we depended or 21 one dep' ends upon s deterministic analysis more.
22 Although in this context, we have to note that this is 23 not an external events analysis; it is only internal
() 24 , events. So from that point, spatial dependencies were 25 covered adequately, using that qualifier.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5816 We did also include postulated flooding of
[]} 1 2 ele vation 8 of the reactor butiding, interfacing LOCAs 3 outside the reactor building which could adversely O 4 impact ECCS equipnent there, and potential containment 5 leakage during cases where we had high containment 6 pressure, internal pressure.
7 All of these things were factored into the 8 model, and then we tried to define what was the result 9 in terms of dominant sequences. Were there, given all 10 of these dependencies among systems, were there 11 sequences that could be identified that contributed 12 dominantly to the overall risk. And, in fact, there are 13 some subsets of sequences that one can iden tif y that, in '
/'N.
(-) 14 fact, appear to be dominant contributors to risk.
15 The question of whether that risk then is 16 acceptable or not is a separate question. I think I can 17 state, based upon a review of results of other studies 18 like RSSMAP, like WASH-1400, --
19 JUDGE BRENNER: What was that study?
20 WITNESS BURNS: The Reactor Safety Study 21' Methodology Application Program that was performed by 22 Sandia for the NRC. Those studies indicate that there 23 is a certain level of risk associated with operating a f
() ,
24 nuclear power plant. In the calculations for Shoreham 25 thus far, they have indicated that combining all of the i
l l
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() 1 dominant sequences, that calculated frequency for 2 Shoreham is comparable to that numser.
3 JUDGE BRENNER I can see why, in doing the 4 PRA, you are interested in the result of getting to the 5 dominant sequences, along the lines you just outlined.
6 If one is also interested in looking at systems 7 interaction to determine whether systems are properly 8 classified or whether other measures should be taken, 9 leaping to the dominant sequence result would skip over 10 other items that might be of interest to somebody 11 looking for systems interaction.
12 That is, you could have potential systems 13 interactions for which one should consider whether or 14 not to take measures. Now, the result might be measures 15 would be appropriate or would not be sppropriate for 16 various reasons of the function of a complicated 17 calculus of what the risk was, what it would take to 18 solve the problem and so on. But that interaction might 19 never show up in the dominant risk conclusion, yet still 20 would be a candidate for consideration as to systems 21 interaction. Can that be picked up in a review of your 22 PRA for Shoreham?
23 WITNESS BURNS: All of the information that
(') 24 one needs to define th e se particular dependencies that 25 are outlined here are included in the PRA. So yes, one O
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(")
\_J I could pick up whatever is cited here.
2 In other words, as I stated before, things 3 like high energy pipe breaks, which we did not look at, 4 are not in here. But everything that is cited here, 5 even though they are not dominant contributors, are 6 possible to pick up from the matrices that we used in 7 Appendix B. And from the cut sets of the fault trees.
8 JUDGE BRENNER: So if I could understand why 9 you would want to look at other studies that were done 10 to see if there are any outliers, and in fact, I suggest 11 you would undoubtadly be criticized if you didn't make 12 that look. And had you found something unusual, it 13 certainly would ha ve made sense to follow up to see what O
\- 14 lesson from that should be applied to whatever you are 15 studying. In this case, Shoreham.
16 However, it does not follow that where you 17 conclude that the results, in terms of overall risk or 18 in te rm s o f a summary of the dominant contributors to 19 risk, are similar it does not then follow that there are 20 no systems interactions which should be considered.
i 21 That is, because you are only comparing the overall 1
22 results in terms of dominant risks, dominant 23 contributors to risk, and not backing up to take a look at how you got to those dominant contri butors through
[v) s 24 25 the fault trees. Am I right?
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5819 Q 1 WITNESS BURNS. Yes, that is very true. There 2 is no question that one of th e very difficult problems
- 3 n. _Jentifyinq systems interactions is what criteria do O
4 you use to say when does one system interact on 5 snother. And there are cases in the PRA where one can i 6 clearly identify systems that are affected by other 7 systems.
8 The criteria that is used here is a numerical 9 basis, a quantification of risk or core melt frequency; 10 some measure of sa fety ba ed upon a quantitative 11 assessment. If there was another criteria, we could -
12 apply this technique to that criteria, but I don't knov 13 of any other criteria.
14 15 16 ,
i t
17 18 ,
19 20 21
?
22 23 24 2 25 i
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5820 JUDGE BRENNER: That is consistent, I think --
(]) 1 2 and I will ask for your confirmation -- with your
- 3 testimony some time ago that among other things, you 4 believed the PRA techniques are a very useful approach 5 to bring together and display all of the information 6 that exists, but unless you have defined criterias as to 7 what you are looking at and unless you have sufficient 8 data base and knowledge as to what you are looking at 9 you would be reluctant to take it too far in certain .
10 areas.
11 'd IT N ESS BURNS: Yes, sir.
12 MR. ELLISs Judge Brenner, could we let Dr.
13 Joksimovich respond to those questions, too?
14 JUDGE BRENNERa Yes, in a moment. And I 15 certainly don't mean to limit him. And the only reason 16 I say in a moment is I don't want to lose my thought.
17 A logical followup which I think Judge Morris 18 is going to ask you about when the Board questions come 19 around, taking into account your recommendation that we 20 not dwell on the comparison too much between Shoreham l 21 and other PRA's except to the extent you indicated of 22 making sure there wasn't anything unusual that you 23 should look for, is that if we want to focus on what you 1
() 24 found so far in the Shoreham PRA, not in terms of the 25 detailed quantification, but in terms of what we should
( ;
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{} 1 do about systems interactions and classification, you've 2 got a sentence on page 104 of the prefiled testimony 3 that, to my astonishment, nobody has asked you about O 4 yet, stating that SAI, meaning you primarily or 5 including you, has identified a number of potential 6 system interfaces and dependencies *which it would then 7 incorporate into the Shoreham PRA framework in a 8 plant-specific manner, and so on and so forth.
9 Rest assured, somebody will ask you about that 10 before we let you go. And I only wanted to take the 11 opportunity to mention that now.
12 I don't want to diverge any further from the 13 County's questioning at this point. But yes, if any 14 other members of the panel want to add, they are welcome 15 to do so, so long as it is to the questions as opposed 16 to something else you want to say.
17 WITN ESS J0KSIMOVICHs Well, you covered a 18 broad ground, so I took a few notes, and they are not 19 100 percent foolproof, so I will try to address the ones 20 that I thought you were highlighting.
21 JUDGE BRENNER: It was a very broad ground, 22 you are correct.
23 WITNES3 J0KSIMOVICHs I said before and I will restate that we take comfort when we look a t a
(]) 24 25 particular study, providing it is credible, whether O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5822 there are some risk outliers or not. And hence, when we
(]) 1 2 looked at the studies like limerick, we didn't see any.
3 And the same applies to Shoreham, as I have stated on O 4 page 79 of my testimony.
5 The second thing that we take comfort in is to 6 compare the results versus WASH-1400, and the reason why 7 we do that is simply that WASH-1400 has been around for 8 seven years. It has been reviewed by everybody, 9 p ra c tica lly , in the business. Professor Lewis' 10 committee was formed to pass a judgment on the quality 11 of the document. His one-year investigation resulted in 12 the report which we are all familiar with.
13 The reactor safety study has been duplicated 14 in the Federal Republic of Germany and it is known over 15 there as DRS, which is Deutsche Risko Studie. I believe 16 they have spent a comparable amount of effort in the 17 Federal Republic of Germany as has been done for 18 WASH-1400.
19 Numerous other countries have reviewed 20 WASH-1400 in great detail. So it is probably the most 21 reviewed study of all, and hence it is always advisable 22 to look at where you stand versus a study that has been 23 reviewed by practically everybody in the nuclear safety
(]) 24 business.
25 That is why I personally and many of us in the l
l l
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5823 business have a great deal of comfort when we see that
{]) 1 2 the results are comparable. That is my second point.
3 The third point is, when I look at the result O 4 of the study I do want to see whether there are some 5 unique systems interactions, and I haven't seen any in 6 Limerick, nor have I seen any on Shoreham. And if they 7 did exist they would have been shown in the risk 8 outliers.
9 And if they were, if they were shown in the 10 risk outlier, I think that the whole community would 11 have been alerted to that, and in particular if it 12 involved a non-safety grade system I think that NBC 13 would have been alerted, I think that General Electric i
/")
(_- 14 would have been alerted if it was their product line, 15 since that's what we're talking about here. I think -
16 tha t the BWR owners group would have been alerted. I 17 think that LILCO and Philadelphia Electric would have 18 been alerted to that, and I know both utilities and 19 hence they would have taken some action to review the 20 importance of that system versus the systems they have 21 used in the past without knowing that.
22 So this would be a new kind of information 23 that would force me to consider the importance of that
() 24 system, is it really a non-safety grade system, if it is 25 a significant contributor with regard to some risk O
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1 outlier.
[}
2 The last statement you made is that one could 3 lea p over some systems interactionss and, yes, one can.
O 4 But those sequences are likely to be important risk 5 contributors. And when I say risk, I mean public risk 6 contributors.
7 Now, some of these sequences may be important 8 contributors to what I call investment risk s, and that 9 is a totally different subject. That is a subject where 10 you can have the plant down for an extended period of 11 time and hance the utility economics can be hurting, but 12 there will be no release of radioactivity and hence 13 there will be no public injury involved.
() 14 And I think that the way I understand those 15 type of sequences they are outside the regulatory .
16 process. The regulatory process protects the public and 17 is not protecting the investment of the utility. And 18 sometimes people are looking into PRA studies that we do 19 for public safety purposes and they are trying to find 20 these, what I call investment sequences, and they are 21 not there, for a very good reason: because we haven't 22 focused on that.
23 If we were asked to focus on them, we would
() 24 and we would identify them in the same way that we 25 ide ntif y the important ones to the public safety O
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I 5025 1 considerations.
2 JUDGE BRENNER: I don't want to take too much 3 tise away, but you talked about a unique systems O 4 interactions problem would have shown up as a risk 5 outlier. And I tske it that s risk outlier would be one 6 of the contributors, the dominant contributors to 7 o ve rall risk; is tha t how it would show ue?
a WITNESS J0KSIE0VICH. Yes, it would stick 9 out. The best thing to do is to compose what I have 10 called an F-C diagram, where F stands for the frequency 11 snd C stands for the consequence. And you can have all 12 sorts of consequences in mind. You can have health .
13 effects, you can have curies of radioactivity, and 14 whatever you want to do.
15 But if you plot your results in the F-C 16 disgram, then you will get a point which is going to 17 stick out from the bulk of the other points, that would 18 be obvious from that diagram.
19 JUDGE BRENNER: Would it have to be a unique 20 systems interactions problem or would not the same thino 21 show up even if it was a systems interactions problem 22 common to other GE plants also?
23 '4ITN ESS J0KSIMOVICH: I'm sorry, I didn 't
() 24 understand that.
25 JUDGE BRENNER: Your original ststement was O
ALDERSON REPORTING COMPAh f, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
5826 1 thst if there had been a unique systems interaction
[}
2 problem it would show up as a risk outlier, and you just 3 further amplified. I don't know what you meant by risk O 4 Dutlier. I'm focusing now on the word " unique" 5 modifying " systems interaction."
6 I guess I'm worried about a common systems 7 interactions problem, one that is common to Shoreham as 8 well as other GE plants. Would that also show up in the e PRA study as an outlier?
10 WITNESS J0KSIMOVICH: Well, that is one of the it reasons why I have heavily supported a review of the 12 operating experience, because I think that all of the 13 knowledge that we have acquired in doing PRA studies has 14 to be supplemented with thorough reviews of the 15 operating experience. And unf or tuna tely, that kind of 16 stuff has not been done prior to the Three Mile Island 17 accident, and as a result of the Three Mile Island 18 accident a number of institutions have come up with 19 programs to do that, and I think that is an invaluable -
20 addition towards our assurance that unique systems 21 interactions have been identified, if not by the PRA 22 studies then somehow they are thrown into what I call 23 precursors.
() 24 Because a thorough review of the operating 25 experience -- because none of these events, by the way, ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5927 l
l
{) 1 which have happened in the opera ting experience have 2 resulted in any significant release of radioactivity.
3 But what they have pointed out, they have pointed out 4 that they could be precursors for a release, and hence 5 they have been caught at an early stage.
6 And as a result of that, attention has to be 7 given to those, and sometimes it is not easy to review 8 thousands and thousands of documents to find which ones
.9 are important, and that led to my recommendation to 10 LILCO to take a surrogate plant like Fitzpatrick and 11 look at the operating experience of Fitzpatrick, because 12 there could be some idiosyncrasies of the combination of 13 General Electric and Stone & Webster design that didn't
() 14 show elsewhere.
15 JUDGE BRENNERs All right. I'm not sure --
16 that was helpful, but I'm not sure I got an answer 17 specifically to the question. And I'm sure it is the 18 way I asked the question.
19 Putting aside the operating experience -- and i
20 I anderstand you don't want to put it aside, but just 21 for the purposes of the question -- would a common 22 systems interactions problem, that is common in the 23 sense that it would also exist at other GE plants also, which would be of concern for overall risk, also show up
(]) 24 i 25 as a risk outlier for the Shoreham PRA, or would only O
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5828 1 Shoreham-unique systems interactions problens show up as 2 a risk outlier in the Shoreham PRA?
3 WITNESS J0KSIMOVICH. Both of them would.
O 4 JUDGE BRENNER: All right. You have got about 5 ten minutes, Ms. Letsche.
6 BY MS. LETSCHE (Resuming) 7 0 Dr. Joksimovich, to follow up quickly with 8 respect to your last answer that both of those systems
, 9 interactions would show up in the Shoreham PRA, that ,
10 would only be true if they were high probability events, i 11 rig h t?
12 A (WITNESS J0 KSIM OV IC,H ) That would be true if 13 they were important risk contributors.
() 14 0 So if they were high risk, if there was high 15 risk associated.vith them?
16 A (WITNESS J0KSIMOVICH) That would be true if 17 they were important risk contributors, and I already 18 sta ted about -- that there were others which I included 19 in the class of investment risk, which is a different l It is of importance to the utility because it 20 class.
i 21 03n cause immage, but it doesn't damage any member of 22 the public.
23 (CJJnsel for Suffolk County Conferring.)
() 24 0 Dr. Joksimovich, if a particular subsystem in 25 which there might be a systems interaction has not been l (
I I
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1 modeled in the faalt tree, then that pa rtic ula r
(}
2 interaction wouldn't necessarily be reflected in the 3 risk?
( 4 A (WITNESS J0KSIMOVICH) It wouldn't, but it's 5 very unlikely that system would ha ve any relevance.
6 0 I'm sorry, I didn 't hear that.
7 A (WITNESS J0KSIMOVICH) I said it wouldn't, but 8 tha t system probably wouldn't have much relevance.
9 Otherwise it would have been looked at. ,
10 (Counsel for Suffolk County conferring.)
11 0 So, based upon what you've just said, wouldn't 12 this ground discharg.e volume problem that has in fact 13 occurred have been picked up through a PRA?
( 14 A (WITNESS J0KSIMOVICH) Well, at the risk of 15 repeating myself, the Browns Ferry incident didn't 16 result in sny release of radioactivity, and hence it was 17 a benign event from that standpoint. Now, the 18 significance of that event is that it could be a 19 precursor for something which could come, and so we are 20 taking note of that event as a precursor and we are 21 treating it as a precursor, and that is why I think NRC 22 and the nuclear industry have reacted to that.
23 (Counsel for Suffolk County conferring.)
() 24 Q So it 13 true, then, that changes in the 25 frequency of an event, it is quite possible tha t they O
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5830 1 won't be picked up and fed into the PRA analysis until
{}
2 after they have occurred; is that right?
3 A ( W IT N ES S J0KSIMOVICH) The process of O 4 scrutinizing the safety of nuclear power plants is a 5 continuous process, it is a never-ending process. There !
6 is no room for complacency, that we think we have done 7 the job and nov we can go back up and do something 8 else. I plan to be around for another 20 years and 9 hence the process is going to continue. It is an 10 e ve r-se a rch ing process. There is no room for 11 complacency.
12 0 D,r. Joksimovich, would you consider as a risk 13 outlier an increased probability of failure of an
() 14 emergency core cooling system or other safe ty system?
15 A (WITNESS J0KSIMOVICH) It depends in what 16 context. I would not per se. On the other hand, you 17 would have to be more specific and show me what kind of 18 example you have in mind.
19 0 Well, when we're talking about risk outliers 20 my question is, are you limiting your discussion of risk 21 outliers that would stick out to some sort of newly 22 defined sequence that has a substantial contribution to 23 a risk, or would you also consider within your
() 24 definition of those risk outliers an increased 25 probability of failure of a safety system?
O ALDERSoN REPORTING COMPANY,INC, 4 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5831 Q 1 A (WITNESS J0KSIMOVICH) It would depend upon
, V -8 2 the increase. If it is, I don ' t know, from 10 to
-6 3 10 , then that wouldn't disturb me. But if it is
-4 -1 4 from 10 to 10 , that would indeed.
5 0 What percentage increase in your opinion, wha t 6 percentage would be sionificant?
7 A (WITNESS J0KSIMOVICH) This is highly 8 personal. I think if something goes up by about ten 9 percent, then that alerts me,to something to look at.
10 If it is one percent I do not ignore it. If it is less 11 than one percent I think that it is probably within what 12 I.would call the noise band.
13 JUDGE BREN!!ER: Ms. Letsche, what is the .
14 probability of your finishing today?
15 (Laughter.)
16 HS. LETSCHE: I think there are high error 17 factors in my estimate.
18 (Laughter.)
19 MS. LETSCHEa I really had thought I was going 20 to finish this afternoon and I don't have very much 21 more. But we are stopping at 4 :00, aren't we?
22 JUDGE BRENNER: Yes.
l 23 .15. LEISCHEs I don't think I will finish by
- 24 then.
25 JUDGE BRENNER: How much more do you have?
O ,
I.
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5832 MS. LETSCHE:
{) 1 I think probably only about a 2 half an hour.
3 JUDGE BRENNER: You looked at the clock and O 4 said, we are going to stop at 4: 00. And maybe it was 5 your tone of voice more than your words. I got the 6 impression you were going to say ten more minutes.
7 Well, we are not going to make it. If it had 8 been ten minutes or so, we would have run further. I g trust, Dr. Joksimovich, when you said you expected to be 10 around for 20 years, you didn' t mean here at this 11 hearing.
. 12 (Laughter.)
l 13 WITNESS J0KSIMOVICH: I'm not so sure about 14 that.
15 (Laughter.)
16 MR. ELLIS There 's a large uncertainty band.
17 (Laughter.)
18 JUDGE BRENNERa All right, we will adjourn 19 until 9:00 o' clock tomorrow morning.
20 (Whereupon, at 4:0 s.m., the hearing was 21 recessed, to reconvene at 9:00 a.m. on Wednesday, July 22 7, 1982.)
23
(]) 24 25 O
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)
O ,
" " " " " " ' " " """ 5 ' " !
Tnis is to certify tnat the attached proceedings before the ;
BEFORE THE ATOMIC SAFETY & LI2ENSING BOARD in the satter of; Long Island Lighting Company (Shoreham Nuclear Power
$tation) ,
Da.te o f ?roceeding : July 6, 1982 l Decket s
Nu=ber: 50-322 OL Place of Proceeding: Riverhead, New York were held as herein appears, and that this is the original transe:-1pt !
thereof for the file of the Coc:=1ssion.,
Ray Heer Official PJeporter (Typed) na ;
OfficiaM eporter (Signature) l O
e e
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