ML20058G089
| ML20058G089 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/30/1982 |
| From: | LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8208030199 | |
| Download: ML20058G089 (203) | |
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In 9.e .V.*:2r 2 cf: :
LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL (Shoreham Nuclear Power Statation) :
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I DATE: July 30, 1982 PAGES: 8514 - 8686 A;; Riverhead, New York
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%j 1 UNITED STATES OF AMERICA 2 NUCLE AR REOULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
5 ------ ---- ------
-x 6 In the Matter of 7 LONG ISLAND LIGHTING COMPANY Docket No. 50-322-OL 8 (Shoreham Nuclear Power Station) :
9 - - - - - - - - - - - - - - - - -x 10 Riverhead County Complex 11 Legislative Hearing Room 12 Riverhead, New York 13 Friday, July 30, 1982
'~) 14 The hearing in the above-entitled matter 15 convened, pursuant to notice, at 8:35 a.m.
16 17 BEFORE:
18 LAWRENCE BRENNER, Chairman i
1 l
19 Administrative Judge i 20 JAMES CARPENTER, Member l
21 Administrative Judge l
l 22 PETER A. MORRIS, Member 23 Administrative Judge rm
() 24 WALTER H. JORDAN, Assistant to the Board 25 Administrative Judge i I;
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I ALDERSON REPORTING COMPANY,INC, l
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8515
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C/ 1 APPEARANCES:
2 3 On behalf of Applicant.
4 5 W. TAYLOR REVELEY III, Esq.
6 DONALD P. IRWIN, Esq.
7 ANTHONY F. EARLEY, Esq.
8 Hunton C Williams 9 707 East Main Street 10 Richmond, Va. 23212 11 12 On behalf of the Regulatory Staff:
13 tO 14 BERNARD BORDENICK, Esq.
15 LEE DEWEY, Esq.
16 Washington, D.C.
17 18 On behalf of Suffolk County:
19 20 LAWRENCE COE LANPHER, Esq.
21 KARLA J. LEISCHE, Esq.
22 Kirkpatrick, Lockhart, Hill, Christopher 23 C Phillips T
) 24 1900 M Street, N.W.
25 Washington, D.C. 20036 O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564-2345
8515-A 7 1 CONTENTS C/
2 WITNESSES: DIRECT CROSS _ REDIRECT RECROSS BOARD 3
4 4 Raymond M. Crawford, Jeffrey L. Smith, Steven J. Stark, 5 John J. Boseman, Fred Hayes, 6 John J. Kreps, C. A. Malovrh, 7 Robert'J. Wright, Marvin W. Hodges, 8
Frank C. Cherny g By Ms. Letsche 8557 10 (AFTERNOON SESSION P. 8634) 11 Raymond M. Crawford, Jeffrey L. Smith, 12 Steven J. Stark, n J. Boseman, 13 Fred Hayes,
() 14 John J. Kreps, C. A. Malovrh 15 Robert J. Wright, Marvin W. Hodges, 16 Frank C. Cherny By Ms. Letsche 8634 I7 By Mr. Irwin 8667 18 By Judge Morris 8678 By Judge Jordan 8679 19 By Ms. Letsche 8680 20 21 Suffolk County motion to strike portions of LILCO ... 8525 22 Prefiled testimony on SC Contention 16--anticipated transients without SCRAM 23 LILCO response to Suffolk County motion to strike ... 8525 rN 24 portions of LILCO's testimony on SC Contention 16
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ALDERSON REPORTING COMPANY,INC, l
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8515-B I
[~j) u CONTENTS (cont'd) 2 LILCO's motion to strike the testimony of Gregory C. Minor.. 8586 3 on Suffolk County Contention 16--ATWS S 4 Suffolk County opposition to LILCO's motion to strike the .. 8586 testimony of Gregory C. Minor on Suffolk County Conten-5 tion 16--ATWS 6
Suffolk County motion to strike portions of LILCO testimony. 8586 7 on Water Hammer Procedures and Training 8 LILCO's reply to SC objections regarding Kreps/Notaro on. . . . 858 6 Water Hammer Procedures and Training 9
10 11 12 RECESSES: Morning Noon End 13 8556 8633 8686
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON, D.C. 20024 (202) 554-2345
8516
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m P OCE ED I N G 1 2 JUDGE BRENNEP: Good morning.
3 We are going to handle the two motions to 4 strike and the responses thereto with respect to ATWS, 5 and then we will handle the County's motion to strike 6 the portion of LILCO's testimony on water hammer 7 procedures, to which we have also received a response.
8 We are prepared to rule on the basis of the 9 written documents before us. The Board has discussed it 10 extensively prior to today. This morning we reviewed 11 the responses. We were going to consider delaying our 12 ruling if the responses had raised significant matters
- 13 that we hadn 't considered.
i )
- 14 The responses raised some matters that we 15 hadn't considered and did affect our ruling somewhat, 16 but not significantly. So we a re able to go ahead. We 17 will ask the Staff to briefly take a position on th e 18 motions at this time, and then we will go ahead and 19 rule.
i 20 (Pause.)
21 3R. 90RDENICK: Judge Brenner, I'm sorry for 22 the delay. I was anticipating a different procedure and 23 I d on't have my papers, my notes, that organized at this 1
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(_) 24 point. I thought you would be hearing oral arcument 25 from the parties first.
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
8517
( ) 1 JUDGE BRENNER: I don't think we need it.
2 MR. 20RDENICK: I understand.
3 On the County's motion to strike portions of 4 LILCO's prefiled testimony --
5 JUDGE BRENNER: That is question and answer 10 6 and 217 s 7 MR. BORDENICK: That is correct.
8 We feel that on question 10, although it is 9 not specifically men tioned in th e testimony, we feel 10 that part of the testimony and question is applicable to 11 - - -
to alternate rod insertion or the ARI, a s it is 12 called, and we think that the testimony is at least 7s 13 background type of testimony, and for those reasons we
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\'. 14 do not think it should be stricken.
15 And on question 21, we think that the 16 testimony in question goes to the overall question that 17 is before the Board on this psrticular contention, as 18 any other contention that involves a generic issue, and 19 that is why it is okay to go ahead with licensing of 20 Shoreham in the interim period pending final resolution 21 of the generic question.
22 So in sum, we would recommend tha t the Board 23 not grant these motions as to the two questions that are T' .
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24 before the Board, or the two questions involved in the 25 proposed testimony before the Board.
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ALDERSON REPoATING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8518 1 As to the other motion, we feel that, for the
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2 reasons indicated in the Applicant's motion, much of the 3 testimony in question should be stricken. However, we 4 feel that there are po rtions of it, which I am not 5 prepared to identify and I don't think, based upon what 6 I 'm going to say, that it is my responsibility to do 7 that, but there are portions of it which probably would 8 be acceptable, and the proposal that the Staff had was 9 that if in fact the Board grants the Applicant's motion 10 that the County be given a further opportunity -- I 11 realize that the time is short, if in fact the Board is 12 going to hear the ATWS motion next week -- for the 13 County to come back, based upon whatever guidance the
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14 Board chooses to give the County to try to sa lvag e , so 15 to speak, those partions of the testimony which at least 16 arguably are no t susceptible to striking for the reasons 17 that the Applicant has indicated.
18 As I say, we are not p re pa red to point out 19 which portions of the testimony that should be. We 20 think that should be the responsibility of the County.
21 But other than the shortness of time, we thin k that that 22 is the appropriate remedy if the Board in fact grants 23 the Applicant's motion.
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24 In other words, we think the result if the 25 motion is granted will be somewhat harsh, but we believe
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'y___i ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8519
() 1 that the Applicant's motion is well taken, for the 2 reasons they have indicated, when reading the testimony
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s-3 as a whole. But there are sentences here' a nd there 4 which perhaps could be salvaged. Whether the County is 5 interested in doing that or not, I will leave that to 6 them.
7 JUDGE BRENNER: That sounds like too big a 8 blank check, and I will tell you why. It is not just 9 the time involved. We encourage the parties to work 10 things out on their own throughout this proceeding.
11 However, we like to do it with some parameters on what 12 it is they have to ucrk out, and you haven't given us 13 any hint as to what those parame ters would be.
O 14 MR. BORDENICK: Well, other than the shortness 15 of time, I think perhaps the parties could get together 16 and work it out, although I'm not prepared to give you 1~ the parameters. And that was just --
18 JUDGE BRENNER: Let me ask you this, because I 19 was going to ask LILCO anyway. The County more 20 particularly than you have stated an ticipated some of 21 tha t in one sense. The County argues that LILCO's 22 motion should not be granted at all.
23 However, the County also arques that even if 1,
24 we agree with LILCO's characterization of the contention l(
i i 25 and its context, that paracraphs 1 through 12, for a O
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8520
() 1 number of differen t but related reasons, should stay 2 in. What do you think about that portion of the 3 County's response? And I guess I'm going to ask LILCO 4 the same question, so LILCO can respond, or the Staff, 5 or both.
6 MR. BORDENICK: I don 't know if LILCO is ready 7 to respond to that. I would like to have a few more 8 min utes to consider tha t, if possible, if they want to 9 go ahead.
10 MR. EARLEY: Judge, we have had very little 11 time to look at the County's response. But in a quick 12 review of it, they seem to argue that there are portions 13 that should not be subject to the motion to strike. I O 14 think Mr. Bordenick pointed out the heart of our 15 objection, that, taken as a whole, the Coun ty 's 16 testimony should not be admitted.
17 Now, there may well be sentences or portions 18 -- for example, the introduction --
19 JUDGE BRENNER: No, I'm not talking about 20 isolated sentences. I'm talking about paragraphs 1 21 through 12.
22 MR. LANPHER: Judge Brenner, to be a little 23 more clear, I think our argument in that first part of
( 24 our response was paragraphs 1 through 13, just so the 25 record is clear. I don't know if you would want to O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASH.c4GTON, D.C. 20024 (202) 554 2345
8521
(~} 1 restate your question.
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3 JUDGE BRENNER: Yes, and I will give myself a 4 minor excuse, although really I don't have any excuse, 5 and that is that 13 is discussed at the same portion, 6 that the first few paragraphs a re discussed , and then 7 when you get to the end it ends at 12. But maybe you've 8 just gotten some insigh t in to our thinking, too.
9 That is another reason as to why I said 1 10 through 12.
11 MR. EARLEY: Judge, in reviewing thi s ,
12 certainly 1 through 6 are background paragraphs. In
_ 13 reviewing this, we cortainly would object to pa ra gra ph i)
'N _ 14 13. Now, I think you run a spectrum in 7 through 12, 15 tha t 7, 8 and possibly 9 might have some relevance. But 16 again, locking at the testimony as a whole, we don't 17 think it ca n be justified, admitting those into 18 evidence. They may be background information, but there 19 is nothing else in the testimony that they serve as 20 background to and it wouldn't serve any purpose to admit 21 them.
22 MR. BORDENICK: Judge Brenner, I think the 23 Sta ff would agree with that observation. The questions O and answers under discussion are certainly descriptive 24
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25 type testimony, background type te stimon y . But the I
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8522 1 problem still is that the testimony is very general, and 2 the question is really, what relevance does it have to 3 the contention as restated by the Board in the order 4 admitting the contention.
5 So, as Mr. Earley has put it, although it is 8 background, what is it background to?
7 JUDGE BEENNEP4 All ri gh t. I think the 8 Boa rd 's thinking has been pretty thorough on this and we 9 are going to go ahead with the ruling. If right after 10 the ruling any party thinks we have -- not just that you 11 disagree with us, but that you think we have really 12 missed an important part of the argument, we will hear 13 from you on it.
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\_) 14 (Board conferring.)
15 JUDGE BRENNER: Well, we agree with some 16 arguments of LILCO and disag ree wi th some a rguments of 17 LILCO, and we agree with some arguments of the County 18 and disagree with some arguments of th e County. So 19 the re is something for every bod y , and the rulings will 20 reflect that.
21 Let me take the County's motion to strike 22 first. We believe the County is incorrect that the 23 contention in there for the litigation must assume that
/ i 24 an ATWS event occars. In fact, it is quite the 25 c on t ra r y , given the Commission's basis for interim
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. ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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8523
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licensing, as we will discuss in a little further detail in connection with the other motion to strike when I
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V 3 a c t ually want to read a portion of the statement of 4 considerations into the record.
5 Given that fundamental misconception, it might 6 be that there motion to strike should be wholly denied, 7 however for a somewhat different reason. For a somewhat 8 different reason, we think that question and answer 21 9 should in fact be struck, and I will get to that in a 10 moment.
11 Question and answer 10 goes to how the scram 12 system a t Shoreham would work. Among other things, this 13 is usef ul ba ckground, but that phrase under which a 14 multitude of evils can be hidden -- more directly, the 15 reason it is useful, as opposed to non-useful, 16 background is that it also goes to the question of the 17 time the opera tor vould have to initia te the standby 18 liquid control s ys tem, which is a subject very 19 fundamental to deciding whether the interim measures are 20 adequate at Shoreham, and that is certainly going to be 21 explored in this hearing.
22 And it is not just the time as a qua n ti ta tive 23 function. It is time as a function of wha t the opera tor 24 would be aware of and what steps the operator would go l
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25 through, including API, at Shoreham.
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l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8524 1 Question and answer 21 broadly goes to the low V("3 2 probability of an ATWS. It is not keyed to Shoreham at 3 all. It would apply to Shoreham. It is not keyed 4 specifically to Shoreham. It -- in the abstract it 5 would be pertinent. It is pertinent to the 6 consideration of whether a plant can be licensed in the 7 interim. We would agree wi th Mr. Bordenick there.
8 However, we are not writing on a clean slate.
9 It also happens to be one of the generic findings of the 10 Commission as to their basis for the interim 11 rulemaking. We can rely on that finding here. In fact, 12 we must rely on tha t finding here. And since there is 13 nothing peculiar about Shoreham with respect to that n
(,) 14 overall findino, we are going to strike the testimony, 15 because the Commission has stated that it believes the 16 likelihood of severe ATWS consequences arising from an 17 ATWS event during the two to four-year period required 18 to implement a rule is acceptably small.
19 I think that covers our ruling on that 20 motion. You will get a little more flavor of what we 21 mean by the fact we're not writing on a clean slate when 22 we discuss LILCO's motion to strike, which we will do in 23 a moment.
(~'3 24 Judge Morris reminds me that we should bind in
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25 the motions to strike. To at this point I would like to
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%.J ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
8525 1 first bind in Suffolk County's motion to strike and 2 LILCO's response, 3 (Tho documents referred to f ollow :)
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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.La;;-in ch*jf UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD O In the Matter of
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LONG ISLAND LIGHTING CO!iPANY ) Docket No. 50-322 0.L.
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(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO PREFILED TESTIMONY ON SC CONTENTION 16 -- ANTICIPATED TRANSIENTS WITHOUT SCRAM Suffolk County moves to strike Questions and Answers 10 (except the last paragraph) and 21 from the LILCO prefiled testimony on SC Contention 16 - ATWS. The basis for this
{) motion is that these portions of the testimony are not relevant to'SC Contention 16 as framed by the Board.
SC Contention 16 concerns whether the Snoreham systems, procedures and training for dealing with an ATWS event are adequate and whether there is compliance with GDC 20 despite the fact that the Shoreham Standby Liquid Control System is not l automatic. The Contention makes the assumption that an ATWS
- event will occur and then questions the adequacy of methods to ndtigate the consequences of an ATWS event. Thus, the focus i of SC Contention 16 is on mitigation of an ATWS event.
f L The portions of the LILCO testimony which the County seeks to strike do not concern mitigation of an ATWS event. Rather, these portions, in effect, argue that an ATWS event will not 4
! occur.
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. .. m Thus, Question and Answer 10 (except for the last paragraph) provides a description of the Shoreham scram system, with the focus being on the fact that it allegedly is highly unlikely to fail.
} Similarly, Question and Answer 21 address the witnesses' view that a severe ATWS event is unlikely during the interim period
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referenced in the Contention.-
Suffolk County believes that Suffolk County Contention'16, as reworded by the Board on March 10, 1982, focuses only on the adequacy of LILCO's means to mitigate the effects of an ATWS event. The Contention does not concern whether an ATWS event will in fact occur, as that is a "given" in the context of this Contention. Thus, the cited portions of the LILCO testimony are outside the scope of the contention and should be struck.
() Respectfully submitted, David H. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memcrial Highway Hauppauge, New York 11788 ,
(l' sw cH' . q;k Herbert H. Brown '
Lawrence Coe Lanpher Earla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W. ;
Washington, D.C. 20036 (202) 452-7000 July 27, 1982 Attorneys for suffolk County O
- / Evidence concerning the probability of successful mitigation of an ATWS event would be relevant in the County's view.
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LILCO, July 29, 1982 UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station, )
Unit 1) )
LONG ISLAND LIGHTING COMPANY RESPONSE TO SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO'S TESTIMONY ON SC CONTENTION 16 I.
On July 27, 1982, Suffolk County filed a motion to strike Questions and Answers 10 (except the last paragraph) and 21 from LILCO's written testimony on SC Contention 16 -- ATWS. SC argues that these portions of the Company's testimony are beyond the scope of the contention as framed by the Board because (1) these portions "do not concern mitigation (as opposed to prevention) of an ATWS event" and (2) "
[t] he Contention makes the assumption that an ATWS ovent will occur and then questions the adequacy of methods to mitigate the consequences of an ATWS event.". We agree with point (1): the challenged portions do focus on the prevention of an ATWS, as opposed to its mitigation. But we do not agree with proposition (2): it is not the case, in our judgment, that SC Contention 16 concerns only mitigation. Accordingly, the County's motion lacks merit and should be denied.
II.
O Regulatory consideration of the ATWS issue has traditionally involved elements of prevention as well as mitigation.1/ This traditional approach was followed by the Commission in the interim determination set out in the notice of proposed ATWS rulemaking; thus, the first two factors relied on by the Commission to support its determination concerned. prevention, not mitigation:
The Commission believes that the likelihood of severe consequences arising from an ATWS event during the two to four year period re-quired to implement a rule is acceptably small.
This judgment is based on (a) the favorable experience with the operating reactors, (b) the .
limited number of operating nuclear power
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reactors . . . .
46 Fed. Reg. at 57522 (col. 2).
III.
We see nothing in the Board statement and explantion of SC 16 that indicates an intention to depart from customary NRC 1/ See, e.g., 46 Fed. Reg at 57522 (col. 3) (emphasis added):
The review and evaluation by the NRC staff of the information that has been developed over the past ten years on ATWS events and of the manner in which they should be considered in the design and safety evaluation of nuclear power plants is contained in
(' the report " Anticipated Transients Without Scram for Light Water Reactors," NUREG-0460, Volumes 1 through
- 4. There are two primary factors in the staff's evalu-ation. The first is the degree of assurance that ATWS events can be prevented, which depends on the reliability of current reactor protection systems. The second is the capability of existing reactor designs to mitigate the consequences of ATWS ovents.
practice and focus only on ATWS mitigation, ignoring ATWS prevention. Against the background of NRC practice on ATWS,
- O it is reasonable to assume that the Board would have expressly stated any intent to depart ofrom customary practice and limit SC 16 to mitigation alone. No such express indication exists.
Indicatively, the present County motion cites no Board language to support its " mitigation only" interpretation of SC 16.
Needless to say, had LILCO previously thought anyone meant to exclude prevention as an element in dealingowith ATWS during the interim, the Company would have long ago expressed its strong view that such a truncated approach.to ATWS would be inconsistent with NRC practice and out of touch with
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reality.
i IV.
For the reasons stated, LILCO opposes the County's request that portions of LILCO's ATWS testimony be struck.
Respectfully submitted,-
LONG ISLAND LIGHTIN p OMPANY I
W. Tdy;. Reveley, III A/'
Anthony . Earley, Jr.
Hunton & Williams O 707 East Main Street Post Office Box 1535 Richmond, Virginia 23219 DATED: July 29, 1982
8526 1 JUDGE BRENNER4 And at this point we will be 2 sta rting a new transcript page, and after this 3 transcript page at this point we will bind in LILCO's 4 motion to strike Suffolk County's testimony and the 5 County response thereto.
6 (The documents referrad to follow:)
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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, , LILCO, July 27, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O
Before the Atomic Safety and Licensing Board l In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station, )
Unit 1) )
s l
l LILCO'S MOTION TO STRIKE THE TESTIMONY OF GREGORY C. MINOR ON SUFFOLK COUNTY CONTENTION 16 -- ATWS I.
On June 29, 1982, Suffolk County filed Mr. Minor's testi-mony on Suffolk County Contention 16.-
The contention reads _ as foll~6ilsi -- _
Although the anticipated transients without scram issue is generically before the Commission in a rulemaking proceed-ing, Suffolk County contends that LILCO and the NRC Staff have not adequately demonstrated that Shoreham meets the requirements of 10 CFR Part 50, Appendix A, GDC 20, re-garding correction of the ATWS problem in the interim period of several years pending completion and implementa-tion of the result of the rulemaking for Shoreham. This is because the interim measures to be taken at Shoreham, in-cluding operational procedures and operator training, will not compensate for the lack of an automatically initiated and totally redundant standby liquid control system (SLCS) which meets the single failure criterion.
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() For the reasons set out below, LILCO moves to strike all of Mr. Minor's testimony on SC 16.
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II.
gg The County's testimony on ATWS should be struck because it U
is beyond the scope of SC 16 as admitted by the Board. Under the NRC's rules of practice, testiraony must be relevant to issues in contention. 10 CFR Section 2.742(c). Testimony that is irrele-vant is the proper subject of a motion to strike. See 10 CFR Part 2, Appendix A, at Section V(d) (7) .
As admitted, SC 16 was expressly limited to the interim period between the time that Shoreham begins operation and the implementation of any ATWS rule.1/ The contention, on its face, assumes the lack of an automatic SLCS and directs the focus of the litigation to the adequacy of the interim measures taken by
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LILCO; thus,~~the Bohrd explained that "the question will be whe5her ~~ '
the plant design and operating actions in place pending the com-pletion of the rulemaking will compensate for the lack of auto-matic imitation' of SLCS in terms of providing the level of protection required by GDC 20." Memorandum and Order of March 15, 1982, at 18.
17~As with many contentions'in this proceeding, significant
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effort went into focusing the ATWS contention. In the form pro-posed by the County on February 15, 1982, the contention alleged a general failure to deal with ATWS:
Suffolk County contends that LILCO and the NRC Staff have not adequately demonstrated that Shoreham meets the requirements of 10 CFR 50, Appendix A, GDC 20, regarding correction of
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ss the anticipated transients without scram (ATWS) problem.
After LILCO and the Staff objected, the County attempted to clarify its concern by focusing the contention on the lack of an automated, fully redundant SLCS at Shoreham. LILCO's and the Staff's objec-tions remained. Following the oral argument at a prehearing conference on March 10, 1982, the Board further restricted the scope of the contention to " interim measures to be taken at Shoreham, including
' operational procedures and operator training . . .'T"~
As the Board recognized, the Nuclear Regulatory Commission expressly found in its notice of proposed rulemaking on ATWS that O the risk from ATWS is acceptably small in the interim period because of certain considerations enumerated by the Commission, includ-ing the existence of interim ATWS measures. See Tr. at 231; 46 Fed. Reg. 57522.
Accordingly, SC Contention 16, as admitted by the Board, focuseshon (a) whether LILCO adequately complies with the interim measures relied on by the Commission in its ATWS rulemaking notice, and (b) whether the Shoreham design is essentially the same as those of other BWR's, such that the generic interim ATWS finding made by the Commission is applicable to Shoreham. The County's testimony made no attempt to address either issue.
(]}
The lack of connection between Mr. Minor's testimony and the interim period is illustrated by the non-evidentiary summary of the testimony:
Suffolk County contends that the present standby liquid con-trol system ("SLCS") at Shoreham is inadequate to mitigate the range of ATWS consequences that might occur at the facility. The Shoreham SLCS is manually initiated and non-redundant. By automating the system and increasing its flow rate, the SLCS would mitigate a larger range of ATWS consequences and thus reduce the risk of core melt accidents at the facility.
1 This summary accurately reflects the lack of any substantive discussion of the interim measures taken at Shoreham. Passing refereEce to some of these measures (e.g., one sentence on page 8
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mentions operating procedures and training) falls far short of meaningful discussion of the pertinent steps.
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(
Section VI of Mr. Minor's testirony does argue that there would be safety, value-impact and ALARA benefits to be gained by making SLCS modifications now rather than after the ATWS rule-making, presumably on the assumption that the rulemaking will im-pose such requirements. The h9pothesis that benefits may accure from making changes now rather than latter, however, has no bearing on whether the current design is acceptable. The issue is whether the NRC's interim ATWS requirements have been met, not whether these requirements would yield a net benefit if they were made more stringent. The latter question is one reserved for the Commission. And, in the case of ATWS, considerations such as the relative safety benefit and the value-impact balance (including ALARA considerations) are being dealt with in the rulemaking. Thus,
("]
(./
Section VI of Mr. Minor's testimony is not germane to the present contention; it cannot salvage testimony that otherwise has nothing to do with the interim period and LILCO's interim measures.
To reiterate, the Board specifically limited SC Contention 16 to the interim period between the licensing of the plant and implementation of an ATWS rule. The County decided to ignore this limitation and address ATWS in general. Consequently, the County's testimony on SC 16 goes beyond the issues admitted and should be struck.
~ ~ ~
~
. -- III.
~
It bears emphasis that Mr. Minor's testimony deals with issues
~ ~
~ ~
squarely within the scope of the ATWS rulemaking. Boiled down to its essentials, the suffolk County testimony alleges that a high
capacity, automated SLCS is necessary to mitigate "a larger range of ATWS consequences" and thereby reduce the risk of core melt accidents. But this is the basic BWR issue presented for resolution in the ATWS rulemaking. As noted below, two of the proposed alternatives would require automation, one would not.
Similarly, the appropriate size of the SLCS'(see, e.g.,
Mr, Minor's testimony at pages 5-6, paragraphs 11-12) is also to be determined in the rulemaking. In fact, the evaluation models and acceptance criteria to be used in determining whether there is a need for SLCS automation and increased capacity are a part of the rulemaking. Even the issue of the single failure criterion is squarely addressed. One of the proposed rules would require that plants issued OL's after January 1, 1984 must take random single failures in ATWS mitigating systems into account. See 46 Fed. Reg. at 57525.
The link between Mr. Minor's testimony and the rulemaking is particularly obvious given the County's extensive reliance on NUREG-0460 to support the notion that LILCO must increase the capacity of, and automate, Shoreham's standby liquid control system. In the rulemaking, the NRC is considering three proposed alternative rules: two would require an automated SLCS, ,
and one would not. Of the former, one is a direct result of the NRC Staff's efforts in NUREG-0460. ("The first NRC-proposed rule
() is known as the staff rule and is a direct outgrowth of NUREG-0460,
' Anticipated Transients Without Scram for Light Water Reactors,'
Volumes 1-4." 46 Fed. Reg. 57522). Accordingly, the County's
_. g -r-_ -
_- ____~- ..- _- - ._- .. -_ . - - - - . ._ . __
j .
I i testimony on SC 16 is an attempt to litigato issues not covered by the contention but' squarely covered, and'directly before the
~
L Commission, in the ATWS rulemaking.2f l'
IV.
t In addition to the reasons stated above for striking the i
l i
County's SC 16 testimony in its entirety, some of the t37.eimony I
should also be struck for complete lack of probative value.
___.ww. .- -% ..
i 2/ Though not relevant to the present motion to strike, it remains LILCO's view that the Appeal Board's decision in Sacramento
! Municipal Utility District (Rancho Seco Nuclear Generating Station),
ALAB-655, 14 NRC 799, 816 (1981), is directly applicable to ATWS.
The hydrogen control issue considered in Rancho Seco had safety impli-cations in the interim akin to those of interim. operation without i an ATWS rule. Yet the Appeal Board concluded that the issue should not be litigated in an individual licensing case. Part of the
- conclusion seemed to be based on the fact that the Board could " rely on
! the Commission's implied judgment that the operation of Rancho Seco r
. . . in the interim will not present an undue hazard to health 4
and safety." Id. at 816, quoting Sacramento Municipal Utility District (Rancho Seco Nuclear Generating Station), LBP-81-12,
! made an explicit finding that based on certain enumerated considera-I tions, including some interim ATWS measures, "the Commission be-lieves that there is reasonable assurance of safety for continued operation until implementation of a rule is complete." 46 Fed.
Reg. 57522. Thus, the rationale of Rancho Seco.would seem to apply j with force here. 7 I Indeed, in Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), _ slip _op. at 31 (March 5, 1982), the Board held.that the Commission's interim determination in the notice of ATWS rulemaking was controlling when the thrust of a contention was "that the applicants have failed to demonstrate that the risk from an ATWS event is such that there is a reasonable assurance that the Catawba plant can be operated prior to the completion of the Commission's pending rule-O making on that subject." But see Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant 7 Units 1 and 2), slip op. (Janu-4 ary 6, 198 2) . ,
I
Although the. weight to be accorded a piece of evidence is normally a matter to be tested by cross-examination, testimony without any f%
s/ probative value at all is properly subject to a motion to strike.
Section V of Mr. Minor's testimony relles on a compariso6 of the results of the Shoreham and Limerick PRAs. First, the County compares the frequency of core vulnerability for the release cate-gories in the Shoreham PRA to the frequency of core melt for the release categories in the Limerick PRA. Second, the County com-pares the relative frequency of core vulnerability and core melt (for Shoreham and Limerick respectively) for ATWS to the total frequency.
In drawing the above comparisons, the County cites summaries gS of the PRA results that were the subject of considerable discussion V
in the testimony of LILCO's witnesses on SC/ SOC 7B. It is readily apparent from a review of the record, that any comparison of the plants using the information cited by Mr. Minor in his testimony is meaningless and has no probative value. Dr. Edward Burns, a principal participant in both the Shoreham and Limerick PRAs, had this to say about the comparison of frequencies that SC attempts to make in Table 1:
As I have tried to say before, you can't compare the two classes. (Class III at Shoreham and Limerick). That is not the correct comparison to be making. I don't know why you want to do that. It doesn't make any sense.
Tr. at 6203. And with respect to Class IV he said:
There is some contribution to that difference due to the change ,
from alternate 2(a) to 3(a), but it is only a partial factor i at Limerick in changing the risk between Shoreham and Limerick in what is referred to as Class 4 (sic) in both plants.
Tr. at 6006; see also Tr. at 5791.and 6315-16.
1 l
With respect to the " pie charts," when Dr. Burns was asked whether Figure 3.5.4 of the Limerick PRA (top of page 9 in SC's testimony) and figure 3.6.6 (bottom of page 9 in SC's testimony) b(s were comparable, he said: "As I stated before, the Shoreham calcu-lation was for core vulnerable condition, and these two (Limerick vs. WASH-1400) are calculations of frequency of core melt." Tr.
at 5793. Similarly, Dr. Joksimovich's view was that the Limerick chart compared " apples and apples" and the Shoreham charge compared
" apples and oranges." See also, Tr. 6307-08.
Moreover, as indicated by Dr. Burns, the Limerick PRA has been revised. Since SC stated that it did not have a copy of the revised Limerick PRA, the data used in this testimony are presumably from the original version. This is another reason why
() the testimony in Section V has no probative value.
V.
For the reasons stated above, Suffolk County's testimony on SC 16 should not be admitted in evidence in this p roceeding.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
/
_4sLA CL . /Jr .
W. Taylor R I'eW III - -
Anthony F. rley, Jr.
Hunton &, Williams Post Office Box 1535
() Richmond, Virginia 23212 DATED: July 27, 1982
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
(-
L BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station,)
Unit 1) )
Suffolk County opposition To LILCO'S Motion To Strike The Testimony of Gregory C. Minor On Suffolk County Contention 16---ATWS On June 27, 1982, LILCO moved to strike portions of the Testimony of Gregory C. Minor on Suffolk County ("SC") Contention 16 dealing with the issue of anticipated transients without scram
("ATWS"). For reasons stated below, the LILCO motion should be denied.
First, even if the LILCO characterization of the focus of SC 16 is accurate--and, as specified hereafter, we do not believe it is--the motion is far too broad. Thus, there are many portions of the testimony which clearly are relevant. For example, paragraphs 1-3 constituting the " Introduction" and " Purpose" sections, paragraph 13, which provides the author's interpretation of GDC 20, and paragraphs 4-6, which describe the Shoreham Standby Liquid Central System ("SLCS"), certainly cannot be the proper object of a strike motion. In fact, LILCO in its own testimony (p. 22)
() also describes the SLCS at Shoreham. Indeed, since SC 16 concerns inter alia operator procedures and operator training to ensure timely actuation of the SLCS in an ATWS situation, a description I
I
of the system as to which such procedures and training apply is clearly appropriate.
~
In the same vein as paragraphs 4-6, paragraphs 7-9 address V) specific conditions and circumstances which an operator would face in an ATWS situation. It is axiomatic that the adequacy of procedures and training for an ATWS situation (or for any other event) cannot be judged in a vacuum. Rather, circumstances such as heat levels (paragraph 7), the need to diagnose conditions and manual actuation of the system (paragraph 8), and the difficulty of an operator's decision to actuate the SLCS (paragraph 9) all relate directly to steps and conditions which are relevant in considering whether the interim measures at Shoreham " compensate for its lack of an automatically initiated and totally redundant
_j Standby Liquid Control System (SLCS) which meets the single failure criterion."
Similarly, paragraphs 10-12 address the time required for the SLCS to accomplish its function. The adequacy of procedures and training to timely initiate the Shoreham SLCS cannot be divorced from the capabilities and potential shortcomings of the system to which the procedures and training relate.
The County perceives that LILCO's main objection to the SC 16 testimony really begins with paragraph ly on page 6 of the s.
Y testimony-1/ . This testimony covers the following points:
Paragraphs 14-15 Comparision of risks using an auto-c' mated higher flow rate SLCS versus risks using the
(_/ Shoreham system.
Paragraphs 16 Benefits of upgrading Shoreham SLCS now.
LILCO objects to all the foregoing testimony, arguing that the focus of SC 16 is on:
(a) whether LILCO adequately complies with the interim measures relied on by the Commission in its ATWS rulemaking notice, and n
(b) whether the Shoreham design is essentialfly the same as those of other BWR's, such that the generic interim ATWS finding made by the Commission is applicable to Shoreham. Motion, p. 3 The County respectfully submits that LILCO's char terization y of SC 16 is not correct. The focus of SC 16, in the view of the County, includes the plant-specific issue whether the interim measures " compensate" for the lack of an automatic and redundant SLCS which meets the single failure criterion. Indeed, by its terms, the contention states that the baris for the allegation of noncompliance with GDC 20 "is because the interim measures to be taken at Shoreham, including operational procedures and operator training, will not compensate for the lack of an automatically initiated and totally redundant Standby Liquid Control System f~3 1. LILCO does object (Motion, p. 5) to Mr. Minor's discussion m/ (in paragraphs 11-12) of the size of the Shoreham SLCS, found at pages 5-6 of his testimony. As noted earlier, however, the size and flow rate of the Shoreham SLCS must be considered when the adequacy of training procedures and other interim measures are considered.
(SLCS) which meets the single failure criterion." (emphasis supplied). See also March 15, 1982 ASLB Memorandum and Order, p.
(~ ) 18, which states that "the question lon SC 16) will be whether the
\J plant design and operating actions in place pending the completion of the rulemaking will compensate for the lack of automatic initiation of SLCS in terms of providing the level of protection required by GDC 20." (emphasis supplied). The portions of the SC testimony in paragraphs 1 -19 are directly relevant to the question of whether the interim measures and the plant design do in fact compensate.
In determining whether the interim measures and plant design compensate for what the County views as deficiencies with the Shoreham SLCS, it is relevant to compare the Shoreham SLCS with a i
o i
\J SLCS design which has some of the features which are referenced in the contention. Indeed, in determining whether there is compensation, a comparison is essential. Mr. Minor's testimony presents one portion of that comparision--namely, that, the differences between an automated and nonautomated SLCS are sufficient to be of concern. Thus, this testimony addresses the need for compensation and presents the author's view (Prefiled Testimony, p. 8, lines 6-10) that such compensation has not been demonstrated. In the County's view, it is LILCO's responsibility to demonstrate quantitatively or qualitatively that the " interim
(~} measures" compensate for the differences in ATWS risk described by
'J Mr. Minor.
_4_
The County acknowledges that Mr. Minor's testimony does not address the details of the Shoreham procedures and training The County submits, however, that it is permitted to present testimony on one aspect of the Contention --the need for compensating measures and the apparent inadequacy thereof--and I
that such testimony is not objectionable soley because it does not address in detail other aspects of the Contention.
Further, LILCO at page 21 of its prefiled testimony asserts that its SLCS is " capable of shutting down the reactor from rated power operation to cold shutdown condition in the extremely unlikely event that not enough control rods cou '1d be inserted."
The County's testimony, particularly paragraph 310-15, serves to rebut this testimony by showing that for many ATWS sequences, the
() Shoreham SLCS is not an adequate mitigator. It is clearly inap-propriate for LILCO to move to strike as irrelevant portions of the County's testimony which address the same issue as LILCO's witnesses have addressed.
Finally, LILCO appears to assert that because "Mr. Minor's testimony deals with issues squarely within the rulemaking", it is ,
therefore outside the scope of SC 16. The County disagrees. The I mere fact that ATWS is before the NRC in rulemaking does not make the issue per se off limits. Mr. Minor does testify regarding his belief that an automated SLCS is needed. However, this testimony is in the context of his belief that procedures and training do O
l l i t
, ~ -. .- - . _ -
-- ~ -- , - , -.----e , ,
not compensate for the lack of such a system. Thus, Mr. Minor states:
The major contributor to Class IV vulnerabilities at both (N Limerick and Shoreham is stated in the PRAs to be ATWS.
k- (For Limerick, ATWS is also listed as a significant con-tributor to the lesser release category, Class III.)
Limerick shows a substantially lower frequency (indeed, a factor of 30 less) of Class IV releases compared to Shoreham. The impact of Shoreham operating procedures and training apparently was not sufficient to overcome the greater calculated frequency of ATWS events resulting in core vulnerability due to the differences in the mitigating systems. Prefiled testimony, p. 8 (first emphasis in original; second emphasis supplied).
Such testimony regarding the adequacy of the design and the inkrim measures at Shoreham to compensate for the lack of an automatic SLCS is relevant to the contention.
In Part IV of its Motion (pp. 6-8), LILCO also moves to strike Section V of the prefiled testimony as being without probative r
value. In support of this position, LILCO relies on selected statements by Dr. Burns and Dr. Joksimovich. First, e believe that there are statements by Dr. Burns which state that such comparisons are possible. Time has not permitted their inclusion in this response but we shall attempt to have them available by Friday, July 30. Second, even assuming that the LILOO witnesses stated that all comparisons betweeen Limerick and Shoreham are not possible, Mr. Minor disagrees. This is a matter, then, for cross-examination. Certainly, a witness should not be prohibited by a motion to strike from giving his interpretation of data which are
/~T in controversy. Finally, Mr'. Minor's use of Limerick and Shoreham V
I data was for the purpose of a relative risk comparison. See l
Prefiled Testimony, p. 6, last line, p. 8, line 16. Mr. Minor believes such relative risk comparisons are valid and that they
(~}
assist in quantifying the degree of compensation required by the interim measures in the absence of an automatic SLCS. If LILCO disagrees, its proper course is to pursue cross-examination.
For all the foregoing reasons, the LILCO motion to strike must be denied.
Respectfully submitted.
David H. Gilmartin Patricia H. Dempsey Suf folk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 o &&
Herbert H. Brown f Lawrence Coe Lanpher Karla J. Letsche .
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.
Washington, D.C. 20036 (202) 452-7000 Attorneys for Suf folk County Dated: July 30, 1982 I
b '
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-s Before the Atomic Safety and Licensing Board
' ' .] ,
l l
-)
In Che Matter of )
. )
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L. ;
) !'
(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO TESTIMONY ON WATER HMiMER PROCEDURES AND TRAINING
/
b In response to statements by the Board on June 1, 1982 (Tr. pages 2681-83), LILCO submitted on July 9, 1982 additional.
direct testimony relating to Suffolk County Contention 4 -- .
Water Hammer. The Board's statements indicated that any such additional testimony was to address the issues of procedures, training, in-service testing, and surveillance relating "specifically" to water hammer. (Tr. 2682). Although some portions of the July 9 testimony do relate to water hammer pro-cedures and training, large portions of that testimony have nothing to do with water hammer. Thus, the following portions of
/'s i
(,) the July 9 testimony should be stricken because they go beyond the scope of the additional testimony permitted by the Board: .
O l
8
J
_2 (a) The answer to Question 6 (pages 3-4), except the first sentence; and (b) Questiens and Answers 7 through 12 (pages 4-7) .
These portions of the LILCO testimony should be stricken because they do not deal with the issue of how water hammer is addressed in SNPS procedures and training, and therefore the testimony is irrelevant to SC Contention 4 and goes beyond the limited scope permitted by the Board on June 1. Indeed, this portion of LILCO's additional SC 4 testimony has nothing (N to do with water hammer. Rather, it contains a description,
\.,._)
in th2 most general terms, of how Shoreham pre-operational test procedures and plant procedures are prepared and reviewed.
It does not include any information that is in any way probative of how -- or if -- such procedures take into account the possible occurrence, or prevention or mitigation of water hammer events.
Indeed, Questions and Answers 4 and 5, as well as Question 6 of .
the LILCO additional testimony, indicate that Shoreham does not have procedures specifically for the prevention or minimization of water hammer, nor do the shoreham operating procedures indicate a
?
i- , . .
that specific steps are included for the purpose of minimizing or precluding water hammer. Question and Answer 3 attempts to explain how the Shoreham procedures purport to address water
( hammer concerns. It is evident that the information contained in Answer 6 and Questions and Answers 7 through 12, add nothing to that explanation that is pertinent to water hammer. .
- Therefore, those portions of the LILCO testimony are irrelevant to the limited issues which this additional testimony was designed to address, Suffolk County submits that those portions of the LILCO testimony should tnus be stricken.
Respectfully submitted, DAVID J. GILMARTIN PATRICIA A. DEMPSEY Suffolk County Department of Law .
Veterans Memorial Highway Hauppauge, ! Jew York 11788 O
G&d Herbert H. Brown Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M~ Street, N.W.
Washington, D.C. 20036 (202) 452-7000 Attorneys for Suffolk County July 20, 1982 O -
.i
..__m
7ve .-- <
,z . - - - - - ,
.z,:r, LILCO, July 23, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGl! TING COMPANY ) Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station, )
Unit 1) )
LILCO'S REPLY TO SC OBJECTIONS REGARDING KREPS/NOTARO ON WATER HAMMER PROCEDURES AND TRAINING The County argues that most of Answer 6 and all of Questions and Answers 7 to 12 "should be stricken because they do not deal with the issue of how water hammer is addressed in SNPS procedures . . . ." We disagree.
Messrs. Kreps and Notaro indicate that " specific procedures for water hammer" are unnecessary for three basic reasons:
(1) The concrete measures needed to deal with water hammer are, in fact, included in the procedures (Questions and Answers 2-3);
(2) Discussion of water hammer as the rationale for these concrete measures would add counter '
productive detail to the procedures, particularly f
- f w. , 7 rjp23 %. 37+37 #7 - - -
- ~
,$ ~ -
. p-
'e- ~2-5 since "[o]perators are aware of the ' whys' through training and experience" (Question and Answer 4);
{
(3) Confidence that (a) all necessary concrete measures have, in fact, been included in the proce{uresand (b) no need exists, on balance, to create a specific category of water hammer procedures rests in good part on the " rigorous fashion" in which Shoreham's procedures are developed (Questions and Answers 6 to 12).
Thus, it is point (3) above with which the challenged testimony deals. The process described in that testimony is not concerned only with water hammer, nor should it be. The
/~T (J process is designed to take into account all pertinent considerations, water hammer merely one among a very great many. Thus, the description of the process -- e.g., its layers of review, its reflection of operating experience, I its concern with the specifics of plant design, its pro-vision for periodic revision -- do bear squarely on whether or not there is reason for confidence in points (2) and (3),
that is, whether adequate basis exists for confidence that water hammer and all other relevant considerations have been i
taken into account in the past and will continue to be in
- N the future.
J l
W L
-,------u "' ~
...Shh Admittedly, there is no reiteration throughout Questions and Answers 6 to 12 that water hammer is one of the concerns kept in mind during the process of developing
}
procedures. Such reiteration could easily have been included.
Messrs. Kreps and Notaro thought it adequate, however, simply to state once and for all, at the beginning of their testimony, that "[w]ater hammer is one of many considerations taken into account in the development of Shoreham's procedures" (Answer 2), and to indicate how (Answer 3). We continue to believe that this reality need not have been repeated over and over in Questions and Answers 6 to 12 in order to make clear that water hammer figures in the process described there.
Respectfull submitted, Vl W. Taf for Reveley, III IIUNTON & WILLIAMS 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 DATED: July 23, 1982 i
i 1
8527
/~T 1 JUDGE BRENNER: We agree with the fundamental JU 2 main point made by LILCO's motion, which we find to be
/~T 3 consistent with our March 15th order a t pages 15 through i
(V 4 19, in which we first reworded and then, as reworde'd, 5 admitted the contention, that the contention assumes the 6 lack of an a utoma tic, fully red und a n t standby liquid 7 control system and limits the litigation in this 8 individual procedure to the question of whether the 9 interim measures in place pending completion of the 10 rulemaking will compensate for that lack.
11 Now, the County uses the word " compensate" and 12 states therefore all comparisons are pertinent, 13 including the f ull discussion in the County's testimony
{N-) 14 as to what it believes would be achieved by an auton. tic 15 standby liquid control system. The County is taking the 16 word " compensate" out of the context of the limits of 17 this litigation, because the word " compensate" in the 18 contention must be read in the centext of what the 19 Commission has left open to litigate as an interim 20 measure. And we discussed that fully as part of our 21 reasoning in the Ma rch 15th order.
22 What is left to look at is the Commission has 23 based its judgment that interim licensing is acceptable 24 on the factors listed in that rulemaking proceeding.
(
25 The question here is solely whether those interim O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554-2345 ,
8528
,e x 1 measures for which we could not assume a generic finding b
2 would be applicable to Shoreham, primarily, and, as we 3 indicated in the con tention , as well as our reasoning t 4 that focuses on reason (e) by the Commission, small 5 "(e)", as to whether the interim steps taken with 8 respect to procedures and opera tor training at Shoreham 7 is consistent with the Commission's overall thinking 8 that such proper interim steps have been taken at 9 plants.
10 This does not include some other 11 considerations as to wha t design capabilities are in the 12 reactor, particularly, for example, if we had a reactor 13 tha t did not have one of the design considerations
,-)
\ 14 expressly assumed by the Commission, such as reactor 15 recirculation pump trip. And in fact, if a reactor has 18 other things that the Commission ha sn ' t considered in 17 terms of hardware, that would be pertinent also in terms 18 of the efficacy of the interim measures in combination 19 with procedures and training.
20 But an overall abstract comparison, getting us 21 into asserted aivsntages of an automatic standby liquid 22 control system, would be the entire range of litigation 23 of just what the rulemaking is considering, and that is
/) 24 not what we are doing here. So, to restate it, the J
25 question comes down to whether LILCO complies with the o
N)
ALDERSoN REPORTING C,oMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8529 r- 1 interim measures such that the Commission's generic O 2 interim ATWS finding is applicable to Shore ham.
3 And because Shoreham has the re ci rcula tion t 4 pump trip we don't have to litigate that portion. I 5 merely cite th a t to show that it might have been 6 possible in other cases that other things would have 7 been pertinent to the interim litigation. But there is 8 no dispute over that point in this case.
9 What the County has done in its testimony has 10 ignored, to put it bluntly, our order in restating the 11 contention and filed the same testimony it would have 12 filed on the County's initial contention, in our view.
13 That is, addressing ATWS in general and whether a fully 14 h a u toma tic , fully redundant standby liquid control system 15 should be required, the Commission has made the finding 16 that it doesn't have te be required in the interim so 17 long as th e proper measures are in place within the 18 parameters indicated by the Commission, something which 19 we will explore quite thoroughly here.
20 This, Our reasoning, applies even to section 21 VI of the testimony, which gives the County 's view that 22 it would be better to make modifications now rather than 23 later due to value impact and PLARA considerations.
/~^i 24 That kind of testimony would certainly be pertinent in a V
25 consideration of whether you can go ahead in the interim
- a i
%)
ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 1
J
8530 r~'. 1 if this were, as in an unresolved safety issue, for L.),
2 example.
3 However, again, we are not dealing with this 4 on a clean slate. We have the Commission's rulemaking 5 proceeding, which has made the decision tha t it is 6 acceptable to proceed on an interim basis without making 7 this change, provided the other measures are complied 8 with. So the Commission has made that finding for us.
9 If we merely had the proposed rulemaking 10 proceeding without the Commission's findings as to the 11 interim basis, then we certainly would have had to 12 consider considerations such as are in Roman VI in the 13 County's testimony. But that is not the case.
p
() 14 (Pause.)
15 JUDGE BRENNER: Our overall reasoning includes 16 and applies to Roman V of the County 's testimony, which 17 is the comparison between Limerick and Shoreham. So 18 that would be sufficient to strike it at that.
19 'J e further agree that the compa rison is, 20 although somewhat in the realm of possible 21 cross-examination as opposed to a motion to strike --
22 and this is an additional reason as opposed to the 23 prima ry reason why we are striking it -- we do agree
[~') 24 that the comparison is sufficiently apples and oranges
()
25 as to not be able to produce a probative record i
/ hj t 1 NJ l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
8531 1 efficiently as to the ef fect of an a utomatic standby
{' }
2 liquid control system.
r'%\ 3 Again, as we stated, our primary reason is (V 4 this comparison is a comparison in the abstract.
5 However, even if we were to find that it was a 6 permissible comparison in the sense of exploring the 7 efficacy of the interim measures in place, that it is 8 not.an efficient, pfobative way of getting at it. We 9 will certainly consider it pertinent to get at it by 10 parametric, I g uess , sensitivity approach, if you will.
11 That is, if you will, to explore what time differences 12 might be involved with a greater flow, to explore what 13 time dif ferences are involved with the flow at Shoreham, N
14 and see whether that makes a difference in terms of how 15 fast the operator -- what time the operator has to act, 16 and in turn how that affects our judgment as to wh e the r 17 it is reasonable to expect that an operator can and will 18 act in that time.
19 That is an example. Time is not the only 20 consideration. Willingness of the operator and trainino ,
21 of the operator to do it is also an important 22 consideration.
23 All richt. Notwithstanding our general 24 agreement that LILCO's motion is too broad, on ou,r own, 25 even before the County's response, we readily perceive l
ALDERSON REPORTING COMPANY. INC, ~j 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
8532 l
1 r" I that the first. portion of the County's testimony should L;)
2 not be struck.
3 I guess I want to point out here that it is 4 true tha t when testirony that should be subject to 5 striking is intertwined with testimony that might not be 8 subject to striking, then it is not the mover's job or 7 the Board's job to separate it out. But when the 8 testimony is readily divisible, parties making motions 9 to strike that are overbroad, given their reasoning, 10 stand the opposite risk of having us not want to parse 11 through it for that reason, either.
12 In this case we did it because it was easily 13 done. So don't go overboard, either. But the first 14 part of tha County's testimony -- and by the first part, 15 we include paragraphs 1 through 12 but not 13 -- is 16 background and not just background. It is pertinent 17 background to show, describe what the standby liquid 18 control systen at Shoreham is, how it would work, how it 19 is actuated, all of which are pertinent to examining the 20 efficacy of the interin measures, which after all will 21 be applied to the system as proposed for Sh o reh a m .
22 Initially on our own, we might have drawn the 23 line, very candidly, at paragraph 9. Eut a f ter reading
[~') 24 the County's response and considering the argument, we v
25 agree that paragraphs 10, 11 and 12 are pertinent to the
,e s
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20c 4 (202) 554 2345
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fx 1 time involved that the operator would have for the
(./ w 2 interim measures, and therefore those portions would 3 stand.
S 4 One portion in particular in the County's 5 testimony involving the potential conflict facing the 6 operator in pa rs g ra ph 9 is of particular interest and 7 concern to the Board. This doesn't give an opinion of 8 how probative the testimony is on the point, where it 9 more or less states the conclusi'on rather than exploring 10 the bases for it.
11 But that potential conflict is apparent to 12 anyone who knows anything about the operation of a 13 boiling water reactor. It was in the Board's mind from f% \
t
(,) 14 the moment the contention was first proposed and then 15 rephrased and then admitted. And for all we know, it 16 may be more impo r ta n t than the abstract time involved on 17 paper academically. That is, the important thing may 18 not be how long it takes to turn the key, but how long 19 it takes to decide whether to turn the key.
20 And this is -- I mention it nt'v,in greater 21 length than we would have to just for the motion to 22 strike, to put the context on our statement the other 23 day that we are particularly interested in the training
[') 24 and the up to date procedures. And I guess training J
25 includes indoctrination in the good sense of the word.
s
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8534 gS 1 So the result of our ruling is that the V.;
2 County's testimony will be stricken, with the exception 3 of paragraphs 1 through 12. All right. If you think we 4 have really missed the boat on something, you can tell 5 us now, or you can think about it and tell us after the 6 lunch break. But we don't want just disagreement, as I 7 sta ted earlier.
8 MR. LANPHER: Judge Brenner, I don' t know how 9 to draw that line pa rticula rly well. I think we 10 probably covered our points in our testimony. You 11 characterized Mr. Minor's testimony as going to the 12 entire rulemaking, the entire subject matter of the 13 ruling. We tried to make clear our view in our response (D
x.,/ 14 that it did not, so maybe we disagree with your 15 ch a rac te riza tio n .
16 JUDGE BRENNER: I stated that badly and that 17 is not the way I meant it. I didn 't mean tha t the 18 testimony went to the entire realm of the rulemaking.
19 What I meant was, the portions we have struck are well 20 subsumed within the rulemaking.
21 MR. LANPHEF: My point is that the purpose of 22 that testinony was to address a portion of the 23 contention which we believe needed to be addressed to
[~) 24 document the need for compensation at Shoreham. But I'm V
25 not going to argue it further, because I think that is
,s ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
- 8535 1 laid out in our response.
2 I would like to point out that your alternate g- 3 basis as to some of the portions that are struck, I
\# 4 guess with reference to the testimony of Dr. Burns and 5 Dr. Jaksimovich from earlier, during 7.B, we think it is 6 improper for the Board to draw those conclusions without 7 having heard from the Suffolk County witnesses to give 8 their views as to the probative value of th e 9 comparisons.
10 You are basing your decision on one side's 11 testimony. And Mr. Minor quite frankly would have 12 different answers or different views. I understand that 13 would be an alternate basis for the Board's decision, A)
(_ 14 but I wanted to be clear again that we don't believe the 15 Board should be reaching that kind of evidentiary 16 question having not heard f rom our witnesses. It is an 17 alternate basis for your decision, so maybe it is just 18 cumulative error from our point of view. But we 19 disagree with that also.
20 JUDGE BRENNER: I probably did not sta te that 21 as well as Judge Morris could have. Staying solely 22 within the alternate basis and recognizing we had a 23 primary basis for striking that testimony, as we 24 indicated, but we also believe our alternate basis to be 25 correct and an independent reason. So let me see if I
(
. ALDERSON REPORTING COMPANY,INC, j
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8536 gy 1 can clarify that in light of your comment.
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2 Our alternate basis isn't that we agreed that 3 the botto.2 line is that no such comparison could be 4 useful. We're not reaching tha t conclusion now. We 5 might when we go back and look at the 7.B testimony, and 6 in that context we agree with LILCO to the extent that 7 the comparison is not straightforward and therefore is 8 not an efficient comparison to productively lead to the 9 point of the efficacy of the interim measures at 10 Shoreham.
11 Rather, the way to get there if you want to 12 assert that the interim mea sures are not efficacious 13 because the flow is so low or some other hardware is so (T
(,) 14 different than that which would be present in the normal 15 population of BWR's considered generically by the 18 Commission, that it would increase the time involved or 17 that type of thing, that is a parametric sensitivity 18 approach to the question, that would be okay and one way 19 tha t would get to the same point for us to decide.
20 So it is a matter not of out and out 21 irrelevance, but of inefficiencies so great as to not be 22 permi tted without sacrificing the ability to get to the 23 question. We know enough from the 7.B testimony that j') 24 the comparison is not straightforward. Whether or not U
25 we could get there by looking at all of the details in
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-m 1 this context, we ha ven 't decided. We don' t think it is
(~/ )
2 productive or efficient to get there by that route.
3 And I probably still didn't state it very W 4 well. But I guess that is as well as I'm going to be 5 able to state it. So we are not agreeing with LILCO's 6 bottom line, that the comparison could not ever be made, 7 but we do know enough that it can't be made efficiently, 8 if at all. And it is not as simple as portrayed in Mr.
9 Minor's testimony. We know that.
10 MR. LANPHER: We think that would be a 11 relevant thing to bring out on cross and not something 12 tha t should be subject to a motion to strike.
13 JUDGE BRENNER: Except in the name of gl
\, 14 efficiency we would keep it out, and for that alternate 15 rea son we a re.
16 MR. LANPHER: We disagree with that as a 17 basis, as a proper basis f or granting the motion to 18 strike, efficiency without giving a witness an 19 opportunity to explain it on the record.
20 JUDGE BRENNER: Let me add one mo re thing, and 21 this gives us an opportunity to clarify our thinking for 22 you. You might be right, if we didn't know anything 23 about the comparison we should wait and see and then 24 deal with ef ficiency on the basis of objections to
}
25 questions during cross-examination. We know enough
(~)
%_J ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8538 N 1 about it to know we would grant those objections.
(G 2 But again, we still have the primary reason as 3 to why we struck the testimony.
4 MR. LANPHER: I recognize th a t , Judge Brenner, 5 and I recognize we have been through a lot of 7.B. You 6 have only heard from one party on 7.B as to those 7 comparisons, frankly, and I mentioned that before when 8 we said th a t there are areas where in fact Dr. Burns --
9 overnight we did have a brief chance to look through the 10 transcript. At pages 6273 through 84, there are areas 11 where the kinds of rough comparisons that Mr. Minor did 12 -- Dr. Burns we believe endorsed it, the relative 13 c om p a ri so n s , not precise but relative compa risons.
h
(~J
( 14 JUDGE BRENNER: We recall that there were such 15 portions of the testimony that agree with your sta temen t 16 in general to that effect and your response to the 17 motion to strike.
18 I don't know if there's anything else on 19 this. If not, we're prepared to move to the other one.
20 MR. EARLEY: Judge, I would just like to make 21 one point on pa ra g ra ph s 10 through 12 that were admitted 22 in the County's testimony. We believe that, given the 23 Board's position that the proper scope of the litiga t io n
()
v 24 is those areas where the Commission's ruling or the 25 Commission's finding on the safety of operating in the O
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(~^ 1 interim period, that the Board should only look at those !
's / l 2 cases where a generic finding could not have been made, 3 cuts against admitting these paragraphs unless the 4 t6stimony is arguing that Shoreham is outside the range 5 of the generic B'4R in those instances.
6 And I don't think that that point has been 7 brought up in the testimony, and therefore the 8 Commission's ruling and the reasoning that the Board 9 applies we think would cut agsinst admitting 10 through 10 12. And I would just offer that as a comment.
11 JUDGE BRENNEPs Well, I think that would be 12 correct. But you've got two problems a t this procedural 13 point of the litigation on the ATWS issue. The point
, ,\ -
4 x_) 14 is, unless there is something we missed in the Federal 15 Register notice -- and there may well be, because it is 16 extensive -- there isn't anything in there that clearly 17 brings in a particular flow rate within or without the 18 considerations.
19 Now, if when the Commission makes interim 20 findings of this nature it focuses on problems that 21 could come up in individual proceedings, it migh t be 22 induced to better specify these kind of parameters. But 23 it didn't as to that type of parameter insof ar as we
( ; j 24 know.
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l 25 Another way to get at it would be to say,
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ALDER $oN REPORTING COMPANY, INC.
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2 within the range of the BvE's that it considered in 3 saying interim measures are okay. But we don't know S 4 that to the extent that we're going to take any sort of 5 notice of that.
6 So you have got to prove the point you 7 asserted through the witness, if you want to go at it 8 that way. In addition, it is one of the pe rtinent 9 parameters to testing the efficacy of the operator 10 action.
11 At this point we don't see how it is possible 12 to take out that parameter from sayinc, oh, yes, if the 13 operator acts in X time everytning is okay. We would (D
\
~J 14 have to have it as background, at least, to know how 15 much time there is af ter action is taken. And at this 16 point we believe flow rate might be pertinent to that.
17 Maybe it's not, but we can't conclude that, and that is 18 why I discussed it in the senso of parametric type 19 approach.
20 If your witness says the difference between 21 that flow rate and the other flow rate is zero in time 22 or one second or 10 minutes or 20 minutes, these 23 different possibilities may make dif f erence s, a nd that's 24 the reason we are not striking it.
( )
25 Maybe this will help your prepara tion of L'
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8541 r~x 1 witnesses for the Staff, as well as LILCO and the C 2 County.
3 Mr. Pord enick , ma ybe this is unfair, to try to t 4 put you on the spot, but we are going to jump into this 5 litigation pretty quickly. Have you made any 6 determinations as to additional witnesses?
7 HR. PORDENICK: Judge Brenner, I was just 8 getting ready to point that out. I think we have made 9 one decision, and that is that M r. Thadani will not be 10 joining the panel. We are looking at the feasibility of 11 obtaining a witness who could address such things as 12 training and that sort of thing. But I don't know who 13 that witness will be yet, if in -fact we will have one.
p
'\_) 14 We a re still pursuing that, but I can state 15 that we will not be having Mr. Thadani join the panel.
16 JUDGE BRENNER: I will be blunt with you, just 17 because I'm that way, I guess. The Staff's written 18 testimony doesn't address the contention. It is that 19 simple. Now, maybe it wasn 't clear wha t the conten tion 20 was, although we tried to do that in harch. Now that 21 you have heard our restatement of what the contention 22 is, the Staff's eritten testizony doesn't help us at all 23 in knowing whether the interim procedures and training
()
\_ /
24 at Shorehan are good, ba d or indif f erent.
25 MR. B3RDENICK: That is the type of witness
\s ALDERSON REPORTING COMPANY,INC.
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8542 1 tha t we contemplate adding.
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2 (Board conferring.)
3 MR. LANPHER: Judge Brenner, give n your 4 comments to the Staff just now, it appears to me at 5 first blush if they are to bring an additional witness 6 this is clearly a situation where you are not just 7 supplementing the panel to give expertise on items which 8 are already covered, but it is the other ca tegory, where 9 it is substantive testimony.
10 JUDGE BRENNER: That's right. And you and 11 Judge Morris must be on the same wavelength, too.
12 MR. LANPHER: You know my . views on that, so 13 I'm not going to repeat that. But if they're going to
(^T
(_) 14 do it, I think they have to prefile that certainly by 15 Monday morning so people can see it.
16 MR. BORDENICK: Obviously, if the litigation 17 on SC-16 is going to commen ce Tuesday, which it may or 10 m ly not, we are going to try to get that motion filed as 19 soon as possible.
20 hR. LANPHER: I'm not talking about the 21 motion.
22 JUDGE BRENNER I know. We talked about this 23 the other day and I don't want to repeat it. I agree
() 24 with you that that is the best way to do it, there's no 25 question. However, I don 't wan t to make it a n
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8543
/~' 1 requirement, because the effect of that requirement U;
2 would be or co uld be that they will choose just to not 3 bring the witness, which is not the best of all 4 possibilities. And the other possibility is that we 5 hea r the witness and then you have the liberal right of 6 recall.
7 Now, if I tell somebody you can't bring a 8 witness on information that we want unless you prefile 9 the testimony in three days -- and I agree with you that 10 that shouldn't be news to them; they should have known 11 this a long time ago, and they are going to know it and 12 this isn 't going to continue for the future, as we have 13 also discussed and there's no need belaboring it. But r3
, 8
( ,' 14 if they have get a witness who can help us, I want him 15 or her.
16 But the best course is to prefile the 17 testimony, and if that can be done even in outline form 18 it should be done. In addition, parties have been 19 working well together off the record and outside the 20 litigation, and I think it would be extremely useful for 21 Staff to talk to other counsel, and as soon as they make 22 a decision as to who they're going to bring and what the 23 Staff expects that witness to testify on and any (v
n) 24 background materials that the witness might rely on even 25 in the absence of written testimony, all of those 13 t
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ALDERSON REPORTING COMPANT, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8544 rN 1 avenues should be pursued.
V 2 -
My problem is tha t I can't force any party to 3 bring a witness here short of making an absolute finding 4 that I have to have that witness, and I'm not at that 5 point yet. I'm not at that point before the testimony 6 on the question. I may be at that point after the 7 testimony, after we hear the litigation.
8 And so, even though we agree with you pretty 9 fully, Mr. Lanpher, and I think we have stated that many 10 times on this questio,1, this type of question, the 11 result of saying, that's it, it's an absolute 12 re q ui re me n t , would be or could be that we end up with 13 less than we could end up with the other way in terms of
/% 5 5
As' 14 the needs of the record.
15 I don't like being put in that position any 16 more than you do, though.
17 MR. LANPHER: I'm not going to respond.
18 JUDGE BRENNER: Let me go one further, Mr.
19 Lanpher. If we just looked at the written testimony 20 now, not knowing who Mr. Hodges was, we might have said, 21 why are you bringing this witness, given the testimony 22 in this contention. But we know well who Mr. Hodges is 2'J now and I don't think, regardless of whether we end up fm i ( ) 24 agreeing or disagreeing with everything he says at the v
25 end of this hearing, there's no question but that ne
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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(~'s 1 knows how these systems operate at this plant and it has R.)
2 been useful inf ormation f or the County as well as for 3 the Board. And he certainly is one of the witnesses we 4 would want on the issue.
5 MR. LANPHER: Judge B renner, I didn't object 6 to Mr. Hodges.
7 JUDGE BRENNER: 'd e ll , what I am saying is that 8 if we had just seen the w ritten testimony, in effect it 9 could have been a sua sponte motion to strike by the 10 Bosed. I mean, why do we need the testimony as 11 written. But we feel that we need Mr. Hodges or might 12 need Mr. Hodges on the question.
13 And it is another example'that just a cold s i
(-) 14 motion to strike might have been valid or an objection 15 to that testimony might have been valid, but the result 16 would have been to deprive us of the potentially useful 17 information that we could get through the o ral testimony 18 of a witness.
19 (Pause.)
20 JUDGE BRENNEF: Okay. With respect to the 21 County's motion to strike portions of the LILCO 22 testimony on water hammer procedures and training dated 23 July 20th, and LILCO's response thereto dated July 23rd,
() 24 we a re prepa red to give our ruling on that, and we will 25 bind in the two motions at this point.
es (The documents referred to follows) .
N ALDERSoN REPCRTING COMPANY,;NC, 400 VIRGINIA AVE, S.W., WASHINGTON D.C. 20024 (202) 554-2345
8546
() 1 JUDGE BRENNER: Does the Staff wish to take a 2 position on it?
(~'t 3 MR. BORDENICK: Yes, sir, Judge Brenner. With
()
4 the exception of question and answer 12, we would 5 support the County in its motion. The reason we make 8 the exception on question 12 is that, while the 7 testimony is somewhat general and perhaps isn't even 8 very much in context if the rest of it is stricken, the 9 testimony does discuss isometric drawings which are used 10 in devising procedures for water hammer.
11 That is not specifically mentioned, so I guess 12 what I am saying is, given the benefit of the data on 13 that particular question and answer, we would not strike 14 or would not support striking that particular question 15 and answer. But we would support the County with ,
18 respect to the balance of the questions and answers 17 which are the subject of the motion.
18 JUDGE BRENNER: Do you agree with the County 19 that those procedures have no bearing on the water 20 hammer and the discussion of how those procedures as 21 developed theref ore have no bea ring ?
22 (Counsel for the NRC Staff conferred.)
23 MR. BORDENICK: Well, we think as a general
() 24 proposition the questions and answers, water hammer, 25 migh t be included in the types of procedures that are O
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8547
() 1 addressed in the questions and answers. But water 2 hammer is not specifically called out in the testimony 3 in the particular procedures that are discussed in the 4 questions and answers. So we have some difficulty with 5 the specific relevance of the testimony in question.
8 (Board conferring.)
7 JUDGE BRENNER: Well, I won't put it as 8 succinctly a s my fellow Board members just did to me, 9 but we don't agree with your argument or the County's 10 argument and we are not going to grant the motion in any 11 part. We think LILCO's reply states it well and is 12 correct, that is that even though water hammer isn't 13 called out specifically in tha procedures or in those i
14 questions and answers, the reason is, if you believe 15 their testimony -- and that is something that we'll find 18 out about -- that is not the way the procedures are 17 designed to take ca re of wa ter hammer. That is, they 18 are considered overall and through.
19 And there is strong evidence that this just 20 isn't a n af ter the f act rationalization by a lawyer in 21 response to a motion to strike. Rather, quite to the 22 contrary, the testimony itself and the questions and 23 answers referred to in LILCO's response make clear that
() 24 that is LILCO's position . And in fact, in addition to 25 the ones cited by LILCO 's reply, we would add question O
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( ') 1 and answer 5 by the witness, which emphasiz es that there 2 is no specific calling out of wa ter hammer in the 3 procedures and they state why.
4 We will find out, when we get to the 5 litigation of it, if there is no settlement or partial 6 settlement. They do state that water hammer is 7 particularly focused on and mentioned in th e training, 8 and they attach training materials which my marginal 9 notes purport to refer to water hammer. Whether all of 10 those expressly reference water hammer or not is another 11 story.
12 And we have not forgotten Mr. Hodges' 13 testimony as to his views on what should be 1.1 the
\_) 14 procedures and we hope to be able to hear more on that, 15 also.
16 So the motion is denied.
17 As we stated, we encourage discussion of that 18 additional aspect of the human factors procedures 19 testimony for possible settlement and narrowing.
20 However, the Board might have questions notwithstanding 21 any settlement or narrowing, but it depends on what 22 agreement, if any, is reached.
23 MR. BORDENICK: Judge Brenner, I have an
['xj ; 24 additional item this morning which relates back to, I 25 guess prinripally Tuesday. This is on SC-27. Mr.
(b
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ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
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('} 1 Repka, who was then present for the Staff, served on the 2 Board and parties a copy of a SECY paper, SECY-82-111, 3 and I believe the Board requested specific portions or 4 requested an identification of specific portions of that 5 SE0Y paper which were relevant to the contention.
6 I can give that information. But I am also 7 informed that Dr. Possi, who is back in Bethesda, is in 8 the process of preparing a Staff position specifically 9 with respect to implementation of Reg Guide 1.97, Rev.
10 2, on this particular SECY paper as it specifically 11 relates to Shoreham.
12 I think if I give you the identifications of 13 the specific sections, in the absence of that Staff
\
()_
14 paper, which I may be able to get telecopied to me as 15 early as today and give out to the Board and parties 16 before we leave here today -- if not, we will get it to 17 the Board and parties as early as possible on Monday.
18 I can give you that specific identification 19 for the specific sections, but I don't think it is 20 really going to help you in the absence of getting this 21 S ta f f pa pe r , which I think will be more helpful. All I 22 can say is, in general, is if you will read --
I guess 23 the problem is the SECY paper was not prepa red n
( ) 24 specifically to deal with SC-27, of course, and the 25 paper does cover many items. There are several
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8550
( ]) 1 references to Reg Guide 1.97.
2 So my own view is it is not going to be very 3 productive for me to give you the particulars. I think, 4 although the documen t is long , it is fairly easy to find 5 the provisions or the sections of the paper that talk 6 about the Reg Guide question. But I think it is going 7 to be more productive for everyone to simply wait until 8 I get the Staff position from Dr. Rossi. And my 9 understanding is tha t it will rela te specifically to 10 Shoreham.
11 JUDGE BRENNER: All right, you've convinced 12 us. We will wait, partly because we are not going to 7, 13 get to it before the break nov.
( 4
' You call it a Staff paper.
14 I don't know if it 15 is.
16 MR. BORDENIGK4 Well, my understanding --
and 17 I guess the problem is I am getting information 18 secondhand because Dr. Rossi is back in Bethesda. My 19 information is it's not going to be a long document; a 20 couple of oages, actually. And I believe it ha s been 21 prepared, but it is undergoing certain reviews. And I 22 hate to use the overworked word of how long it will take 23 to go through the bureaucracy, but I understand it could
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(_,/ 24 be as ea rly as today. And we're going to arrange to get 25 it telecopied.
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() 1 And as you just pointed out, I think time is 2 not really critical since the contention obviously will f\ 3 not now come up until after the break. But in any
\_)
4 event, I will endeavor to get a copy of this position 5 paper as soon as reasonably possible.
6 JUDGE BRENNER: Let me suggest this, and this
,7 is maybe broader than what you were thinking. But I 8 don't want to get to SC-27 and find we have the same 9 problem that we had on SRV's with respect to the status 10 of the Staff review.
11 Now, if you just look at the Staff's testimony 12 you would think that, yes, we are going to have that 13 problem. LILCO has filed testimony. I recognize it was O 14 filed at the same time as the Staff testimony, so the 15 Staff didn't have the benefit of LILCO's testimony at 16 the time the additional testimony was filed.
17 We are going to, as soon as I figure out what 18 date today is -- today is July 30th. The last week 19 before the break is going to be next week. We are not 20 going to get to this issue that week. I would think 21 that if you file something in addition pertinent to that 22 testimony and the SECY paper and tie it all up nicely, 23 so that we understand what the story is, to be received
( 24 by the Board and the parties at the beginning of the 25 break, that is Tuesday, August 10th, that will be O
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() 1 sdequate and that will give you time to do a better 2 job.
3 What I have in mind is Staff's written 4 testimony -- and this is maybe going to be unfair, 5 because this is my shorthand, non-technical summary --
6 Staff's written testimony is, it's too early, don't call 7 us, we 'll ca ll you .
8 MR. BORDENICK: That's true.
9 JUDGE BRENNER: Thank you.
10 MR. BORDENICK: But I think this SECY paper 11 will have changed that.
12 JUDGE BRENNER: Okay. LILCO's testimony says
,, 13 it's okay because: A, we're going to do it; B, what
( l
\/ 14 we' re going to do is just as good; C, you don 't have to 15 do this for Shoreham because of these reasons. And 16 those are loose categories.
17 We would be very interested in th e Staf f 's 18 analysis of what LILCO is doing, particularlys do they 19 meet the guide now; if they don't meet the guide now why 20 is it okay to go ahead with the licensing; if the Staff 21 is going to require additional things la ter , is tha t 22 later before licensing or after licensing?
23 I just can't handle these abstract time frames n
(,/ 24 any more that we get on the Staff's testimony, without 25 the relationship to licensing. So tha t is why I'm (O
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8553 1 suggesting that you wait until August 10th and put it
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2 all together and let it be in the na ture of rebuttal 3 testimony to LILC3's, or follow-up testimony.
4 In addition, we think the contention is 5 susceptible to narrowing, if not settlement.
6 MR. BORDENICK: I think that process is 7 ongoing.
8 JUDGE BRENNER : I think the S taf f view of what 9 LILCO is doing would certainly be very useful towards 10 that settlement process and will alco be not vasted work 11 if it is not settled, because it will then be very 12 useful to the hearing process.
- 13 I' shouldn ' t get involved in the negotiating
\
14 process, and I don't know what you 've discussed so f a r .
15 If I was the County , I would certainly want to know what 16 the Staff thinks of what LILCO is doing before I decided 17 whether I thought it was good, bad or indifferent, since 18 it is the Staff's Reg Guide in the first instance that 19 we are starting fron.
20 I don't know if you agree with that or not, 21 Mr. Bordenick.
22 MR. LANPHER: Are we done with that item?
23 JUDGE BRENNER: Yes.
/~N l
( ). 24 MR. LANPHER: I have just a very brief inquiry 25 that was passed to me this morning. My understanding is
()
\.
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8554
() I tha t the security status reports are due next Tuesday, 2 correc t?
I~h 3 JUDGE BRENNER: Yes.
4 MR. LANPHER: And tha t is to be submitted in 5 writing. Is it the Board's desire to have someone who 6 authored or can answer questions concerning those status 7 reports available next week?
8 JUDGE BRENNER: Well, you know the reason we 9 required them. It is to decide whether to stay with it 10 a little longer or not. So we are not going to need 11 every nitty gritty detail of what is still open and what 12 is settled. But we are going to have to have quite a 13 good handle on the prognosis.
O 14 MR. LANPHER: I guess what I would really ask, 15 if you wanted someone who could respond to Board 16 inquiries, I would just like to be able to advise the 17 people. I'm not personally working on that status 18 report. We are dividing responsibilities and we just 19 have to alert Mr. Miller, frankly, to the need and when 20 to be available to the Board.
21 So I don't need an answer this minute, but if 22 you want to consult.
23 JUDGE BRENNER: Well, the sooner the better
() 24 next week, except I would like to finish the testimony 25 on SRV 's first , and then do it righ t a f ter tha t, I O
V ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8555
() 1 guess, unless there's a particular scheduling problem.
2 I would like to try to do it by the end cf the day on' (s 3 Tuesday.
4 (Board conferring.)
5 JUDGE BRENNER: Do you understand wha t we need 6 to kno'w? Not the detailed status from a technical point 7 of view of what is involved, but enough so that we get a 8 good handle for the prognosis of settlement.
9 MR. LANPHER: I understand that.
10 JUDGE BRENNER: Given that, I can't give you a 11 particular time. It would be good if they were 12 available by the end of the day on Tuesday. If whoever 13 is here than tells us they have to leave af ter Tuesday, b)
\/ 14 we will consider making an accommodation.
15 MR. LANPHER: Okay.
16 JUDGE BRENNER: We will be flexible, but the 17 other problem is I don 't wa nt to keep the SRV witnesses 18 over an extra day just because of that.
l 19 MR. LANPHER: Fine. That is all I needed to 20 know. Thank you.
4 21 JUDGE BRENNER: We are interested in seeing if 22 the parties are able to convince us that we really will 23 enjoy litiga ting tha t issue ourselves.
( 24 (Laughter.)
25 JUDGE BRENNER: We are ready to go with the ALDERSoN REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
I 8556 O testi o#1- we =>= teke e drier dreex 1r there is 2 nothing else before that. Why don't we break until 3 9:50.
4 (Whereupon, at 9:40 a.m., the hearing was 5 recessed, to reconvena at 9:50 a.m.)
0 7
8 9
10 11 12 13 O 14 15 18 17 18 19 20 21 22 23 24 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
I 8557 i
r~ 1 JUDGE BRENNER: We are ready to proceed with N ')s 2 the Coun ty's examina tion.
3 MS. LETSCHE: Judge Brenner, this morning I t 4 would like to bring up some examination on th e ne w 5 testimony submitted yesterday by LILCO and the Staff 6 concerning the SRV testing issue.
7 Whereupon, 8 RAYMOND M . CR AW FORD ,
9 JEFFERY L. SMITH, 10 STEVEN J. STARK, 11 JOHN J. BOSEMAN, 12 FRED HAYES, 13 JOHN J. KREPS,
/^T
(_) 14 C. A. MALOVRH, 15 ROBERT J. WRIGHT, -
16 MARVIN W. HODGES, 17 and FRANK C. CHERNY, 18 the witnesses on the stand at the time of recess, having 19 been previously duly sworn, resumed the stand and were 20 examined and testified further as follows:
21 CONTINUED CROSS EXAMINATION 22 BY MS. LETSCHE:
23 0 With respect to LILCO's response to question
() 24 number 1 from the Staff, which appears on page 2 of the written response submitted into evidence by LILCO 25 bwi ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8558
() 1 yesterday, I would like to ask either Mr. Smith or Mr.
2 Malo vrh a How do you know that the test facility dynamic 3 mechanical loads on the SEV's bounds the Shoreham 4 case?
~
5 Now, in reference to paragraph number 2 in 6 your answer to Staff question number 1, which discusses 7 the use of a ram's head discharge pipe configuration in 8 the test program as opposed to the " tee" quencher 9 configuration at the Shoreham plant --
10 MR. IRWIN: Ms. Letsche, excuse me. I don't 11 want to disrupt that question, but you ment}oned Mr.
12 Smith and Mr. Malovrh in reference to question 1. I 13 have indicated also that Dr. Crawford had been involved n %s 14 in that answer. You were not intending to restrict that 15 to any of the witnesses, were you?
16 MS. LETSCHE: Well, I'm questioning -- I 17 understand what you are saying, but I was asking for the 18 basis f or the sta temen t concerning the Shoreham-specific 19 conclusion, and that is why I addressed it to Mr.
20 Malovrh and Mr. Smith.
21 Let me, just to make the record clear, 22 indicate the particular portion of the LILCO response 23 I'm ref e rring to in my question, and that is the (0j 24 statement that the first length of the segment of piping 25 downstream of the SRV in the test facility was twice ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8559
() 1 that of Shoreham piping, thereby resulting in a bounding 2 dynamic mechanical load on the valve in the test 3 program.
4 JUDGE BRENNER: Where are you reading from?
5 MS. LETSCHE I'm reading from the paragraph 6 number 2 in the LILCO response to the Staf f 's question 7 number 1, which appears on page 2 of the written LILCO 8 response submitted yesterday.
9 (Panel of witnesses conferring.)
to WITNESS MALOVRH: As stated in the second item i
11 in our response, the first segment of piping downstream 12 of the valve on any of the discharge lines in Shoreham 13 is substantially longer -- I'm sorry, is substantially O 14- shorter than that in the test facility. The 15 significance of this feature is that the internal load 1
16 in the piping segment is directly related to the length 17 of the segment, namely the longer the segment the longer 18 the imbalanced load which will act on that first f 19 segment.
20 The significance, of course, of focusing on 21 the first segment is that the loads on that particular i
22 segment have the greatest significance in terms of 23 response on the valve. It is directly connected to the (n) 24 valve. And again, it is a fact that in the test 25 configuration the length is twice that of Shoreham; ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
i 8560 tR therefore the loads in'that test configuration will be
(_) 1 2 grea ter than in Shoreham and therefore a bounding (h
v 3 condition on the valve.
.4 BY MS. LETSCHE: (Resuming) 5 0 Mr. Malovrh, is this conclusion of yours 6 something that you've calculated or is it just your 7 engineering judgment based upon the piping 8 configuration?
9 A (WITNESS MALOVRH) It is not a judgment 10 sta temen t. It can be shown analytically that the -
11 unbalanced load in that segment is a function of the 12 length of the segment.
13 Q Mr. Cherny or Mr. Wright, has the Staff O
14 reviewed any analysis of whether or not the test 15 facility bounds the Shoreham case with respect to the 16 dynamic me:hanical loads?
17 A (WITEESS WRIGHT) In terms of Shoreham l
18 analysis, no. But let me confirn that we h ave a l
19 situation where there is a pipe or valve, the discharge 20 and the pressures in the test configuration are the same 21 as anticipated as st Shoreham. We have a fluid making a 22 bend and that would be the same force. We have a pipo I
23 that is longer.
1
( ,f 24 In calculating the moment on the valve, the 25 longer the soment arm the grea ter the momen t that is O
i ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
b ~. -
856-1.
g i
,t O ==1ao to be. ate =e4 oa it- aa* aet tuer ere riao is 2 that in the test configuration that moment arm is longer f 3 than what is a t Shoreham. And since we have the same
4 force, I think it is concludive that the moment on the _
5 valve would be greater in the test configuration. m
., t 6 (Counsel for Suffolk County conferring.)
! 7 0 Mr. Wright, is there, in your judgment is 8 there no possibility that the longer piping could not ,
% 9 impose a larger load? s. s h -
That would be my'judg' rent.
._ .x 10 A (WITNESS WRIGHT) 11 (Counsel for Suffolk County conferring.)
i 12 A (WITNESS WRIGHT) Would you rephraise that '
l 13 question? 'Instasi of saying yes to it, let me say that O 14 the longer -- since we have the same fluid-flowing 15 through the pipe under the same conditions, the longer .
! ~
16 that moment arm is' going te be -- in other words, the
. 17 longer the length of piping, that produces a larger l
18 moment. \ -
Now, if you would rephrase the question in 19
~ 20 terms of tha t.
/ 21 JUDGE JORDAN: Is this the moment that you're 22 i , talking about, the moment oE the valve e x te rn als , the 23 shell of the valve or the valve internals, the 73
! V y- 24 diaphragm?
25 WITNESS WRIGHI. Well, the moment comes
.O%
L- ,
~
t .
ALDERSoN REPORTING COMPANY,INC, g- 400 VIRGINIA /E., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 A .- -.
8562
() 1 external to the valve, but eventually works its way back 2 into the in ternsis. The larger the moment external to
( 3 the valve, the larger it's going to be internal.
4 JUDGE JORDAN So your concern is with the 5 distortion of the valve body as a result of the torque 6 produced from the external length of pipe, is that 7 right? Is that your main concern?
8 WITNESS WRIGHT: Yes.
9 JUDGE JORDAN: It is not directly with back 10 pressures or flows, the ra te of flow of the steam?
i 11 WITNESS WRIGHT: Well, that rate of flow is 12 going to result in the moment, and since they are 4
13 identical both in the Shoreham and the test 14 configuration, then the only difference becomes that 15 length of pipe.
16 BY MS. LETSCHE: (Resuming) 17 Q Mr. Smith or Mr. Malovrh, referring to the 18 answer to Staff question number 1, generally does that 19 answer apply to steam pops only?
20 A (WITNESS MALOVRH) The responce to that 21 question is applicable to either sL&am discharge or 22 water discharge events.
23 (Counsel for Suffolk County conferring.)
24 0 Mr. Cherny, I believe yesterday you described 25 this question as an optical question when you vore ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
8563
() 1 discussing its origin. Can you tell me wha t that 2 means?
3 JUDGE BRENNER: Ms. Letsche, just in the name 4 of efficiency, I don't think you recall what he said 5 correctly. He didn't say the question was optical. He 6 said optically the configuration was different. Is tha t 7 in effect where you're going?
8 MS. LETSCHE: What I'm asking Mr. Cherny to 9 explain a little further is what I understood his 10 . explanation yesterday to be of how this question was 11 generated by the consultant who asked it. And if I 12 mischaracterized what he said, I apologize for that.
13 BY MS. LETSCHE. (Resuming)
I l
('~)
d 14 0 Do you know what I'm referring to, Mr.
15 Cherny?
16 A (WITNESS CHERNY) Yes, I think I know what 17 you 're ref erring to. I don't remember my exact words, l
18 either. But I thought what I said was that, in 19 discussing the question with the consultant, that I had 20 the impression from him that the question was in large l
21 part optically motivated by the fact that everyone can 22 see when looking st the configuration that is depicted 23 in the tcst report that the discharge device, the ram's
( 24 head discharge device, is not the de vice that most of 25 these plants are using, including Shoreham.
O g 9 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8564
() 1 That is what I intended to say yesterday.
2 O Mr. Cherny, yesterday did you discuss the
{'T 3 LILCO response to the question that the Staff received 4 y es te rd a y with the consultant who initiated this 5 question?
6 A (WITNESS CHERNY) No, I ha ve not.
7 Q So you don 't know whethe r this answer by LILCO 8 would in fact satisfy the concerns of the consultant, is 9 that right?
10 A (WITNESS CHERNY) I would say that I have 11 discussed it sufficiently with him previously to 12 understand his thinking process and I don't think he 13 would have any problem with this response.
l O 14 Q Mr. Smith, directing your atten tion to page 3 15 of the LILCO written response to the Staff's question, 16 particularly paragraph B on that page, which is still in 17 the response to question number 1, why was the orifice 18 pla te in the discharge line located above the water 19 level?
20 A (WITNESS SMITH) I was not a party t o.
21 preparing this particular response. I believe Mr.
22 Crawford, this was his area.
23 0 That 's fin e.
{Ng,/ 24 Mr. Crawfo rd?
25 A (WITNESS CRAWFORD) As state in the testimony, C)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
1 8565 the testinony or the response to this question, an (f ]) 1 2 orifice plate was located in the line to ma ximize the l 3 steady state back pressure. So we provided a bounding (V 4 steady .c t a t e back pressure value which had the potential 5 for affecting the valve internals, and the orifice plate l 6 was located above the water because in the steady state 7 flow of steam or water through the line, and 8 particularly the steam portion of the valve, it would 9 not be appropriate to have that orifice submerged in the 10 water leg.
11 0 Was the orifice location and size the same for 12 the steam test as for the water test?
13 A (WITNESS CRAWFORD) Yes, it was the same 14 o ri fice , at the same location.
15 0 Were any water tests in the generic program 16 initiated with the SRV discharge line already full of 17 water?
18 A (WITNESS CRAWFORD) I'm sorry, would you 19 repeat the question.
20 0 Were any water tests conducted in the generic 21 program initiated with the SRV discharge line already 22 full of water?
23 A (WITNESS CRAWFORD) The submerged portion of
() 24 the line was full of water. But there is still an air 25 volume between the valve and the water level in the pool ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
8566 r
1 where you had the submerged pipe that contained air.
2 (Counsel for Suffolk County conferring.)?
3 A (WITNESS CRAWFORD) I might just add as a
, s 4 matter of clarification that that is the prototypical 5 situation when one initiates the shutdown cooling mode.
6 And I might clarify to the County that under normal 7 operating conditions, either with steam --
the safety 8 relief valve discharge *line is not full of water. It is 9 only the ta ilpiece tha t is submerged, that has wa ter in 10 it.
11 And when one initiates the alternate shutdown 12 cooling mode, there is initially that air volume in the 13 line.
7-V 14 0 Dr. Crawford, let me make sure I understand.
l 15 Is it true that there were no tests conducted with water 16 above the orifice?
17 A (WITNESS CRAWFORD) During the water flow test 18 where there was steady state flow of water in the line, 19 the orifice plate of course was subjected to the water.
20 During the steam test, the orifice plate wa s never 21 subjected to the water.
I 22 I'm not sure I sufficiently understand your 23 question.
( 24 0 Let me rephrase my question for you. Is it i
l 25 true that there were no tests, no tests initiated with O
1 ALDERSON REPORTING COMPANY,INC, l
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8567
() 1 water at the time of the initiation of the test above 2 the orifice?
3 A (WITNESS CRAWFORD) That is correct.
j 4 (Counsel for Suff olk County conferring. )
5 Q Mr. Hodges, let me ask you a question.
6 Couldn't an operator error while they were operating in 7 the alternste shutdown cooling mode cause subsequent i
l 8 valve openings to occur, which would make the result we 9 just talked about possible, that is an opening of the 10 SRV with water above the orifice, as we have been 11 discussing its location in th e test program ?
12 A (WITNESS H0DGES) I think I'm understanding 13 your question. But let me see if I can at least 14 rephrase it to see if I'm understanding what you're l 15 asking. You are postulating an operator error which may 16 close or reopen a valve, as an example. So that you are 17 postulating you would have the discharge line full of l
18 Water and now you are reopening the valve for the 19 discharge line full of water and you're asking, can that 20 happen.
21 0 That is correct.
22 A (WITNESS HODGES) Well, first off, in the i
23 reactor you don't have the orifice, so we're not talking l
24 about with or without the orifice for the reactor case.
25 The orifice itself is there to represent a line n
ALDER $oN HEPoRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
8560
() 1 resistance. You can characterize the orifice with a 2 friction coefficient and at least for steady state 1 3 purposes tha t would be basically the same v alve or the (d 4 same orifice plate characteristic, whether you were 5 working w? th steam or with water. There are water 6 versus steam density differences that you have to figure 7 into the calculation, but basically the same 8 coefficient.
9 There would only be some slight effect, if you to are looking at dynamic differences. And if you had the 11 valve closed for a momentary period and then reopened, 12 there would be some draining of the line but there could i
13 still be maybe a substantial leg of water in the pipe, 14 just depeniing upon how long you waited before you 15 reopened it and whether or not you drew a vacuum.
16 So that little scenario was maybe a little 17 long-windad, but I suppose it is possible.
18 0 Do you know what the load would be on the 19 valve if such a scenario did happen? And let's forget 20 about the orifice discussion, because we understand that 21 the orifice was simulating the " tee" quencher at the 22 Shoreham plant in terms of the back pressure. But in
. 23 the scenario we've been discussing, the possibility of
') the valve opening with water in the line, lo you know I s) 24 25 what the load would be on the SRV?
i (1)
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8569
()_ 1 A (WITNESS HODGES) I don' t know what the load 2 would be on the SRV. I don't know what the load -- I r~.
(.(
(_)
3 haven't looked at the load on the SRV for the test, for 4 the case that they have tested in terms of the force, as 5 far as the numerical value. Maybe these other people 6 have. I just havan 't looked at the numerical value.
7 But the load that is being applied to the 8 valve is really basically, if you are starting with 9 water next to the valves, which is what you are doing in 10 this case, it is a flow force on the valve and whether 11 the pipe had wa ter or air downstream, I don 't think it 12 would make much difference to the valve. It might make 13 some difference to the piping, but not to the valve.
O V 14 JUDGE BRENNER: Mr. Hodges, maybe I lost the 15 trend of this a few questions ago, and perhaps what I'm 16 going to ask you now will reflect that. You are 17 starting out postula ting wa ter in the line in the 18 reactor, because the questioner asked you do to that, 19 correct?
20 WITN ESS HODGES: We're postulating a couple of 21 things. First, we're postulating water in the steam 1 22 line up to the valve, and now she has postulated that l
23 you open the valve and have gotten water into the 24 tailpipe downstream of the valve and then reclosed the 25 valve. And now she wants to open it again, assuming O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8570 C)
(. 1 that there is water in the pipe. At least that's the 2 way I understand her question.
3 JUDGE BRENNER: Okay. If you are dealing with 4 scenarios like th a t, aren't you into the situation that 5 you believe wouldn't occur as part of your justification 6 as to why you don't wa n t to consider high pressure water 7 for Shoreham?
8 WITNESS H0DGES: No, we're talking, as I 9 understand it, cycling the valve a t low pressure, the 10 process of getting to the condition where you have water 11 there. You basically are opening the valves and holding 12 them open until you get depressurized, and you are not 13 increasing the water level until after you are O 14 d e p re ssu rized .
15 So at least the scenario I have been 16 discussing with Ms. Letsche, I am presuming that I'm 17 starting from a depressurized condition already and that 18 the operator, in trying to determine pressures or flow 19 rates may be opening and closing the valves to try to 20 establish the range th a t he is operating in.
21 JUDGE BRENNER: I guess I have no feel for how 22 reasonable the scenario is. Can you help me? You've 23 got the depressurized sta te.
/~) His operating
(,/ 24 WITNESS HODGES: Okay.
25 procedures direct him to first depressurize. So once he O
ALDERSON REFORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., W ASHINGToN, D.C. 20024 (202) 554-2345
8571
(') I has depressurized, then he floods the vessel and the 2 steam lines with water. His procedures tell him that gw i 3 with one valve.open for the Shoreham design -- and this tb 4 varies somewhat from plant to plant, but for Shoreham, 5 with one safety relief valve open he gets sufficient 6 flow from either his-RHR or his core spray pumps-through 7 the core and the valve and all of the piping to maintain 8 the temperature rise in the wate r passing through the 9 core at 100 degrees or less. And this is basically the 10 criteria that is used for determining how many valves 11 that he would open.
12 But if the operator for some reason or another 13 decided he wanted to try to, or wa n ted to try a r'T
"#' 14 different valve, it is a possibility that he -- his 15 procedures are pretty clear, so I wouldn't expect him to 16 be doing this. But you can let your imagination wander 17 and say, yes, there are lots of things that he might 18 do. And that is what I'm getting towards with Ms.
19 Letsche.
20 JUDGE BRENNER: In any event, the conditions 21 would be present in the reactor where if he did that you 22 would end up in that situation?
23 WITNESS HDD3ES: I didn't understand your last 24 question.
25 JUDGE BRENNER: The conditions in the reactor O
ALDERSoN RhPoRTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
< 8572 m
1 would be such that if he made that one error then you 2 would be in the situation, at least leading into the r~S.
t 3 situation, that Ms. Letsche is talking about. And then V 4 we have got to go further in this scenario?
5 WITNESS HODGES I think you could conceivably 6 get to the situation where you had come water in the 7 tailpipe when you reopen the valve. But as far as the 8 load on the valve and what the valve will see, I don't 9 think it's really going to be any different, because 10 thst's going to be determined by the flow force of the 11 water going through the valve, and that's going to be 12 determined by the pressure upstream of the valve and the 13 fact that the water is already there.
C) 14 So I don't see any different effect on the 15 valve. The only difference tha t I see may be in th e 16 amount of water yoI have in your piping to determine the 17 load on the piping, and it will have drained down 18 somewhat before you reopen it, and so it's hard to 19 determine what tha t water level would be.
20 JUDGE BRENNER: Ms. Letsche, were you assuming 21 all the low pressure situations that I've been 22 discussing now with Mr. Hodges?
23 MS. LETSCHE: Yes, Judge Brenner, I was. We (h
.s,/ 24 were talking about being in the alterna te shutdown 25 cooling mode and we were talking about a low pressure ALDERSoN REPORTING COMPANY,INC, 400 VIRGIMA AVE., S.W WASHINGTON D.C. 20024 (202) 554-2345
8573 situation. The way Mr. Hodges characterized my
(]) 1 2 questions was exactly what I had intended.
I~T 3 WITNESS CRAWFORD. May I attempt to provide 4 some small amount of clarification?
5 MS. LETSCHE Judge Brenner, I would prefer to 6 continue this line f or a few moments longer with Mr.
1 7 Hodges, and then I would more than welcome Dr.
1 8 Crawford's comments.
9 JUDGE BRENNER: All right.
10 BY MS. LETSCHE: (Resuming) 11 0 Mr. Hodges, has the S taf f reviewed any test 12 results or any analysis of the load on an SRV, given the 13 conditions we'have been discussing for Shoreham?
O 14 A (WITNESS HODGES) I think we have better than 15 an analysis. We have this test.
16 0 What test are you referring to?
17 A (WITNESS HODGES) These low pressure tests 18 with water discharge.
19 0 Are you saying that th e generic test program 20 included a test where the valve was opened with water 21 above the orifice, and we're talking about the test 22 program now?
23 A (WITNESS HODGES) You asked me a question
() 24 about the valve. I'm talking about -- we're talking 25 about loads on the valve. Now, if you are talking about O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
8574
() I the bending moments -- I was thinking in terms of 2 internal loads on the valve. If you're getting at 3 bending moments, the tests have already been run with 4 the line full of water while the test is going on.
5 Maybe I have been answering a different 6 question from what you asked. I 'm not certain.
7 JUDGE CARPENTER: Ms. Letsche, may I ask a 8 question?
9 MS. LEISCHE: Certainly, Judge Carpenter.
10 JUDGE CARPENTER: Mr. Ho d g es , did the test 11 spectrum include the case you just alluded to, where the 12 discharge line is full of water and an impulse is
_s 13 applied to that slug of water, and have the various 14 forces that are generated in that transient been looked 15 at either analytically or in the test procedure?
16 WITNESS HODGES: I don't think so. But what 17 you have is a slug of water running down an empty pipe,
. 18 vhich might be, I think, a little more se ve re .
t i
19 JUDGE CARPENTER: But come back to the
! 20 postulated condition nova stationery water to which an 21 impulse is applied, with its mass in the pipe, its 22 potential for creating torque in the pipe , but starting 23 from the water being static and that impulse applied.
(A
,/ 24 WITNESS HODGES: I don't believe that was 25 tested.
l
! ALDERSoN REPORTING COMPANY,INC, l
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 L
8575
() 1 JUDGE CARPENTER: Thank you.
2 WITNESS WRIGHT: May I add to that question?
3 Since these pipes a re at some angle and the valve must 4 close, I'm not sure that at any time you could say that 5 you have a static liquid situation in the discharge pipe 6 until you reach the top level of the suppression pool.
7 WITNESS CRAWFORD: May I add something?
8 MS. LETSCHE: In just a minute, Dr. Crawford.
9 WITNESS CRAWFORD: I think we are losing 10 perspective about what the time involved is in the water 11 column.
12 JUDGE BRENNER: We give the questioner some 13 reasonable flexibility, but we vill get back to you.
O 14 MS. LETSCHE: It will be just a minute, I 15 think.
16 BY MS. LETSCHE: (R esuming )
17 0 Mr. Hodges, has there been any analysis 18 performed of the load on the piping under the conditions 19 we have been ' discussing, the analysis with respect to 20 Shoreham or with respect to the generic program?
21 (Panel of witnesses conferring.)
22 A (WITNESS H0DGES) Maybe Mr. Wright or Mr.
23 Cherny could answer the load on the piping question. I 24 have not reviewed the load calcula tion for the piping.
25 A (WITNESS WRIGHT) For those exact conditions l
l ALDERSoN REPORTING COMPANY,INC, l
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 l
1 8576 that we have been referring to, no, it has not. I would
( )f 1 2 add thst, in terms of the tests that were run and the
( 3 conditions under which they would run, I would not 4 expect to see forces or loads and resulting stresses 5 different by that situation. But the analysis that you 6 were asking for has not been done.
7 A (WITNESS HODGES) Also, intuitively, though, I 8 think to get at the point that maybe you are trying to 9 address, that the fact that you are opening this valve 10 with the pipe empty and now you have this slug of water 11 proceeding down the valve and impacting on the elbows 12 and creating the load on the piping, in that sense I 13 believe it would provide a larger load on the piping U,, than starting with the pipe full and providing an 14 15 impulse to that slug of water.
16 If you think back to some of the water hammer 17 concerns, it is the voided line that causes the bigger 18 problem.
19 (Counsel for Suffolk County conferring.)
20 C D r. Crawford, would you like to comment?
21 A (WITNESS CR AW FOR D) Thank you.
22 Let me attempt to explain to the County the 23 way the test facility was and the way the plant is, and O
(,/ 24 at least give my perspective on the time frame of this
~
25 type of incident that you are postulating and why this O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8577
() 1 type of incident that you a re po st ula tin g is not the 2 bounding case. And let's begin with a discussion of the
'i 3 plant configuration.
f'd
\
4 As I mentioned before, the plant configuration 5 consists of a discharge line between the valve and a 6 submergence in the pool containing air volume and a 7 vacuum breaker. The test facility contained a line 8 between the valve and the suppression pool. And we 9 discussed in our testimony why we felt that produced the 10 bounding loads.
11 In the case that you are postulating where 12 there is an inadvertent closure of the valve, the water 13 would drain in tha't line, would drain down into the pool
(~^)
/ 14 within five to ten seconds. The vacuum breaker would 15 actuate and there would be an air column between the --
16 following that water column as it drained down into the
, 17 pool.
t 18 'dithin tha t five to ten-second time period --
l I
i 19 and I haven't made that calcula tion; tha t is just 20 specula tion on my part of five to ten seconds. I'm sure 21 it is no longer than ten seconds. And the valve were 22 opened again, and if there was a question about what 23 kind of back pressure loads or transient loads that
() 24 would be introduced on the valve itself, you have to 25 remember now that you are dealing wi th a wa ter column O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8578
() 1 that is draining out of the line.
2 You are introducing some water at the valve 3 and the maximum pressure would be no greater than 250
(
4 psi on the upstream side of the valve. Now, in the 5 plant configuration -- well, before I go to the plant 6 configuration, let me add one other thing. When the 7 test was performed with the steam case and we had the 8 submerged leg, the transient pressure was considerably 9 higher than 250. So that clearly, in my opinion, 10 produced maximum back pressure loads on the valve and 11 the valve internals. That exceeded what you could 12 reasonably expect with the situa tion that you I
l 13 postulated.
14 And in the plant configuration the analysis is 15 made on the line both at the normal submergence level of 16 the water, as well as a conservative analysis performed 17 with an assumed higher water leg greater than the 18 submergence. And this load I think clea rly demonstrates 19 that the pressure that the valve had been analyzed for 20 and looked at, both in the test as well as in the plant 21 analysis, exceeds that postulated event, which would be 22 extremely rare since it is contrary to procedures and it i
23 only involves a very short time frame, time window, when
() 24 it could happen.
25 JUDGE BRENNEE. Let me make sure I understand k
l l
ALDERSoN REPORTING COMPANY. INC, 409 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
1 l
I 8579
() 1 this, Dr. Crawford, in more concise terms. The matters 2 tested for bound the event even if the water doesn' t I
\ 3 drain out as fast as you think it will drain, correct?
4 You said the water would drain into the pool in under i 5 ten seconds and th ro ugh the vacuum breaker. The air i
6 column would come after. l l
7 But even if that doesn 't happen, you have 8 still bounded, the tests performed still bound the load 9 that would occur, correct?
10 WITNESS CR AWFORD: Yes. I said with the steam 11 opening the transient back pressure with the normal 12 submergence would be greater than the 250 psi, and hence 13 would bound it.
O--
14 JUDGE BRENNER: And besides that, since the 15 water is going to drain so fast, you think tha t is 16 another reason not to consider it 17 WITNESS CRAWFORD: Yes, sir.
l 18 JUDGE BRENNER It is probably not important, 19 given the context, but why does the water drain so fast 20 if the valve is closed? What does it drain through?
21 WITNESS CRAWFORD: The water has an initial 22 momentum, depending upon the pressure a t which it was 23 forced through the valve. The vacuum breaker opens and 24 has a sufficient capacity to allow the water to maintain 25 its initial momentum, minus whatever friction losses i
ALDERSoN REPORTING COMPANY. INC, 400 VIRGINtA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8580
() 1 wo61d occur, plus the gravity head of the water draining 2 down into the pool is approxima tely 20 feet or more.
3 JUDGE BRENNER: I guess I don't know tha
(~j\
\
4 hardware very well. Doesn't the SRV have to be open for 5 the water to drain out of the discharge line into the 6 pool?
7 WITNESS CR AWFORD: No, sir. There is a vacuum 8 breaker just immedia tely downstream of the valve, and 9 that would actuate and allow air to enter into the line 10 very rapidly and allow the initial velocity of the water 11 to continue with very little degradation.
12 WITNESS MALOVRHs If I might just add one 13 thing to that. The calculated velocity at Shoreham l ' 14 would be on the order of 20 to 25 feet per second, such I
15 that if it maintained that velocity it would be about 16 five seconds to clear the line. There will be some 17 slowing because of the loss of the pressure, but I would i
! 18 agree with the ten second estimate of the longest time l 19 frame.
l 20 JUDGE CARPENTER Wha t condition would prevail 21 if the vacuum breaker f ailed to actuate? Is it still l 22 bounding?
23 WIT N ES S CR AWFORD: If the vacuum breaker in
() 24 the plant failed to actua te even d uring the normal steam 25 discharge -- let's take that case first -- there would ALDERSoN REPORTING COMPANY,INC, f
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8581
() 1 be a steam discharge wi th steam in the line after that 2 discharge, and when the valve closed that steam would 3 condense and draw the water back into the line. It is 4 for that raason that in the Shoreham plant I believe 5 they have redundant vacuum breakers that are equipment 6 to provide the assurance that there will be sufficient 7 vacuum breaker capacity, even under normal operation, to 8 prevent any significant water reflood back into the line 9 sufficiently very high above the initial level.
10 And certainly the same thing would be true 11 with the alternate shutdown cooling mode.
12 JUDGE CARPENTER: I'm not sure I followed
- 13 you. Did you tell me that you hadn't looked at the case
'- 14 where the vacuum breaker fails to actuate because there l
15 are redundant vacuum breakers and therefore it's not a 16 concern, or that you have done the analysis assuming 17 that the redundant vacuum breakers were not effective?
18 WITNESS CRAWFORD: Just a moment.
l 19 (Panel of witnesses conferring.)
1 20 WITNESS CRAWFORD: It is my understanding that 21 no analysis has been done assuming that both vacuum l
l 22 breakers on the line failed. These are two vacuum 23 breakers that are in parallel and it would have to be a
(_) 24 failure of either one of them, is sufficient to relieve 25 a vacuum that would exist. And no analysis was made
(~
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8582 O ' ese-1= taet sota re m a.
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l 7
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8
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i 10 11 12 13 0 14 15 16 17 18 l
19 20 21 22 23 lO 24 25 l
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l ALDERSON REPORTING COMPANY,INC,
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8583
() 1 JUDGE CARPENTER: Once again, I apologize. I 2 am fishing. I have a lot of experience with small bore 3 vacuum breakers over the years and their failure rates.
(
4 And I am trying to visuglize just exactly -- it is your 5 professional opinion that the probability of that joint 6 failure, for example, the work when mis-installing both 7 of them in some way is so small that it is not a 8 credible case?
9 (Panel of witnesses conferring.)
10 WITNESS CRAWFORD: Could I consult with my 11 colleague for just a minute?
12 JUDGE CARPENTER: Certainly.
13 (Panel of witnesses conf erring. )
l')
- 14 WITNESS CRAWFORD: Thank you for your 15 patience. These are two 10-inch safety-related vacuum 16 breakers that because they are safety related, are 17 inspected when installed, and there are specific 18 maintenanca programs.
19 It is my opinion that the reliability of these 20 vacuum breakers is such that in my professional opinion, 21 the assumption that they would both fail would be 22 extremely improbable. And to the best of my knowledge, 23 this is not a design case.
( 24 - JUDGE CARPENTER: Acknowledging that the 25 analysis has not been done, can you, more or less, by ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
8584
() 1 inspection, come to the conclusion that if this very 2 remote possibility were to occur, that it would be 3 significant at all? Would it really produce substantial 4 loads relative to the kinds of loads that have been 5 tested? And I realize that you are speculating now, and 6 this is not based upon analytical results.
7 WITNESS MALOVRH: First of all, I think we 8 need to distinguish between whether or not we are 9 talking about the liquid discharge case or the high 10 pressure steam discharge case. The question originally 11 arose regarding the liquid pressure discharge, and as 12 Dr. Crawford had mentioned, even if there were still 13 water in the line at the time of a subsequent actuation, I
l l s/ 14 the dynamic back pressure.that would occur under that 15 scenario would not be as great as that which did result 16 from the high pressure steam discharge.
17 So that even if we assumed all of the worst 18 possible consequences, the failure of the vacuum breaker 19 to slow the water leg, et cetera, the loads would be 20 less than the high pressure steam condition.
21 JUDGE CARPENTER: Yes, I see. Thank you very 22 much. I hope my interruption was helpful.
23 MS. LETSCHE Judge Carpenter, it was.
7 (j 24 JUDGE BRENNER: Ms. Letsche, where is this 25 water in the line that you are postulating? Upstream or
,m.
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8585
(~^; 1 downstream of the SRV7 v
2 (Counsel for Suffolk County conferring.)
3 MS. LET5CHE: Judge Brenner, the situation I 4 am postulating is in the alterntate shutdown cooling 5 mode, and the line would be full of water, so it is 6 going to be both.
7 JUDGE BRENNER: Now, I think it was Dr.
8 Crawford or somebody told me that the water would d rain 9 so rapidly through the vacuum breakers that there is 10 water upstream of the SRV, also.
11 WITNESS CRAWFORD: No, sir. If the valve were 12 closed and we were still in the alternate shutdown l
,- 13 cooling mode, I think there is reason to believe th a t i i
\# 14 there would be water continuing to be upstream of the 15 valve, and that the vacuum breakers would actuate and 16 the water column downstream of the valve would continue 17 to drain out into the pool within a five to ten-second 18 time pe rio d.
19 JUDGE B'ENNER : Okay. But does your previous l 20 answer that the tests performed bound the load si tua tio n 21 with water still present upstream of the SRV? Is that l 22 still correct? I think the record was left with a 1
23 misimpression that there is no water in the line; that
(,/ 24 all wa ter in the line drains out through the vacuum 25 breakers which, of course, is not correct.
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1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8586
() 1 And that is all that I am getting at, so I 2 vant to make cure your answers as to the bounding
, (} 3 analysis still apply with the water upstream of the SRV.
\_/
4 WITNESS CRAWFORD: In the response that I gave 5 to you before I had implicitly considered that the water 6 would be upstream of the valve.
7 JUDGE BRENNER: Thank you.
8 BY MS. LETSCHE (Pesuming):
9 0 D r. Crawf ord , your conclusion about the 10 testing bounding this scenario we have been discussing 11 -- that is, with respect to the dynamic back pressure 12 involved in that condition, is that right?
f 13 A (WITNESS CRAWFORD) Yes. That is specifically 14 with regard to the transient or dynamic back pressure, 15 because in my opinion, that is the worst case for a 16 steady state. I mean, we are talking about five 17 seconds, and I think it is quite clear f rom a technical 18 basis that the loads would become lower. I mean, I
(
19 didn't give you the response assuming some type of 20 steady state flow.
21 0 But the question of the amount of the load 22 resulting from a combination of back pressure, water 23 weight, water impulses on the piping -- that hasn't been
/~T tested f or or anla yzed, has it?
24
(/
25 A (WITNESS MALOVRH) May I respond to that? The O
V i
ALDERSoN REPORTING CCMPA'iY,INC, 400 VIRG:NIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8587
() 1 scenario that you just de sc ribed could result in 2 somewha t la rger dynamic loa ds on the pipe than if the 3 initial water level was at the pool surface. However, f'\
d as the test indicated, the dynamic loads on the piping 4
5 during the water discharge event were significantly less 6 than the dynamic loads on the piping during the steam 7 discharge event.
8 And therefore, although I couldn't quantify it 9 at this time, if there was some increase in the dynamic 10 load I wouldn't expect it to be a major one. And I 11 believ that the conclusion would still hold that the 12 dynamic loads due to the steam discharge wo uld be i 13 bounded.
14 0 But that wasn't included in any of the testing 15 that was conducted either generically or for Shoreham, 16 is that right?
17 A (WITNESS MALOVRH) That is correct.
18 0 I would like to move on to the LILCO -- excuse 19 me, Judge Carpenter.
20 JUDGE CARPENTER: Just one question.
21 Con side rin g the other line of evidence, which is the l 22 valves that have been in long service, is there any 23 record that these valves af ter a long service show signs
() 24 of having been s tressed in th e sense that whoever does 25 the testing and so on rejects the valve as not suitable ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
, 8588
() 1 for refurbishing because of distortions from the kind of Is there any evidence 2 forces that we are talking about?
f'T 3 that forces like the ones that we have been speculating
%) 4 about are actually occurring in the field?
5 A (WITNESS BOSEMAN) To the best of my' Knowledge, 6 sir, there is no evidence. I would like to add,
/
7 however, that the specific two-stage valve tested in the 8 test program was a valve that had 'been in service. It 9 was donated by a utility and that is the valve we te sted .
10 To be precise on how many service years it had 11 seen before, I really don't know.
12 JUDGE CARPENTER: Thank you.
13 BY MS. LETSCHE (Resuming): . . _
14 0 Mr. Cherny, I would like to direct your 15 a ttention to the LILCO response to staf f question 2, l
16 which is contained on page 5 of the LILCO written i
'17 response. You were discussing yesterday in your 18 testimony the percentage increase in the dead weight 19 load resulting from water. Have you had an opportunity l 20 to -- and I think you were saying yesterday that you l
( 21 anticipated maybe something like an 80 percent increase ,
l 1 22 in that -- have you ha'd an opportunity to evaluate'that i
. 23 percentage increase?
I I
() 24 A (WITNESS CHEPNY) No, I have not.
You stated yesterday I believe, in discussing
- 25 0 i
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t I
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l A4.DERSON REPORTING COMPANY. INC.
l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 I
t 8589 1 this respons6 -- and I don't mean to be quoting you but
(')J L
2 I want to' refresh you recollection about your testimony 3 -- that the alternate shutdown cooling mode was a very 4 :Inu su al condition or low probability event. 'Why do you 5 say tha t?
,\ _
s 8 A (WITNESS CHERNY) Well, I guess for a couple ot 7 reasons. One is in a fair number of BWR reactor years 8 of operati.ig . experience already, I'am not aware that 9 this case has over come up. If it was a high s 10 probability event someone would ha ve used i t already.
11 0 This is an event that is provided for in the i 12 emergency or the ope ra ting procedures of most plants',
i 13 isn't it? c' ,
i
( -
~
14 JJDGE BRENNER: Ms. Letsche, I am sorry, could 15 you repeat your question? I missed sit . --t 16 MS. LETSCHE: The one I am now askino?
17 JUDGE BRENNER: Yes. .
18 Bi MS. LETSCHE (Resuming):
19 0 This condition, usin[ the.alterna,te shutdown 20 coS11ng mode, is something that is included in 21 procedures o f plants, 3 J: i t? y 22 A (WITNESS S c' W ' I believe so, but I would 1 23 like to have Mr. Hodges com;;ent on that.
/\
f f 24 A (WITNESS HOD 1ES) Yes, this is included in 25 Shoreham's emergency procedures, but by design, these
/
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
8590
() 1 emergency procedures cover many things that are ra re 2 events, and in fact, goes to cases where there are all 3 sorts of multiple f ailures and degraded conditions which
(
4 have not occurred and are not very likely to occur. But 5 the idea is to provide the operator with the guidance 6 now, so that if he does confront it he knows what to do.
7 JUDGE BRENNER: Es. Letsche, I don't 8 understand the pertinence of this line of questioning, 9 because in considering what we are talking about is the 10 SRVs and loads on the SRVs and whether the test program 11 is applicable to Shoreham, and to some extent, given the 12 additional questions a sked, whether the test program 13 accounted for the questions the staff asked.
14 And as I understood it, unless I just missed 15 the boat somewhere, regardless of whether it is rare or 16 happens every day, the alternate shutdown cooling mode 17 is assumed in the te sts. So for purposes of this 18 anlaysis, just assume it occurs. Why do we care about 19 the probability?
20 MS. LEISCHE: Judge Brenner, what I am doing 21 here is cross examining the testimony of r. Cherny i
22 yesterday.
23 JUDGE BRENNER: Answer my question as to I don't care if he said it or not.
( 2<4 relevance.
25 MS. LETSCHE: I am, Judge Brenner. In which O
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8591
() 1 his discussion of the anticipated loads and the 2 difference in anticipated- loads with respec t to the test
'\ 3 facility and the Shoreham facility was couched with his (V 4 conclusions that this is a very unusual or low 5 probability event. And I think it is within my right 6 to probe the validity of that conclusion, since that was 7 part of his reasoning process in getting to his 8 conclusion.
9 JUDGE BRENNER: I don't understand the 10 relevance, even after hearing your answer. Unless you 11 can show that Mr. Cherny misunderstands what was done to 12 the extent that he assumed that the alternate shutdown l 13 cooling mode would not be used to present loads on these l
(# 14 valves, that would be the only possibility relevant and
(
15 you didr.'t ask that question.
16 MS. LETSCHE: Judge Brenner, I think the 17 relevance is a little bit different from that, and that i
l 18 is whether or not Mr. Cherny's opinion of the 19 probability of this event affected the extent or the 20 degree of his review of this information.
l 21 JUDGE BRENNER: I just don't agree. Mr.
22 Cherny, in thinking about the test results and the loads 23 and whether or not the tests are applicable to Shoreham
,- 24 and whether or not the tests in themselves were valid, 25 did you appreciate the fact that the consideration that Q
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8592
() I the alternate shutdown cooling mode has to be assumed to 2 occur, regardless of whether the probability is low?
4
('\
- /
s 3 WITNESS CHERNY: I am not completely sure I 4 understood what you sa id , but I think the answer is yes.
5 (Laughter.)
8 JUDGE BRENNER: Well, that is no good.-
7 (Laughter.)
8 What don't you understand? Let me ask it 9 another way.
10 WITNESS CHERNY: I have assumed it occurs, if 11 tha t is- wha t you're asking.
12 JUDGE BRENNER: Yes, that is what I am 13 asking. It is just not per tin en t to this line, Ms.
i O 14 Letsche, in light of that.
! 15 BY MS. LETSCHE (Resuming):
j 16 Q Mr. Podges, I would like to direct your 17 attention to page 7 of LILCO's written response and l
18 sta f f 's que stions, particularly the last sentence on 19 that page where it states that the effect of dead load 20 weight does not affect the ability of SRVs to open to 21 establish the alternate shutdown cooling path, since the 22 loads occur only af ter valve opening. Do you agree with I 23 that statement, that in all cases the dead weight load
( 24 of water could not be present prior to a valve opening?
25 A (WITNESS HODGES) A few minutes ago 'ie talked O
ALDERSON REPORTING COMPANY. INC,
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400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8593
("; 1 about a case where the operator may cycle a valve and
(_/
2 possibly -- and it has to be a fairly quick cycle. I 3 think the key word here is to establish the alternate 4 shutdown cooling path. And also, the fact that there 5 are 11 valves and only one is needed.
8 So if, for some reason, he made an error and 7 if what we are saying is that the test results are 8 incorrect, which I don't think they are, but if they 9 were all he has to do is go to another valve which has 10 not been cycled yet, and he is back to the original 11 condition and ost.ablishes his path.
12 Q Mr. Cherny, in reaching your conclusion or 13 preliminary conclasion with respect to LILCO's response N' 14 to staff question 2, did you examine the as-built piping 15 drawings provided by LILCO?
16 A (WITNESS CHERNY) I have looked through them, 17 yes.
18 0 When did you do that?
19 A (WITNESS CHERNY) Yes t e rd a y , and a little bit 20 this morning.
21 0 I would like to cove to the LILCD response to 22 staff question 3, particularly page 8 of th e written 23 LILCO response. Mr. Wright, directing your attention to t's
( / 24 the second paragraph of the response on page 8, 25 particularly where it talks about the anomaly and the vs ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
8594
() I testing of the ta rge t rock two-stage SEY, it states tha t 2 on water test run number 3, two of the test systems, th e
\ 3 GN2 regulator failed. Do you know whether the tests of (G 4 tha t GN2 regulator caused the safety relief valve not to 5 function?
6 A (WITNESS WRIGHT) I would assume tnat since it 7 is reported tha t whenever the valve was called to open, 8 it opened. That there were not failures in this 9 particular case. I don't know whether the valve was 10 asked to open or not to open.
11 0 Do you know whether this regulator failure was 12 due to SRV dynamic loads?
13 A (WITNESS WRIGHT) In my opinion, I would be O 14 surprised if that were true. I can't think of any 15 teason that a regulator would fail due to dynamic loads 16 on the valve.
17 0 Do you know whether it did or not, though ?
18 A (WITNESS WRIGHT) I do not know.
19 (Counsel for Suffolk County conferring.)
20 0 Mr. Hodges, I would like to direct ~your 21 attention to the LILCO response to staff question 4 f
22 Are you satisfied, Mr. Hodges, that liquid flow is only 23 possible in the alternate shutdown cooling mode?
() 24 A (WITNESS HODGES) "Only possible" is very 25 restrictive, and if you take absolutes, then I have to l
ALDER $oN REPORTING COMPANY,INC, 1
l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8595 say it is also possible under high pressure conditions.
(]) 1 j
l 2 But if we are looking at the probability of it occurring j j (~hg 3 under high pressure conditions, then I think that
\_/
4 probability is small. And we have also looked at loads ,
5 on piping as a result of that, and we think that it is 6 generally bounded by the steam line break, which is at 7 least as probable if not more probable than the ;
8 condition we are talking about.
l 9 JUDGE MORRIS: Excuse me, Ms. Letsche, could I 10 back up a ninute and ask Mr. Boseman if he knows what 11 caused the failure of the GN2 regulator?
12 WITNESS BOSEMAN: Yes. It is a valve in the 13 system that controls the pressurization of the water 14 that was in the tank that was used at the test 15 facility. It had failed and had not pressurized the
(
16 water tank according to procedure.
l 17 As a result of that, when the test, the water 18 run test, was run, when the valve was opened the 19 profile, the pressure profile, that we required to be 20 had was not achieved. Therefore, the test was not a 21 valid test.
22 In finding out why that did not occur, we had 23 to back into it and we found out that one of the l
l 24 technicians apparently had not tied in the electrical l
25 line to the regulator, and it had been damaged during O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554 2345
8596 (m) 1 the time that they had serviced it. So that it limited v
2 any nitrogen from pressurizing the water tank.
3 I would like to add one thing. We are talking 4 about cause and effect. The v31ve did not cause the 5 regulator to fail, and the valve did open and close 8 during that run, even though the run per se, the 7 pressure profile or the flow profile was not what we 8 were looking for; it was a lot less.
9 JUDGE MORRIS: Thank you.
10 BY MS. LETSCHE (Resuming):
11 Q Mr. Hodges, have you reviewed the Shoreham 12 level 8 trip?
l l
,s 13 A (WITNESS HODGES) There are level 8 trips on i
(
14 HPCI, RCIC and feedwater, and I have reviewed all three, l
15 yes.
l 18 Q Does the level 8 trip cover the CRD hydraulics?
17 A ( WITNESS HODGES) No.
18 (Counsel for Suffolk County conferring.)
19 Q Are there any other high pressure injection 20 sources that the level 8 trip does not cover at Shoreham?
l 21 A (WITNESS HODGES) No.
22 JUDGE BRENNER: Ms. Letsche, could I go back 23 one, and maybe again this shows my ignorance of plumbing T'T Are you assuming that the hydraulic
( ,1 24 in the reactor.
l 25 fluid for the CRDs, the control rod drives, could cause p
t, /
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8597
(} 1 an overfill of the reactor, so tha t at high pressure you 2 would get water through the SRVs?
3 MS. LETSCHE Yes.
4 JUDGE BRENNER: Mr. Hodges, is that something l
5 tha t could h appen?
6 WITNESS H3DGES: Part of the water for the rod 7 drives go into the vessel primarily to cool the control 8 rods. It goes into the region between the cannisters 9 that surround the f uel. The purpose there is to cool i
10 the control rods and prevent boiling on the control rods.
11 So there is a direct injection to the vessel 12 from the control rod drive system. It is not a very l
13 high capacity system; it is about 100 gpm, and so, it l N i . \ 14 would take a very long time for that small flow rate to l
15 go up past level 7, past level 8, into the steam lines.
16 And the operator would be well a wa re, I think, of what 17 is going on.
18 JUDGE BRENNER: Do you want to give me an area 19 of how long you are talking abou t?
20 WITNFSS HODGES: I haven't made a calculation 21 for that low a flow rate, and frankly, I did make one 22 for the RCIC system which is about 425 gmp, and it has 23 been a couple of years since I did that. So my number
() 24 won't be precise. But it is on the order of I think 10 25 or so minutes f or that. It is a fairly long time period O
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l i
() 1 for that smaller system. I would have to go back and i 2 verify my Calculations to get the exact number because
() 3 4
it has been a couple of years since I did.that.
don't have that exact number at my fingertips.
I just 5 JUDGE JORDAN: Is it more than adequate to 6 take care of the boil-off rate?
7 WITNESS HODSES: The water from the control 8 rod drives?
9 JUDGE JORDAN: Yes, sir.
10 WITNESS HODGES: No, s ir .
11 JUDGE J3RDANs So if that were the only source 12 would the water con tinue to rise or would it fall?
13 WITNESS HODGES: If that were the only source O 14 of water, then it would continue to fall. But if you 15 have something else, then you are all right. But you 16 have got to get a long time, a long way out in time, 17 having been shut down for the control rod drive flow to
- 18 cause a problem. And in fact, even for the RCIC to.be 19 able to keep up with the decay heat, and flood-up f
20 requires having been shut down for a considerable period 21 of time, also.
22 WITNESS SMITH: Judoe Brenner, I believe we 23 can add a little nore detsil to th a t . The analysis tha t 24 se had for RCIC overfill event on a failure of level 8, 25 as Mr. Hodges just indicated, from the level 8 up
()
ALDERSON REPORTING CCMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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() 1 through the main steam line up to the inlet of the valve 2 is .t 1000 seconds, which is about 16 or 17 minutes.
(\ 3 The CRD system is significant -- the flow
- x-) 4 would result as a bypass on the CRD drives, and that 5 would vary depending upon on the last time that the J
6 drive was repaired. It could be from less than 1 gpm on 7 up to about I guess 2 1/2.
8 So the flow you are talking about is about 200 9 opm, 250 gpm. And we had hypothesized that back very 10 early in the II.D.1 analysis, as one of these far out 11 events, and we were talking about -- we figured close to 12 an hours beween a half an hour and an hour just from the 13 level 8.
14 Now remember, the level would be normal, so 15 the operator would have all of that added time, and it 16 comes up to well over an hour to get it from normal 17 o pe ra ti ng level up to the SRV.
1 18 JUDGE BRENNER: M r. Hodges, did you want to 19 add anything?
20 WITNESS HODGES: I was just curious. Mr.
21 Smith, if that was with one or two CRD p ump s running ? I 22 am surprised you would get that much with only one pump 23 running.
() 24 WITNESS SMITH: You have me, Mr. Hodges.
25 (Laughter.)
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1 JUDGE BRENNER: Do you mean you assumed both
(])
- 2 pumps? f 1
3 WITNESS SMITH: I do not know the answer to i \
4 tha t.
l 5 WITNESS HODGES: I believe his answer is 6 probably for both-of them running, which would not 7 normally be the case, but they can be both turned on but l
8 one is usually su f fi cie n t .
9 JUDGE BRENNER: Ms. Letsche, within reason, 10 you can ask all questions that are relevant, and I am 11 not saying it is not relevant. But you have got 12 consultants and it is better if we stay with the 13 questions that might be of real concern in terms of 14 whether or not we should worry about high pressure 15 liquid flow. You judge accordingly.
16 BY MS. LETSCHE (Resuming)4 ,
i 17 0 Hr. Hodges, directing your attention to page
- 18 11 of LILCO's response to staff question 4, close to the I 19 middle of that page it states, "Of the 13 events l 20 referred to . . . " -- a n d they are referring to the EWR 21 owners group test program -- "
...only 8 are applicable 22 to the Shoreham plant because of its design and specific 23 plant configuration."
Has the staff performed any review of -- or,
[
( 24 25 has the staff received any in f o rm a tion from Shoreham ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554-2345 .
8601 1 indicating whether or not there are any events in
(}
2 addition to the 13 analyzed by the owners group, which l [ 't 3 could result in wster or two phase flow to the SRVs?
4 A (WITNESS HODGES) Could you repeat your 5 question one tine just to make sure I understand what 6 you are asking?
7 Q Has the staff received any information from 8 Shoreham concerning whether or not there are any events, 9 in addition to the 13 events evaluated in the owners 10 group study, that at Shoreham could result in a water or 11 two-phase flow through the SRVs?
12 A (WITNESS HODGES) I don't recall any being 13 discussed. I think we have hid a couple of meetings on
-- 14 this sometime ago, and I just don't recall any 15 additional ones being discussed.
16 0 Have you reviewed any information concerning 17 the validity of the conclusion that for Shoreham, the
! 18 alternate shutdown cooling mode is the condition that I
( 19 provides the maximized dynamic forces on safety and 20 relief valves?
21 A (WITNESS HODGES) I think you are, again, going 22 back to the words in the original requirement there, and 23 that was referring to expected conditions. And so, we l
t have to put that condition on this maximization. And
( 24 25 with tha t cond ition , the answer is yes.
O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8602
() 1 Q And what information is it that the staff has 2 reviewed in reaching that conclusion?
3 A (WITNESS HODGES) I say prior to receiving this
(~h v 4 particular letter, I had reviewed level 8 trips for HPCI 5 and RCIC and for f eedwa ter. I had looked at flow rates; 6 I had looked at operating procedures and looked at the
, 7 general things as far as the plant layout.
8 What I am asking LILCO to provide to finish 9 fleshing out the response here is the details of what 10 they did look at for the comparison.
11 0 Ihat is the information that you haven't 12 gotten yet?
13 A (WITNESS HODGES) That is correct.
(~
l
! \' 14 0 Mr. Hodges, I would like to direct your 15 attention to the LILCO response to staff question 5.
16 First of all, on page 13, in the second paragraph of the 17 answer on that page it is stated tha t cycling to assure 18 the cooldown rate is maintained within the tech spec 19 limit would require on the order of 1 to 10 cycles of l
20 the SRV. Have you reviewed any analysis to support that 21 estimate?
22 A (WITNESS H0DGES) I have not revieved an 23 analysis to support that estimate. However, the 24 estimate seems reasonable on this basis. The cycling of 25 the valve -- that is going to be done by the operator to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
0603
() 1 con trol the cooldown rate to maintain the cooldown rate o
2 is less than 100 F per hour. The sta rting point is
(\ 3 about 550 degrees, 540, in tha t ' range. And before he x.)
4 can start with the shutdown cooling, he is going to go 5 down to about 250 degrees, so he got a 300 degree 6 Fahrenheit delta t that he has to worry about.
7 With that kind of a delta t, and looking at 8 what he would get with the depressuriza tion rate, I 9 would expect that he could actually accomplish such a 10 thing, the depressurization, with on the order of 5 or 6 11 cycles of the valve, maybe less. Just based upon 12 depressurization rates that I have observed with the 13 valve open.
14 Because the opera tor is having to make a 15 judgment and is going to be careful to be on the 16 conservative side of that cooldown rate, I would expect 17 it would be a few more cycles than that, and so 18 something may be closer -- the order of 10 or 12 might 19 be more exact. But the actual number is going to depend 20 upon the operator's decision of hcw many steps he wants 21 to actually take the cooldown rate in.
o 22 But he is going to go as close to his 100 F 23 per hour as he can without exceeding it. So when ther 24 say on the order of 1 to 10, I am not taking those as 25 exact numbers, but I think that is the right order of O
ALDERSON REPORTING COMPANY,INC, 400 V:RGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 magnitude.
2 0 Has the staff received from LILCO any f'] 3 documentation concerning these operator actions or the y;
4 expected cycling amounts or the number of cycles at the 5 Shoreham plant?
6 A (WITNESS HODGES) If you are asking if we have 7 specific information for the Shoreham plant for the 8 number of cycles in this particular case, no.
9 JUDGE BRENNER: Well, Mr. Hodges, if Ms.
10 Letsche is asking you about the numbe; of cycles, even 11 if you had all of the Shoreham-specific inf orma tion, the 12 procedures wouldn't be in terms of cycle 5 times or 6 13 times or 10 times, would it? It would be in terms of
( )
N/ 14 the cooldown, the goal of the cooldown and cooldown 15 rate, isn't that right?
16 WITNESS HODGES: That is correct. And in 17 fact, the procedures instruct the operator to 18 depressurize, and he has a te :h spe- requirement to try 19 to stay within 100 degrees F per hour, and those a re th e 20 things that are guiding the operator and not the actual 21 number of cycles.
22 JUDGE BRENNER: So not having the specifics 23 doesn't deprive you of any information in terms of the 24 answer you gave before?
25 WITNESS HOLGES: That is correct.
k o !
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("D 1 BY MS. LETSCHE (Resuming):
2 Q Mr. Hodges, di rec ting your a ttention to page
~~
(' 3 14 of the LILCO response, the second paragraph on that
't) 4 page states, "In order to a ssure continuous long-term 5 heat removal, the SRV is kept open and no cycling of the 6 valve is performed." Are you satisfied with that 7 response from LILCC?
8 A (WITNES3 HDDGES) Yes.
9 0 What would be the effect on loads if cycling 10 were performed by operator error?
11 A (WITNESS HODGES) I thought we discussed that 12 earlier. There is a possibility, if you cycle them very 13 quickly, for some water to be in the line. I have not
!?
(/ 14 personslly looked at a load eval ua tion.
15 0 Thank you. I would like to move to the LILCO 16 response to staff question 6. Mr. Hodges, do you know 17 at Shoreham what the operator has to do in order to use 18 the flow coefficient? Is he going to look at that flow 19 coefficient and then go to a curve tha t has been 20 provided to him? Or does he actually have to look a t 21 the flow coefficient and make a calculation from it 22 himself?
23 A (WITNESS H0DGES) The operator is not going to 24 use the flow coefficient at all. The person who writes 25 the proceiures uses the flow coefficient, and he pl ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8606
( )> 1 develops a curve which basically provides the operator 2 with information on what the pressure should be for the
('N
%)
3 number of valves opened in order to get adequate core o
4 cooling. And it is based upon, as I say, 100 F 5 temperature rise across the fuel.
8 The operator has to ma ke no calculations. He 7 doesn't even have to know what the Cv means. All he has 8 to do is go to the curve in his procedures.
9 0 I guess tnis question is directed generally to 10 the staff panel. About how long did the staff spend in 11 its review of these responses to the staff's questions 12 from LILCO?
13 A (WITNESS WRIGHT) I think we will have to 14 answer that individually, and I will start. I spent 15 roughly some length of time, on the order of an hour to 16 an hour and 15 minutes yesterday morning reading them.
17 I would say during the day I may have referred back to 18 them on the order of half an hour, and I read them again 19 last night -- I don't know, another nominal hour. So I 20 would say a nominal -- what does that add up to?
21 Somewhere between two and three hours.
22 And Mr. Hodges reminds us that there was a 23 m ee ting where everyone, or all parties, were present in 24 which we had verbal discussions of the responses before 25 they were made, which lasted on the order of two hours.
(
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ALDERSoN REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
8607 O ' ^ (*1rness sooces) rue tote 1 time eveat wee 2 the time we spent in the meeting plus roughly 45 minutes 3 to an hour yesterday morning reviewing the write-up. So 4 between two and three hours total.
5 A (WITNESS CHERNY) I would say including 6 reviewing the as-built drawings, about the same time as 7 Mr. Wright.
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22
, 23 24 25 O
1 ALDERSON REFORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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v 1
0 How long would the Staff review normally take 2 to a response submitted by an Applicant of this nature?
~N. 3 A (WITNESS WRIGHT) For th e three questions that x.s 4 I had input to, the actual review time would be 5 approximately the same, because I had previous 8 information that I was going on. There would be 7 substantially more time involved in writing up responses 8 and getting them through management approval, but actual 9 time evaluating and deciding on the adequacy of the 10 response, roughly the same.
11 A (WITNESS H0DGES) I have the same comment, 12 solely on the fact that there was a certain amount of 13 f amiliarity wi th the questions asked and for the type of
,a
( )
(J 14 response you are looking for. So I don't think I would 15 have spent any more or less time reviewing it than what 16 I did.
17 A (WITNESS CHERNY) I would support what they 18 both said, and I would also make one more comment, and 19 that is that I don't really think that there is 20 necessarily just one a'nswer to that question, in the 21 sense that different reviewers have different areas of 22 expertise, and some people might take longer on a given 23 question than others.
24 0 In the ordinary situation, how many Staff f
l i
25 individuals would review an Applicant's response of this
/^N ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8609 (y
c 1 nature?
2 JUDGE BRENNER: Ms. Letsche, let's make it f'\, 3 more specific and to the point, instead of "of this
\_/
4 nature," when we talk about this response.
5 MS. LETSCHE: That's fine, Judge Brenner.
6 WITNESS WRIGHT: One person would be assigned 7 to make the review. If that individual had any concerns 8 or inability to answer the questions, he would probably 9 seek help. But I wo uld say normally a single reviewer 10 would be assigned to this type of response.
11 WITNESS HODGES: The normal routine, when it 12 would come in I would assign it to a reviewer under my 13 supervision. He would look at it and we would discuss 14 it, and based upon that we would write an evaluation.
15 Usually at that point any changes are more editorial 16 than anything else, and it gets sent out.
17 WITNESS CHERNY: Since Mr. Hodges and I are 18 both section leaders, I would generally support what he 19 just said.
20 BY MS. LETSCHE: (Resuming) 21 0 In the normal situation, would consultants who 22 had been involved in the prepa ra tion of the questions 23 also review the response received from the Applicant?
24 MR. BORDENICK: Judge Brenner, this is not an 25 objection, but I don 't know what the use of the word
- A
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8610
(_) 1
" normal" means in this context. That is my concern.
2 JUDGE BRENNER. I don't, either. Why don't 3 you ask him, if he had received this back in the office
(~
x_,/
4 in the mail and four months from now or three months 5 from now or whatever, who else they would have involved, 6 and if they were going to involve anybody else after 7 this, and so on.
8 Maybe we will make a case for regionalizing 9 the Staff into little groups around the country near the 10 plants and have the reviews made in tha t fashion. It 11 seems like when there is nobody to delegate the review 12 to by the section leaders it gets done just as fast.
13 But we will see.
n.
_) 14 (Laughter.)
15 BY ES. LETSCHE: (Resuming) 16 Q I will adopt the modification suggested by 17 Judge Brenner with respect to your responses, 18 gentlemen.
19 A (WITNESS CHERNY) Well, in the case where we 20 do utilize a consultant -- and then, it would depend 21 upon really the urgency of completing the review to some 22 degree. In a case where it was terribly urgent to 23 complete the review and to get out some kind of a sa f e ty 24 evaluation, I would say the consultant might not 25 actually see the response. It might just be discussed r.
'% /
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8611
() 1 with him by phone.
2 0 Did that kind of dircussion take place with fS) 3 respect to this response from LILCO?
4 A (WITNESS CHERNY) No, it did not. But we have 5 discussed these questions with the consultant by phone 6 in sufficient detail, I would say.
7 0 That is, a discussion of the questions prior 8 to having received the LILCO responses?
9 A (WITNESS CHERNY) That is correct.
10 A -(WITNESS HODGES ) Also, I think that we 11 generally, for most of these questions, feel that we are 12 capable of evaluating the responses. The use of the 13 consultant for looking at the raports and trying to
('D
' - 14 provide the questions is quite often just an expedient 15 because of manpower limitations. It is not because we 16 don ' t h a ve the expertise to evaluate the questions.
17 A (WITNESS CHERNY) For this particular THI 18 item, that is indeed the case, why this consultant is 19 being used.
20 (Counsel for Suffolk County conferring.)
21 MS. LETSCHE: Judge Brenner, at this point I 22 am read y to re turn to my cross-exa mina tion on 23 28(a)(vi).
24 (Counsel for Suffolk County conferring.)
25 JUDGE BRENNER: Ms. Letsche, when the Staff
{}
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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(,) 1 frets about the time they have had to spend answering 2 the County's questions, you should have them, for the X 3 net result, deduct the time that you've saved them by fj
\
4 making then perform this review here this week.
5 (Laughter.)
6 (Pause.) -
7 BY MS. LETSCHE: (Resuming) 8 Q Mr. Hodges, based upon your review or the 9 Staff's review of information submitted by LILCO, in 10 your opinion has LILCO complied with the re quire men t of 11 NUREG-0737, item II.K.3.16, to reduce challenges to the 12 safety relief valves substantially, by an order of 13 magnitude?
,f \
k '3 14 A (WITNESS H0DGES) It appears at this point 15 that they have at least complied with the intent of the 16 requirement as we wrote it, ra ther than the literal 17 wording, and that they have reduced the failures to 18 close by an order of m a gni t ud e . And I can get that by 19 looking at the comparison we discussed yesterday of the 20 valve failures, the failure rates for the two-stage 21 versus the three-stage.
22 I still haven't reached the point of 23 concluding that I want to write off on the owners group h 24 evaluation at this point, because I think I want to look 25 a little bit closer at some of the measures to see if we
(~')
\._ j ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 t
8613
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(,/ 1 can go further. And if out of that we decide, as an 2 example, tha t -- and this is only an example -- that we
(~'; 3 would like for LILCO to look at modifying setpoints for w,
4 the water level setpoints for the main steam isolation 5 valve closure, then we may come back and ask them to do 6 something like that.
7 But I think even without that, they have 8 substantially satisfied the intent of what we were 9 trying to do.
10 JUDGE BRENNER: Could I jump in for a moment?
11 I was going to ask this at the end, but this is close to 12 what you just discussed in terms of the range of further
,_s 13 measures that you might be considering in your yet to be
( )
\ 14 completed further review of the total owners group 15 recommendations as they might be applied to Shoreham to 16 red uce valve failures, including the challenges to the 17 valves.
18 Do you have in mind any possible hardware 19 changes that would have to be la ter incorporated to 20 Shoreham, or were you thinking of things like setpoint 21 changes and procedure changes?
22 WITNESS HODGES: I think it is setpoint 23 changes or procedure changes. There may be some 24 analyses that may be required to do tha t . I don't at 25 this point visualize any hardware changes.
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1 BY MS. LETSCHE: (Resuming) 2 0 Mr. Hodges, this NUREG-0737 item was approved f'] 3 by the Commission when it was issued, is that right?
v 4 A (WITNESS H0DGES) That is correct.
5 0 Have you ever notified the Commission or sent 6 any kind of memo or errata indicating that your intent 7 in writing this document is not to require a reduction 8 by an order of magnitude of the ch alle ng es to the relief 9 valves?
10 HR. B3RDENICK: J udge Brenner, I'm going to 11 object to that question. I don't know what relevance it 12 has to the contention.
13 JUDGE BRENNER: Well, I think what she is A
i !
'"' 14 getting at -- and I will make this statemen t and then 15 you can tell me if you want to continue your objection, 16 and I will see if she agrees. I don't know what she had 17 in mind, but the possible relevance is that, kind of 18 like legislative history, that is nice in terms of what 19 the writer meant in the first instance, but when it gets 20 the imprimatur of the higher approving bodies, if they 21 are going on the express written word, and plus if they 22 have applied it that way tangibly, it may have come to 23 sean something else. And it is that something else that 24 would be more pertinent to apply.
25 '4 o u l d you continue your objection in light of r"
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8615 c
(m) 1 that possibility?
2 MR. B3RDENICK I think I would reconsider. I
(~h 3 don't know where she was -- I obviously don 't know where
%)
4 she was going with it.
5 JUDGE BRENNER. I guess we will a llow Mr.
6 Hodges to answer that question. But more to th a point, 7 has there been anything done by the Staff or the 8 Commission inconsistent with what Mr. Hodges now says he 9 meant by the requirement?
10 WITNESS HODGES: The answer to both questions 11 is no.
12 (Pause.)
13 BY MS. LETSCHE: (Resuming) 7-l I 14 Q Let me ask a similar question, Mr. Hodges.
15 With respect to the NUREG-0737, item II.D.1, with 16 particular reference to item C of that concerning ATWS 17 testing, which you say was intended not to apply to BWR 18 plants and the applicability portion of that item , which 19 states that the requirement applies to all operating 20 reactors and opera ting license Applicants, have you ever 21 notified the Commission or written any memoranda or 22 anything or errata to that item to indicate your l
23 intention that that ATWS te stin g portion of the item I 24 II.D.1 was not intended to apply to BWR's?
25 MP. IRWIN: I'm going to object to that
(~)
kI ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 question, Judge Brenner. It is based upon presumptions 2 about that text which I don't think are there. And if fjv 3 Ms. Letsche wants to lay a foundation for the 4 instruction of the text, I think she had better do it, 5 because I think we have had a lot of argument about what 6 that text means. And she has just assumed that it means 7 something quite different from what I think the record 8 suggests.
9 JUDGE BRENNER: Well, you know, I think we can 10 -- yes, your objection has technical merit. But I think 11 We can get -- i t is not going to prevent getting to the~
12 point, and we can re ph ra se through a series of
,_ 13 questions. Why don't we just get right at it, and the i)
'- 14 record will reflect whether or not it is a 15 mischaracterization or not. And you have flagged it 18 that at least in your view it was.
17 But the real point is, has there been any 18 action indicating some different view by the Commission 19 or, I will even add, Staff practice or something.
20 WITNESS HODGES: Because of the paragraph in 21 NUREG-0758 upon which this requirement was really based, 22 it refers only to BWR's -- excuse me, PWR's -- for that 23 condition, and also because in the requirement itself in 24 II.D.1 we are talking about PWR conditions, I thought at 25 any rate it was clear that we were restricting it to (O
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8617
()
1 PWR 's , and we saw no need to notify the Commission 2 o th erwise.
~
3 So based upon that logic, no, we have not.
(}v 4 JUDGE BRENNER: And is it also correct that 5 neither the Commission nor the Staff by deed or word has 6 expressed anything to the contra ry?
7 WITNESS HODGES: That is correct. .
8 MS. LETSCHE: For the Board's convenience, I 9 am moving at this point to page 4 of my cross plan on 10 28(a)(vi), particularly item B under Roman numeral VI on P
11 ' tha t
~
pa g e .
12 BY MS. LETSCHE: (Resuming) 13 0 Mr. Smith, directing your attention to i \
14 NGREG-0737, item II.K.3.16, has each of the 13 15 modifications listed in that NUREG item, N U R EG -f:.7 37 16 item, been specifically considered for the Shoreham 17 plant?
18 A (WITNESS SMITH) Each of the 13 items thattare 19 presented is possible challenge and failure rate 20 reducticn ways were incorporated into the BWR owners 21 group, 2nd through our analysis of tha t report and 22 review of the suggested options we have analyzed the 13 23 uvents \t 'E.a t are presented there.
24 ',
0 The "we" in your question, is tha t the owners 25 group?
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(_) 1 A (WITNESS SMITH) LILCo.
2 0 And where is that analysis documented?
3 A (WITNESS SMITH) That analysis is done through
(^]/
n 4 a review of the BWR owners group document, which is 5 controlled by procedures in the project, LILCO project 6 organization, and within the Stone C Webster 7 organization.
8 0 Is the analysis documented anywhere?
9 A (WITNESS SMITH) The analysis is documented 10 within the review, yes.
11 0 Has that documentation been provided to the 12 Staff?
,,,s 13 A (WITNESS SMITH) No, it has not.
5J - 14 JUDGE BRENNER4 Mr. Smith, I think what we're 15 getting at here is what papers or documents or whatever, 16 by what means have you provided the Staff with the 17 information of what LILCO is doing in response to this 18 NUREG item. And did you call them up, did you write 19 them a letter, did you put it in the FSAR?
20 WITNESS SMITH: The specific options that were 21 identified by the BWR owners group that would be i
22 applicable to Shoreham BWE for design and tha t would j 23 produce an order of magnitude reduction in challenges 24 and stuck-open relief valve events on Shoreham was 25 con tained in our response to the II.K.3.16 item. In f~.
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V 1 addition, we attached with that, as endorsing the BWR 2 owners group review of this item, there is material (n
v
)
3 contained within the owners group document that provides 4 analysis for varied options.
5 The additional analysis that would be required 6 by LILCO is to see if they are at all applicable, number 7 one; to assure ourselves that the analysis that was 8 performed on behalf of the owners group is accurate; and 9 then to determine if there are the particular op tions 10 that we wish to move with to obtain and meet the 11 requirement for a reduction in stuck-open relief valve 12 events by an order of magnitude.
13 JUDGE BRENNER: All right. And your basic 8 14 response is 15 16 17 18 19 20 21 22 23 24 25 j
l O)
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=_ -. _ _ -
8620 O(,/ 1 JUDGE BRENNER: All right, and your basic 2 response is the section of the FSAR that we have been 3 handed.
4 WITNESS SMITH: Yes, sir. It is Revision 22, 5 July, '81, with the pages II.K.3.16-1 through 3, and in 6 addition the attachmen t which would be the owners' group 7 evaluation, which is attached to our testimony.
8 JUDGE BRENNER: And in fact, if I have my 9 attachments straight, what is called Attachment 1 to the 10 FSA R response, is that the same as one of the 11 attachments that we got with the testimony?
12 WITNESS SMITH: Yes, sir. That would be 13 Attachment 4 to the LILCO testimony, which is Attachment 14 1 in the FSAR response, and that is identified on Page 15 II.K.3.16-2 under BWR owners' group implementation group 16 criteria, the last sentence in that first paragraph.
17 BY MS. LETSCHE: (Resuming) 18 0 Just so that I can make sure I understand, Mr.
19 Smith, in all the various documents and attachments you 20 have just been discussing with Judge Frenner, do any of 21 those contain a Shoreham-specific analysis of the 13 22 modifications listed in NUREG-0737, Item II.K.3.16?
23 A (WITNESS SMITH) No, they do not.
) 24 0 Mr. Smith, I would like to direct your 25 attention to Page 7 of your prefiled testimony, O)
R- !
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_I
8621
() 1 particularly the answer to Question 10. That continues 2 onto that Psge 7.
~
3 JUDGE BRENNER: Ms. Letsche, could I jump back
( "\,
V 4 for a minute? I hate to do this, since this is probably 5 a subject for counsel on redirect, but I am not sure the 6 witness was keyed into your question, or maybe I wasn't, 7 as to the documents in the Shoreham specific analysis.
8 You meant all of the documents discussed, not just the 9 attachments and references, but the FSAR as well?
10 MR. LANPHER: Yes, Judge Brenner. I will --
11 JUDGE BRENNER: Did you understand th a t , Mr.
12 Smith, when you gave your answer?
13 WITNESS SMITH: I don't understand what was I)
'- 14 just discussed, Judge Brenner.
15 (General laughter.) ,
16 JUDGE BBENNER4 You said there was no Shoreham 17 specific analysis, and I am wondering if you were 18 limiting yourself to the references and attachments, or 19 whether you included the FSAR section also.
20 WITNESS SMITH: My response to "s. Letsche's l 21 question was aimed at what I thought specifically said 22 was there a Shoreham specific analysis of the 13 items 23 contained in II.K.3.16, and we did do a BWR owners' 24 group analysis and review of the recommendations within 25 that owners' group repcrt, our analysis of the 13
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l ALDERSON REPORTING COMPANY, INC, 400 VIRGINlA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8622
() 1 events, and that -- her question seemed different to me 2 than wha t I had previously stated. That was the review
( 3 analysis that we had done. We did not do an independent 4 evaluation based upon industry operating history of S challenges, industry history of stuck open relief valve 6 events, and apply that to the 13 items in II.K.3.13.
7 LILCO has used the analysis, the information that is 8 available from General Electric Company, from their 9 nuclear operations data base computer system, and from 10 that we have analyzed the report that was generated by 11 the owners' group.
12 JUDGE BRENNER: I understand that now. Thank 13 y ou .
O 14 BY MS. LETSCHE4 (Resuming) 15 0 Mr. Smith, again directing your attention to 18 the testimony I referenced a minute ago, is it your 17 testimony that the only disadvantage of having open 18 safety relief valves is the potential f or the valve to 19 fail to close?
20 A (WITNESS SMITH) I am sorry, you are going to 21 have to reword that question.
l 22 Q Let me try this. Wouldn't a reduction in the 23 number of challenges to safety relief valves be 24 beneficial from the standpoint of reducing the 25 structural loads on containment and suppression pool?
,e\
Q,/
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8623
(_) 1 A (WITNESS SMITH) I am not a stress analyst, 2 nor do I claim to be, but my understandinc of the design
(
%j j 3 of the SRV valve, its body, its structural integrity, 4 the piping, and its associated supports are designed for 5 the life of service of the Shoreham plant, and that 6 design takes into consideration the fact that a BWR must 7 use a safety relief vhlve to depressurize the reactor 8 vessel and b rin g it down to a cool shutdown mode.
, 9 0 I am not sure that answered my question.
10 Wouldn't a reduction of the number of challenges to the 11 safety relief valves also reduce the structural loads on 12 containment and suppression pool?
g s, 13 A (WITNESS SMITH) I am not qualified to answer i
~
14 that. From a judgment basis, there would seem to be 15 some fatique limit on the cycles that you would put on a 18 s tructure, but I think that a response of that nature is 17 better answered by M r. Crawford or Mr. Malovrh.
18 A (WITNESS CR AWFORD) If you go back to 19 NUREG-0737, II.K.3.16, I think it clearly indicates that 20 there are contraindications, and I wouldn't believe that 21 you were suggesting that one should never open a sa f ety 22 valve. There is some confusion in my mind exactly what 23 your question was, because you stated, isn't there a 24 disadvantage to an open safety valve, and no, in fact, 25 they are designed to relieve pressure, and when they
,a t )
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8624
() 1 actuate, they do produce stresses in the line, and they 2 do produce stresses in the suppression pool.
3 These stresses have been tested for, and 4 thoroughly evaluated using all of the applicable ASME 5 codes and standards, so there really isn't a specific 6 disadvantage to open an open valve. I don't know if 7 that was the f ull intent of the question.
8 0 Mr. Smith, I assume you also agree that 9 reducing the number of challenges to the iafety relief 10 valves would also reduce the duty cycle on the reactor 11 coolant pressure boundary?
1 12 A (WITNESS SMITH) Could you explain duty 13 cycle?
O 14 (Whereupon, counsel for Suffolk County 15 conferred.)
16 0 Let me rephrase my question, Mr. Smith. If ,
17 you had your choice, wouldn 't you rather reduce the 18 number of unnecessary openings of the safety relief 19 valves rather than just trying to make sure that if they 20 did open, they wouldn't get stuck open?
21 MR. IRWIN: Objection. That question has got 22 at least two factual predicates that have not been laid.
1 23 JUDGE BRENNER: Which two? Mr. Irwin, I don't l /"N 24 understand your objection.
l
(_)
25 MR. IRWIN: Ms. Letsche has not. established
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ALDERSoN REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 that there are unnecessary openings to which the 2 witnesses are being directed, and she is also
['1 V
3 hypothesizing that there is a choice. Both of those are 4 propositions that the witnesses have neither been 5 questioned on or agreed to. I am not saying there 6 aren't ways of getting at the point. I just think it is 7 a loaded question, and I don' t want the witness to have 8 to answer it.
9 JUDGE BRENNER: You know, these are big boys 10 up here.
11 (General laughter.)
12 JUDGE BRENNER: I don't think it was that 7.
13 loaded. All right, Ms. Letsche. I see well where you
'- 14 are headed. Do you want to rephrase the question and 15 get there more directly ? Do you sant me to take a shot 16 at it?
17 MS. LETSCHE You are welcome to, Judge 18 Brenner.
19 JUDGE BRENNER: All right. I guess this is 20 primarily for the LILCO witnesses, at least ini tia ll y ,
l l 21 and then to some extent if r . Hodges after, as part of his
! 22 explanation as to what he meant when he said he was not 23 limiting it to the challenges. Your testimony, in 24 effect, implies that there is, in terms of looking at 25 reducing SORV events, th e re is no dif f erence between p
V ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8626 (J 1 looking at reducing the challenges as distinguished from 2 looking at improvements to the valve itself, given those
- 3 3 challenges, and that you should look at both things L.)
4 together to get the total picture, and what Ms. Letsche 5 is going at is, is that true? Isn't it better for the 6 reason she suggested, or any reason to concentrate on 7 reducing the challenges as much as possible, 8 notwithstanding the fact that you think you have done a 9 good job on the way the valve would respond to those 10 challenges?
11 WITNESS SMITH: I understand your question, 12 Judge Brenner. When the owners' group and subsequently 77 13 LILCO reviewed the owners' group analysis, our concern,
( j V 14 underlying concern was that we do honestly wish to 15 reduce the number of stuck open relief valve events. It 16 is not an event that we don't believe the BWB can't 17 handle, but that it is, it could be an un d e sira ble 18 event, and I think we looked at it from both 19 directions. We had sufficient operating history by the 20 time we started to evaluate the requirement.
21 I think as Mr. Hodges indicated the 22 requirement came out some time in late '79 or that time 23 frame. By the time we had gotten around to evaluating 24 i t, we had significant data on the two-stage target rock 25 valve, and the history significantly showed that for V
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) 554-2345
8627
() 1 stuck open relief valve events, the major contributor 2 had been the target rock three-stage valve, which was on 3 most of the BWR plants, and most of the operating 4 history was from those target rock three-stage valves, 5 but we went beyond that, and hypothesized or assumed 6 that if an SORY event was to occur, the more challenges 7 that you had, the greater the likelihood of having a 8 stuck open relief valvo event, even given that you have 9 made modifications, you have an ongoing program for to operating improvement of existing valves.
11 So, in fact, we took all of the challenges and 12 made evaluations on them. The low, low set option was a 13 very dramatic step towards the reduction of those 14 challenges, because we saw in our analysis of transients 15 where the valve was being called upon to function in a 16 design mode, and that particula r option was very 17 applicable to Shoreham and could be applied to 18 Shoreham. There are other challenges that in fact LILCO 19 and the owners' group have considered.
20 JUDGE BRENNER: '4 ell , let me put it this way.
21 Unless you feel you have to add something, you gave me a 22 better answer than my question deserved, and I 23 appreciate it, because you did get right to the heart of A
what I was t rying to get at.
/
} 24 Another way of saying it, 25 if I am understanding you correctly , would be that
}
ALDERSoN REPORTING COMPANY,INC, 400 VIRG:NIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8628 r3 t,) 1 nothwithstanding the improvements in the valve, you 2 haven't used that as a reason to ignore other ways of 3 meaningfully reducing the challenges.
4 WITNESS SMITH: That is correct.
5 JUDGE BRENNER: Mr. Hodges, and I am still 8 asking you, Mr. Ssith, but Mr. Hodges, he doesn't knov 7 yet. He is going to take a look at it, but he believes 8 there may be -- he hasn't concluded that there is no 9 further room for improvement, and he has suggested one 10 possibility of varying the set point or both points in 11 f act set points. Have you considered this on your own?
12 And why have you come out differently? Well, not 13 differently. He may come out the same in the end, but O
k/ 14 why have you concluded tha t there is nothing further to 15 be done in that area?
18 WITNESS SMITH. Let me first characterize tha t 17 I will not say that we have concluded that there will be -
18 nothing else to do in that area. The expediency of 19 responding to II.K.3.16 and specifically addressing the 20 reduction of stuck open relief valve events, we 21 identified the option of the improved valve with low, 22 low set, and I believe we gave the additional option of 23 improved pneumatic supply which we took no credit f or.
m 24 JUDGE BRENNER It is about 10 percent or 25 something.
O Al.DERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
8629
() 1 WITNESS SMITH: Yes. That, however, does not 2 mean that we have concluded our analysis and evaluation I~N 3 on the II.K.3.16 item. We have a rather detailed review
\_
4 by our project engineering and nuclear engineering 5 department of the particular challenge modification, set 6 point change that Mr. Hodges mentioned, and we, 7 in-house, within LILCO, see that perhaps that is a 8 modification that can be -- successfully reduce 9 challenges with minimal cost impact.
10 The problem is that with the time restraints 11 at present we have not been able to have GE do the 12 analysis that is involved, and that particular set point 13 change does require that you go to a lower level than 14 you presently have before main steam isolation. I think 15 Mr. Hodges mentioned that an analysis is required with 16 tha t, and the time t ha t we answered the II.K.3.16 item, 17 we just could not permit that analysis.
18 JUDGE BRENNER: I am glad you straightened out 19 my mischaracterization, because it was in fact a 20 misimpression on my pa rt. I had the impression, Mr.
21 Hodges, th a t you thought you have now got everything you 22 are going to get from LILCO in terms of what they are 23 going to do, and you are going to -- you, the staff, is f~
24 going to tell them whether you think they should do 25 more. Did you understand that they might still propose O
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,a
't ) 1 further measures to you?
2 MIINESS H0DOES: I haven't seen anything
( ,)
3 official that they were going to do anything of this
- x. /
4 nature. Obviously, I talked with the LILCO people, Mr.
5 Smith and other people, at various times, and I knew 6 this was somethin7 under consideration, but there are no 7 commitments for them to do that, and so I still look at 8 it from my viewpoint, as I need to look at it, whether 9 they intend to do it or not at this point, it is 10 something I want them to do in addition.
11 JUDGE BRENNER: He didn' t say he would do 12 anything in terms of a bottom line. He said they would 13 consider it further and, I guess, report further on 0 14 their consideration, which may be that they have 15 determined to do nothing further.
16 WITNESS F0DGES: That is correct. And there 17 are several items of this general na ture. I am not sure 18 if they are considering any of the others or not, but 19 another one would be changing of the testing frequency 20 of the MSIV's, because there have been several spurious 21 openings or, let us say, several openings or challenges 22 to the valve where they are not spurious that have 23 resulted from the problems with testing MSIV's. That 24 one gets a little more tricky as far as saying you ought 25 to change the test frequency because it impacts on a lot l r"x
! (
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8631 gs
() 1 of other things which can af fect doses, so it is less 2 likely we will make a change there, but those are still
(")
\._/
3 some things we are looking at. l 4 JUDGE BRENNER: Yes, and also if you make Mr.
5 Bridenbaugh happy on this conten tion by reducing the 6 challenges to the SRV's, you may make him unhappy on the 7 other contention as to passive valve failures. I think 8 he kind of liked the pretty frequent test program on the 9 MSIV 's .
10 WIThESS HODGES: So there are tradeoffs to be 11 made. Nothing is free, whether you are talking in terms 12 of dolla rs or whether you a re talking in terms of effect 13 on something else.
(_ i
\>' 14 JUDGE BRENNER: Okay. I think maybe I am the 15 .only one who didn't fully appreciate the situation is as 16 both LILCO and the staff are considering it further, l
17 instead of just the ball being in the staff's court.
18 Are you still talking about the end of December for 19 that?
20 Well, don't answer this no w. Talk to your 21 counsel and everybody else. But I want to know if the 22 time frame for licensing has been factored into LILCO's 23 consideration of whether they plan to take any further 24 action on this, and the nature of what further action, 25 if any, would have to be taken could affect that
{
V ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8632
() 1 decision also, but I would like to -- the Board would 2 like to hear that at, I guess, the beginning of next
~
3 week, if you can think about that.
4 MR. IRWIN: We will do that. We may even be 5 able to beat that time frame.
6 JUDGE BRENNEP: 'Je a re going to break for 7 lunch, unless -- did you want to add something, Mr.
8 Smith?
9 WITNESS SMITH: Just one point, that when I 10 indicated th a t we needed GE analysis on the level 2 to 11 level 1 MSIV, that is a safety concern. That is not a 12 general operating f requency or a pplicability. It is 13 applicability from a safety standpoint in our specific (3
v' 14 unit.
15 JUDGE BRENNER: I think everybody understands 16 that you are not talking about whether it is convenient 17 to do something or not. We understand we are talking 18 about, as Mr. Hodges well said, a system in which there 19 are all kinds of tradeoffs. I didn't mean my comments 20 to imply, well, why haven't you done it. I hope you 21 didn't take it that way.
22 WITNESS SMITH: N o, I didn't.
23 JUDGE BRENNER: I was just asking as to the
/"S 24 sta tus.
(}
25 WITNESS SMITH: I honestly feel that for the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8633 O ' re2u1rement we aeve met the order on reduction or 2 challenges.
3 JUDGE BR ENNER: I understand your position.
4 All right, let's break until 1.00 o' clock.
l 5 (Whereupon, at 12:00 p.m., the hearing wa s 6 recessed, to reconvene at 1 00 p.m. of the same day.)
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 -
23 24 25 O
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8634
() 1 AEIEEE00E_SggSION 2 JUDGE BRENNER: We may con tinue now with the (v ') 3 examination.
4 Whereupon, 5 RAYMOND M. CRAWFORD, 6 JEFFREY L. SEITH, 7 STEVEN J. STARK, 8 JOHN J. BOSEMAN, 9 FRED HAYES, 10 JOHN J. KREPS, 11 C. A. MALOVRH, 12 ROBERT J. WRIGHT, 13 MARVIN W. HODGES, 7-14 and FRANK C. CHERNEY, 15 the witnesses on the stand at the time of recess, having 16 been previously duly sworn, resumed the sta nd , and were 17 examined and testified f urther as follows:
18 CONTINUED CROSS EXAMINATION 19 BY MS. LETSCHE:
20 0 Mr. Smith, in the owners' group study relating i 21 to Item II.K.3.16, a BWR four plant with ta rget rock l
l 22 three-stage valves was used as the benchmark plant. Is 23 that right?
24 A (WIINE55 SMITH) That is correct.
25 Q Did that benchmark plant with target rock 1
r'%
N_)
l l ALDERSON REPORTING COMPANY,INC, 1
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8635
() I three-stage valves, BWR f our , h a ve the highest SRV 2 failure rate of the BWR's that GE evaluated?
~
( ')!
3 A (WITNESS SMITH) Yes, I believe that is a 4 correct statement, and the rationale for that would be 5 that it is also the most f requently applied valve on the 6 operating utilities, and thus it is representative of a 7 rather larger percen tage of the data base available on 8 SRV's.
9 Mr. Hayes from GE has specific information 10 relative to what tha t date base consisted of.
11 (Whereupon, counsel for Suffolk County 12 con f e rred . )
,_x 13 C Was that plant, the BWR four with the target fk >; k 14 rock three-stage, did that also have the highest SRV 15 challenge rate of the plants evaluated by GE?
16 A (WITNESS SMITH) I believe your question 17 implies tha t there was one specific plant that was 18 evaluated, and that is not correct. There is not one 19 specific plant. All operating experience from a stuck 20 open relief valve and challenge standpoint were utilized 21 in the data hace-22 Q I didn't mean to imply that in my question, 23 one plant. I meant to refer to the BWR four wi th the 24 target rock three-stage, which was chosen as the l
25 benchmark. I assume that they evaluated other BWR's, L,'
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8636 s
(_) 1 and BWR's with other types of valves. Maybe I am 2 incorrect.
3 A (WITNESS SMITH) Yes, in the data base were 4 other SRV valves that were in operation. As I 5 ind ica ted , the opera ting da ta base was not 100 percent 6 th ree -s ta g e ta rget rocks.
7 A (WITNESS HAYES) Could I just add a little bit 8 more to what Mr. Smith has just said? The banchmark 9 pla n t that was used in the owners' group study and which 10 was the basis for the improvement factors was a BWR four 11 design as Shoreham and a th ree-s ta ge target rock. That 12 was based on the fact that the great majority of the 13 data which was available to GE was that design with the (k ') 14 three-stage target rock valve. We had much more data.
15 Ihe operating plant experience at t h'e time was based 16 upon the design that we had ured, or I should say the 17 design we used as a benchma rk plant was based on the 18 majority of the designs that were operating at the time 19 that the study was made.
20 (Wheraupon, counsel for Suffolk County 21 conferred.)
22 A (WITNESS HCDGES) May I add a comment?
23 Q Certainly.
24 A (WITNESS HODGES) In NUREG-0626, which we 25 referenced yesterday on Page B-23, there is a comparison f-y N_]
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WAShlNGTON, D.C. 20024 (202) 554-2345
8637 i 1 of events which challenge safety relief valves, or 2 events which challenge the safety valve, whether it is a l I 3 safety relief valve or the other type of safety valves, y,)
4 and that one of the conclusions as sta ted on Page B-23 5 at the top of the page is, the number of events in 6 plants with SRV's does not seem different, including or 7 excluding test events.
8 Q Mr. Smith, when did LILCO determine to use 9 two-stage target rock SRY's at the Shoreham plant?
10 A (WITNESS SMITH) The decision to utilize 11 target rock two-stage came through a recommendation from 12 General Electric, in that they used it on their basic
,s 13 design, and I believe the recommendation for change was I,
'~'
)
14 in the 1975 range, mid-seventies, '76, that approximate 15 time frame. That would not preclude GE having chosen to 16 use some other -- excuse me, LILCO chosen to use some 17 other valve.
18 (Whereupon, counsel for Suffolk County 19 conferred.)
20 0 Mr. Hayes, I think you a re going to be able to 21 answer this question. What were the relative rankings 22 of the other BWR plants evaluated by GE before any 23 changas were made as a result of NUREG-0737, Item 24 II.K.3.16? I am talking about with respect to the 25 number of SRV failures and the number of SRV
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1 challenges.
2 A (WITNESS HAYES) Well, there were a number of I} 3 generi: designs evaluated, of course, for the base v
4 plant, which was the BWR four design with the 5 three-stage target rock valve. It was dete rmined that 6 the valve, the number of stuck open relief valve events 7 as note in this report was the highest primarily because 8 of the propensity of the three-stage target rock valve 9 to stick open when challenged and also for its to propensity for spurious actuations.
11 So, that would have been the product line and 12 valve type that I believe would have been, however you s 13 vant to put it, the lowest ranking of all of them.
I \
'd 14 0 That would be the vorst case, in other words?
15 A (WITNESS HAYES) Yes.
16 0 How did the other BWR plants fall in above the 17 BWR four with the three-stage?
18 A (WITNESS HAYES) Are you talking about the 19 other product lines? Or size of plants?
20 0 The other product lines.
21 A (WITNESS HAYES) Roughly, and again, it would 22 depend upon the size of the plant, you know, plant 23 unique features, but for the assumptions that were made 24 in the analysis, the ranking would show. Again, it ;s 25 hard to say because of all the v aria tion s. Of course, l3 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8639
() 1 Shoreham, with the two-stage target rock valve, and the 2 low, low set modification, would be somewhere along the O 3 list, and I am not exactly sure where to put it, but the 4 BWR three with the isolation condenser we determined was 5 fairly high, because the isolation condenser would 6 reduce isolation cycling.
7 The BWB five and six product lines were f airly i
l 8 high because of the high valve reliability versus the 9 three-stage valve. Again, as with the two-stage valve, 10 they were not showing, based upon tests, the same t
11 failure modes that the three-stage valve was having for 12 sticking open.
13 (Whereupon, counsel for Suffolk County 14 conferred.)
15 0 Did you have something to add?
16 A (WITNESS HAYES) No.
17 0 Mr. Hayes, directing your attention to Table 18 5.2 in the owners' group evaluation which is attached to 19 the prefiled testimony, which contained -- that table 20 contains a list of candidate modifications, and --
21 JUDGE BRENNER: Ms. Letsche, let's get an 22 attachment number, because there are a few owners' group 23 evaluations attached, if you know.
( 24 MS. LETSCHE: It is Attachment Number 4 to the 25 testimony on Contention 28.A.6. That table lists SRV O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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- () 1 chslienges normalized and along the side it has a number 2 of candidate modifications.
g~s 3 BY MS. LETSCHE4 (Resuming) 4 Q Can you tell me which modifications were 5 ultimately selected for the Shoreham class plant by the 6 owners' group study?
o 7 A (WITNESS HAYES) I can tell you the 8 modifica tions tha t were selected on this table, tha t 9 appear on this table. There are some others that we 10 con se rva tiv ely didn't in cl u de , but the ones that are on 11 this table would be the low, low set relief or 12 equivalent manual action. There are some other 13 improvements, and I think in LILCO's FSAR they have O 14 indicated an improved pneumatic supply system which 15 would provide an additional reduction in challenges as 16 well as the improved blowdown on the valves, which would 17 also reduce that number.
18 So, we conservatively neglected those in the 19 Shoreham ana' lysis.
4 20 JUDGE BRENNER: Incidentally, Mr. Hayes, we 21 have had reference throughout the written testimony and 22 orally to the low, low set relief. I picture that as 23 being some sort of automatic setting, as distinguished r
24 from what LILCC is doing, that is, manual action. Are 25 they doing both at Shoreham, or just one or the other?
(
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,m
' _) 1 WITNESS HAYES: From what my understanding is, 2 on Shoreham they are implementing a manual low, low set
(\_,',} 3 based on procedures being given to the operator.
4 JUDGE BRENNER: I infer that there is also a 5 possibility of an automatic low, low set relief. Could 6 you briefly explain how tha t would work and whether 7 there would have been an advantage to do that from the 8 standpoint of reducing SORV events ?
9 WITNESS HAYES: Well, the automatic low, low 10 set really basically would automatically reset the set 11 point of the low valve, the low set valve following the 12 first actua tion, and it would allow it to stay open 7s 13 longer, therefore, releasing more steam and more reactor I'i 14 stored energy to prevent subsequent actuations of 15 multiple valves.
16 On Shoreham, the procedures a re instructing 17 the operator to hold the low set valve open following 18 the initial pop or even a subsequent pop in order to 19 bring the pressure down, and I believe their procedures 20 say to bring the pressure down to 800 psi and then to 21 reopen the valve at approximately 965 psi, which is well 22 below the set points of the other valves, and the impact 23 of that is to prevent the other valves from reopening.
24 If the operator were not to take that action, then you 25 may get subsequent actuations of multiple valves.
1
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() 1 JUD3E BRENNER: Right. I think we have got 2 that already, and the effect of either the manual 3 procedural instruction or the automatic low, low set
((
4 relief is essentially the same, as I understand it, if 5 they are both done right. The question.is, why would 6 you choose one or the other?
7 WITNESS HAYES: I would expect for several 8 reasons that there would be a high reliability of the 9 operator doing -- performing the manual low, low set.
10 One would be the fact that it is a part of his 11 procedures, and he is trained to do it. Another is the 12 fact that for most of the transient events where he 13 would get popping of the valve , popping of the valves, 14 which would be like primarily isolation type events, the l
15 operator isn't really concerned about such things as l 16 core cooling, because his makeup systems, his ECCS 17 systems will automatically maintain level.
18 He has got level readouts in the control room 19 which a re in the same vicinity as the button to open the 20 safety relief valve, and from what I understand, what he 21 would do is, he would turn the safety relief valve to 22 the open pasition and leave it there so that he wouldn't l
23 have to be holding a button or anything while he has to 24 do something else. So, I would expect a fairly high 25 reliability of the operator to perform that function.
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8643 1 WITNES3 SMITH: I tnink I could add to that, (s.)
2 Judge Brenaer.
3 JUDGE BRENNEP,4 What I was thinking of was 4 that maybe there were some disadvantages in having that 5 type of thing automatic, depending upon wha t you may 6 encounter, and the reliability of the sensitivity of 7 those kinds of settings and things of that nature. I 8 don 't know if that applies.
9 WITNESS SMITH: No. I believe that the 10 considered disadvantage by operating people is that it 11 takes away from the flexibility of the operator to 12 choose that mode under the particular operating 13 condition that he is under.
( )
14 The important point to consider, I think, as 15 Mr. Hayes has said, is that this particular low, low set 16 challenge reduction in a manual mode is done under a 17 non-stressful condition, and it is an option that the 18 operator is told to be aware of, that he can take 19 without jeopardir.ing any of his safety systems, and 20 reduce challenges, and that is why we felt that it could 21 be done successfully in a manual mode in lieu of the 22 automatic mode.
23 JUDGE B9ENNER: And in your view the lack of rm Iws / 24 flexibility introduced by the automatic mode would be a 25 disadvantage?
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( ) 1 Bft.YS. LEfSCHEi (Resuming) v C,
2 0 M r .-- d a y es , d I t h.'.n k in your answer you were g >
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3 telling me what dificationg L LCD had decided to 4 implement, and 1 want t'o talk about that some more in a u ,
3 5 minute. j But befo/e we get t5 that, my question, and f
8 maybeitjwasn't clear, was did the owners group make a 7 recommendationLto -- or did GE, ra the r , 'make a I
, 8 recommendation to the owners group for mddifications, 9 suggested modi' fica tions to BWR-4:clants in general? And
)
10 I guess I was ref erring to your testimony a t< page 10 of 11 the prefiled testimony, which referencras page 31 of the 12 generic evalua tion , in .'the answer to question . numb,er 'l 13 14.
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0)
14 A
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( WITN ESS H AY ES)
Excuse me while I find tha t .
, 15 (Pause.)
16 A '(WITNESS HAYES) I think"whst we are saying on s ,
j
' 17 that page . 71 is; tha t a plant, based upon several of the 18 modifications which we had provided in the report and-
. t l r 19 6,'basel upon - the improvements that we had calculated would 20 be made by implementation of th ose modifica tions, c E u?.d 1
21 make an ordar'of magnitude reduction in their number of
(
l l 22 stuck-opeo reflef valve events. And we kind of left it 23 open to the individual utilities as to what combination 1
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() 1 recommendation. You sort of gave them a menu to choose 2 from?
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VJ 3 A (WITNESS HAYES) Exactly.
4 0 For the specific modifications that are listed 5 in table 5.2, how was the particular number listed here 6 to represent the reduction or improvement in challenges 7 arrived a t f rom the range of improvement that had been 8 possible? And maybe so we could be specific here, let's 9 talk about the low low setpoint, which I think is 10 discussed in section 3.1.3.1 of the owners group 11 evaluation.
12 A (WITNESS HAYES) Yes, I would like to clarify 13 what was meant by "a range." When 9e talked about range 14 in the 3.1.3.1, I believe we were talking about a range 15 which could be male across all of the product lines and 16 all of the plant sizes.
17 The number th a t we had provided in the table 18 for reduction in challenges, table,5.2, showed a, 19 basically I guess, a 56 percent improvement or 44 out of 20 a reference number of 100. The range could vary from a 21 high of, I believe we said, 63 to a low of 29. We have 22 -- now, the calculation that was done for the BWR-4 was 23 also done for the worst case BWR-4
() 24 In other words, it was the case, or it was the 25 BWR-4 plant, which gave us the smallest reduction for O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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(^3 1 that product line. And it turns out that, having looked R._;
2 at the analyses for the 218-size BWR-4 with 11 safety 3 relief valves, which is the Shoreham plant, that you 4 would actually get a reduction f actor a lit tle bit 5 higher than the 56 percent, and it would be more on the 6 order of 66 percent for Shoreham .
7 Q Is the method of arriving at the particular 8 number value for a given product line contained anywhere 9 in the generic analysis?
10 A (WITNESS HAYES) We did describe -- and I can 11 get you the section number -- we did describe how we had 12 arrived at those numbers. And if you can just give me a 13 minute I will find where that is. It is section 4.4.
p
'- Okay, we described how we came up with the estimation of 14 15 safety relief valve challenges. In section 4.4.1 we 16 talk about how we determine the frequency of the 17 transient events.
18 In section 4.4.2 we talk about how we come up 19 with the safety relief valve openings f or the 20 transients, and basically I can summarize that, if that 21 is what your question is, is how we did the analysis.
22 0 I guess what I would like, Mr. Hayes, is for 23 you to tell us how you got to the 66 percent number for (rh),
24 Shoreham. And let me just make sure I understand what 25 the 66 percent is. Is that the percentage reduction in
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() 1 the number of challenges to SPV's at Shoreham as 2 compared to the number of challenges in a BWR-4 plant i
3 with a three-stage Target Rock valve?
4 A (WITNESS HAYES) Right, without the low low 5 set.
6 0 Right.
7 A (WITNESS HAYES) Right.
8 0 Okay. Could you summarize how you came to the 9 66 percent value?
10 A (WITNESS HAYES) What we did was -- and I 11 quess I can address it pa r ticula rly to the low low set 12 -- in looking at the different modifications which could 13 reduce the total number of stuck-open relief valve 0
\l 14 events, okay, the modifications could have benefits 15 either in eliminating transients which would or could 16 challenge the safety relief valves or a modification 17 could reduce the number of safety relief valves opening 18 for a given class of transients.
19 For the low low set modification, we got a 20 significant benefit because the low low set modification 21 would reduce the number of valve challenges for a class 22 of transients and in s significant number of 23 transients. What we did is we locked at --
within GE we
() 24 have a computerized system, componen t inf orma tion 25 retrieval system, which is a comprehensive data base O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8649 1 tha t includes licensing event reports, reports from the
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2 site, forced outage reports. And they all get included 3 in this data base, and it is on computer.
4 What we did was to go through and look at the 5 different transients that had occurred to find what the 8 causes for those transients were. When we had-7 determined that we had these transients and we knew what 8 the causes were, we could determine whether a certain 9 modification was going to eliminate that cause, and if 10 so then those class of transients could be eliminated.
11 So basically, we could determine the reduction 12 either in the number of transients or in the number of 13 relief valves opening per transient for a certain 14 modification, and based upon that reduction we could 15 derive a percentage reduction from the reference plant, l
l 16 which is the BWR-4 with the th ree-stage Target Rock.
17 A (WITNESS SMITH) I would like to make one 18 correction. I believe in a sta tement M r. Hayes made the l 19 table 5.2 3RV challenges, the column related to BWR-4, 20 three-stage Target Rock benchmark plant. I don't 21 believe whether it 's a two or th ree-stage valve has an 22 impact on that particular column of the improvements.
l 23 And I believe Mr. Hayes said just the three-stage valve,
() 24 25 and that is not correct.
Challenges will affect not the performance or l
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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(~, 1 failure to perform properly of the valve, but simply v
2 based upon the number of transient events and operating 3 history, whether you have two or three-stage valves, the 4 improvement is made. What is important is the number of 5 valves that are on a particular unit, and that will of 6 course affect the amount of challenges for a particular 7 unit.
8 0 Mr. Hayes, the GE analysis that you just 9 described, was that analysis done specifically with 10 respect to the Shoreham plant configura tion ?
11 A (WITNESS HAYES) It was done for the same 12 Shoreham design, yes, the 218. For all of the 13 parameters which would impact the results of the (D
14 analysis,'those parameters were identical to those in 15 the Shoreham plant. So I would say yes.
16 0 Is that analysis documented anywhere?
17 A (WITNESS HAYES) The analysis and the results 18 of the analysis are documented in the analysis, yes. I 19 don't know what else to call it.
20 0 Well, maybe I can be a little mor e specific.
21 That is not in this generic document that was attached 22 to your testimony, is it?
23 A (WITNESS HAYES) That's right.
( ) 24 Q Has it been submitted to the NRC Staff for 25 review?
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1 A (WITNESS HAYES) We did not submit the 2 specific numbers, just the report, the results of that 3 analysis.
4 0 You say the results of the analysis. Are you 5 talking about the results of the Shoreham-specific 6 analysis?
7 A (WITNESS HAYES) No. We submitted the owners 8 group report.
9 0 So the results of the Shorehim-specific 10 analysis have not been submitted to the Staff, is that 11 right?
12 A (WITNESS HAYES) That is correct.
13 (Counsel for Suf f olk County conferring. )
\Y 14 Q Mr. Hayes, how many SRV's are in the benchmark 15 plant?
16 A (WITNESS HAYES) I believe the benchmark plant 17 had 16 safety relief valves, but I'm not sure. That is 18 my guess.
19 (Panel of witnesses conferring.)?
20 A (WITNESS SMITH) Ms. Letsche, I think there 21 may be some confusion in identifying whether the number 22 of valves that was mentioned by Mr. Hayes are SRV's or 23 whether those plants have separa te safety valves and
() 24 separate relief valves. And I don't have that answer.
25 I'm not sure anyone does.
r" l}N ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
8652 o 1 (Counsel for Suffolk County ronferring.)
()
2 0 What I am trying to understand is the 3 significance of the 44 number in the generic study, 4 which is representative of the improvement in challenges 5 for the low low set relief for the BWR-4 benchmark 6 plant. I am trying to understand how that was arrived 7 at and how or why it differs from the 66 percent tha t 8 you have told us would be a pplicable tc Shoreham.
9 A (WITNESS HAYES) Okay. Mr. Smith had 10 men tioned ea rlier that one of the parameters, I guess, 11 that would affect the outcome of the analysis was the 12 number of safety relief valves. But there are others.
13 The power level would be another.
i
( But it turns out that in our analysis, that 14 15 the key parameter was the size of the vessel, because 16 with the smaller sized 218 plant, which is the Shoreham 17 pla nt, versus the larger-sized plant that we had l
18 analyzed, the pressurization rates would be much 19 greater. And as a result we would expect more --
20 without the low low set, you might expect more 21 actuations of low low valves than you might in a larger l
l 22 plant.
23 So as a result the implementation of the low (h
(j 24 low set on the Shoreham -sized plant had a greater 25 effect, a greater benefit, than it would have had on a
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() 1 larger-sized plant.
2 0 Would you just say, explain to me or say 3 again, why it is that the effect would be bigger on the 4 Shoreham plant because of the size than it was on the S benchmark plant?
6 A (WITNESS HAYES) Okay. The low low set, okay, 7 will result in subsequent actuations of the valvos 8 really being confined to only one valve, because you're 9 depressurizing sufficiently low with one v a lv e , and then 10 you are popping that valve well below the setpoint 11 pressures of the other valves. So that you really only 12 are reopening one valve.
j 13 If such were not to be implemented, then you p
i-') 14 might have repressurization when the valves close which 15 was sufficient to open a multiple number of valves, and 16 that could occur over several cycles. In a small plant 17 such as Shoreham, those multiple valve actuations over
! 18 ihe subsequent cycles could be higher or could be more 19 cycles, either more multiple actuations per cycle or l
20 more cycles than it would be on a larger plant.
l l
21 And we found that because of that your l
1 22 reduction in going to a low low set would be much 23 greater for the Shoreham-sized plant than it would be 1
(f'")
24 for the analyzed plant.
25 (Counsel for Suffolk County conferring.)
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() 1 Q What ass the size of the vessel in the 2 benchmark plant?
3 A (WITNESS HAYES) It was a 251.
4 (Counsel for Suffolk County conferring.)
5 0 Is this information that you've just been 6 explaining to me explained anywhere in the ganeric 7 report?
8 A (WITNESS HAYES) No, it is not. And by the 9 way, it is not something that Shoreham has taken credit 10 for in its evaluation.
11 Q I guess I don't und e r s ta nd . Are you saying 12 Shoreham is only claiming the 44 number?
13 A (WITNESS H AYES) Yes.
r^5
(' )
14 Q The number of the reduction of challenges as a 15 result of this low low set relief?
16 A (WITNESS HAYES) Yes.
17 0 I would like to go back to -- not go back, but 18 refer you to your prefiled testimony, in which you 19 discuss three items that have been -- three 20 modifica tions made a t Shoreham in response to NUREG 21 II.K.3.16. We've talked about the low low set relief.
22 You also talk on page 16 about the lower reclosing 23 setpoint.
()
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24 This was not avslustad, this modification was 25 not evaluated, by the owners group, is that right?
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) 1 A (WITNESS HAYES) That is correct.
('J L.
2 0 What is the value of the reduction in the 3 number of SRV challenges resulting from thi s 4 modification?
5 A (WITNESS HAYES) A specific number has not 6 been quantified for th a t . It is a reasonably small, 7 certainly less than one percent, improvement.
8 (Pause.)
9 Q What is -- the first modification that is 10 men tioned in your testimony is the use of the two-stage 11 Target Rock valve. What is th e percentage reduction in 12 SRV challenges attributable to that modification or the 13 use of those valves in the plant?
l f)
( (J 14 A (WITNESS HAYES) There is -- remembering that 15 the overall goal of our owners group study and 18 Shoreham 's evaluation is f or the reduction of stuck-open 17 relief valve events, we did th a t through three means.
18 Okay, we did that by reducing ch allenges to the safety 19 relief valves, reducing the probability of the valve 20 sticking open when challenged, and by reducing spurious 21 actuations of the valves.
22 In going from the three-stage to the two-stage 23 Target Rock valva, Shoreham was making improvements in
,m
- j 24 two of those areas, namely reduced probability of 25 sticking open when challenged and in reduced spurious p/
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() 1 actuations of the valve.
2 0 I understand that, Mr. Hayes, but I would like
- 3 to know what the reduction in the number of challenges 4 attributable to the use of the two-stage valves is, if 5 the re is one.
8 A (WITNESS HAYES) There is a reducti.on, because 7 you could consider spurious actuations of the valve as a 8 challenge to the valve. But I haven't evaluated what t
9 that number would be.
i 10 0 And I take it tha t is not in the owners group I 11 study anywhere, either?
12 A (WITNESS HAYES) That is correct.
13 0 There has also been some mention of the (s 14 pneumatic control system modification at the Shoreham i
15 plant. Does that result in a a reduction of challenges 18 to the SRV's?
17 A (WITNESS HAYES) No.
18 (Panel of witnesses confecring.)
19 A (WITNESS HAYES) I believe the benefit --
20 well, Mr. Smith will answer that question.
21 A (WITNESS SMITH) Yes, it does. It affects 22 both challenges and the reduction of stuck-open relief 23 valves.
) 24 0 What is the percentage reduction in challenges 25 that results from that modification?
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A (WITNESS SMITH) Only the analysis relative to challenges and spurious -- the specific quantification 3 of challenges and spurious openings has been evaluated, 4 which is two to three percent.
5 0 I would like to direct your attention, Mr.
6 Smith, to page 16 of your prefiled testimony. You 7 indicate in the response to question number 24 th a t the 8 combination of modifications discussed in your testimony 9 will achieve a tenfold reduction in SORV events 10 frequency when compared to the benchmark BWR-4, and that 11 is documented in table 5.1.
12 Can you tell me what the number is tha t is 13 being referred to in that answer? What is the reduction 1 (~h <
\/ 14 in SORV frequency that you feel has been achieved at 15 Shoreham?
l 16 A (WITNESS SMITH) It is the number 11 that is l 17 in the first column under BWR, across from the l
18 horizontal of item E.
19 0 Now, can you tell me, Mr. Smith, what is the 20 total reduction in challenges to SEV's that has been --
21 that you contend has been achieved at Shoreham as a 22 result of the modifica tions?
23 A (WITNESS SMITH) Excluding the improvement in
,m
/ ) 24 the controlled pneumatic system and utilizing the
(_-
25 generic figure that is provided in table 5.2 of the
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- fwi ,') 1 owners group report, the number would be 44 as presented 2 under colunn BWR-4, across from low low set relief or 3 equivalent manual action. And that would not aisc 4 include any evaluation or numbers for the reclosure 5 setpoint increase.
6 (Discussion off the record.)
7 WITNESS SMITH: I believe I said inc rea se . I i
8 believe it should have been decrease.
9 BY MS. LETSCHE: (Resuming) 10 0 Let me just understand one thing, Mr. Smith.
11 To get to your number for a re d uc tion , the reduction of 12 SORY events, that is in number 11 that you pointed to on 13 table 5.1?
()
14 A (WITNESS SMITH) Correct.
15 0 That is attributable solely to the use of the
[
16 low low set relief modifica tion ?
17 A (WITNESS SMITH) And the utilization of the l 18 two-stage Target Rock. I believe I said item E.
19 (Counsel for Suffolk County conferring.)
l 20 0 How was -- for Shereham how was that number l
l 21 arrived at?
22 A (WITNESS SMITH) What number is this?
23 0 Your number on the table that you referred me
,3 24 to, which is 11. That is, the reduction in SORV's that
! ()
25 has been achieved at Shoreham.
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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() 1 A (WITNESS HAYES) That number was -- again, 2 going back to the three contributors that we had talked l 3 a bout ea rlie r, there was a fa.ctor or, I should say, a 56 4 percent reduction due to the low low set modification.
5 Tha t brough t the stuck-open relief valve down from a l 6 number of 100 to 44. And then, based upon the two-stage 7 to three-stage valve improvement, which reduces your 1 8 probability of sticking open when challenged and your 9 spurious actuations, you effectively get another factor 10 of 4 reduction in the stuck-open relief valve event 11 frequency, and you get down to your factor of 11 from 12 44.
13 (Counsel for Suffolk County conferring.)
~ i 14 0 Where does the factor of 4 that you have 15 assigned to the use of the two-stage valve come from?
16 A (WITNESS HAYES) The factor of u is based upon 17 a factor of .5 for sticking, a factor of .5, with the 18 reference value being one, for sticking open when 19 challenged, and another factor of .5 for reduced 20 spurious opening of relief valve frequency.
21 A (WITNESS SMITH) I believe it might be helpful 22 to reference you to note 2 at the bottom of table 5.1, 23 which then references you over to table 5.3.
,.m (j 24 (Counsel for Suffolk County conferring.)
25 Q Maybe I'm confused, but the footnotes that you (m
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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( ,'t 1 just mentioned, Mr. Smith, only seem to reference one .5 2 factor attributable to the two-stage valves. Is the 3 information that you just gave us, Mr. Hayes, the fact 4 that you have two factors of .5 for that, contained 5 anywhere in this report?
6 A (WITNESS HAYES) I believe the footnote 2 7 references you to table 5.3, which talks about the 8 spurious event frequency, and then table 5.2 has a 9 footnote in it which talks about the .5 reduction in 10 stuck-open relief valves when challenged. So the 11 reduction factors are contained in tables 5.2 and 5.3.
12 (Counsel for Suffolk County conferring.)
13 0 These reductions are all reductions that would p
\ s' 14 apply if you went from having a three-stage valve to 15 having a two-stage valve, is that right?
16 A (WITNESS HAYES) That is correct.
17 0 Shoreham has never had a three-stage valve, 18 has it?
19 A (WITNESS SMITH) Shoreham has not operated.
20 It has purchased Target Rock two-staga valves.
21 MS. LETSCHE: Judge Brenner, if I could have 22 just a moment, please.
23 (Counsel for Suffolk County conferring.)
JUDGE BRENNER. Ms. Letsche, as long as (G,) 24 25 there's a pause let me jump in.
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( 1 I don't know if this question is fair or not, 2 Mr. Hayes. I will try it anyway. This low low set 3 relief or ma nual action low low set is such a big 4 factor, even within the three-stage Target Rock valve, 5 the question occurs to me -- and it's easily implemented 6 and it makes a lot of sense -- why did there have to be 7 a big owners group study and so on in order to come up 8 with th i s ?
9 Is there some detriment to implementing this 10 action that required a full study of all of the cause 11 and effect? Why didn't everybody think of this right 12 away from the beginning --
I'm quite serious, from the 13 beginning -- of using the Target Rock valva, so at least
/m i
( ._ . 'I 14 early in the experience of the SORY events?
15 WITNESS HAYES: I think it had been thought 16 of. It was a relatively new concept at the time, but it 17 was thought of in terms of, I think it was, in the 18 containment program where they were looking at 19 subsequent actuations relative to its effect on 20 containment. And I'm not sure about the time frame, but 21 I believe that was like within the same time f rame as 22 the study that we had performed.
23 Why it hadn't been implemented before that, I
/ 'N (Lj ) 24 don't know.
25 JUDGE BRENNER: Maybe I should ask -- well, if n
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8662 I^'i
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1 M r. Smith wanted to respond. Then I wanted to ask Mr.
2 Hodges something from the Staff's perspective.
3 WITNrSS SMITH: Certainly, II.K.3.16 4 stimulated thought in the area of challenges where 5 perhaps that thought had no t entered bef ore. And I 6 think that on an individual utility basis there are 7 suggestions and improvements or just changes to plant 8 design that GE institutes on, for example, their BWR-6 9 and feeds that information back to utilities. And on an 10 individual plant basis maybe the same thought processes 11 would not have gone into this particular item. But 12 combined as an owners group effort, it does get the 13 utilities to collabora te a lot more and think as a 1 rs l \ )
\/ 14 unified group.
l 15 And as such, agreement was reached that, by 16 .n a a y utilities, I believe. that this was perhaps an 17 option we should be taking.
l l 18 JUDGE BRENNER: I suppose perhaps the i
19 magnitude of the contribution to reduction would not 20 have been clear until all of the data was put together, 21 or were put together?
22 WITNESS SMITH: I can ' t say for sure if, when 23 it was presented to other utilities, there was a data A
24 base in its presen ta tion. The concept of low low set
()
25 had been presented, but I don't know if it was presented l
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0663
( 1 in the light of the total number of challenges 2 qusntitstively.
3 JUDOE BRENNERs Mr. Hodges, when the Staff set 4 up the II .K . 3.16 t equiremen t, did you have a pretty good 5 idea that this was going to be an important part of the 8 answer?
7 WITNESS H0DGES: Not really. To put it in 8 perspective a little bit, there had been a lot of 9 challenges to the valves and a lot of failures of the 10 valves, in excess of 50 times when the valves had either 11 opened spuriously and remained open for some time or 12 been challenged and then stuck open. We thought this i
13 was a fairly poor record and that is why we made those I \/ 14 kind of words in the II.K.3.15.
l 15 But with all of these problems with the valves 18 sticking open, nothing had ever happened to the fuel or 17 anything of that nature from it. There had been no 1
18 threat to public health and safety. It was almost like 19 a nuisance problem and the utilities were trying to 20 solve it because to them it was, I think, a nuisance 21 problem. If they've got a plant that's operating and a 22 valve all of a sudden pops open, that cost them money, 23 and so they were interested in solving the problem as
/
(j 24 well.
25 They had already taken some steps, which p,
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ALDERSoN REPORTING COMPANY,INC, 400 VIRG ANIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8664
/m 1 included things of the nature of changing setpoints.
(v) 2 They were already going to the two-stage valve because 3 of the problems recogniz?d there. They were taking a 4 lot of steps. They were looking at maintenance 5 programs. They were doing things to try to improve the l 6 valve performance, and this was kind of like a spur to 7 say, we want you to look a little bi t harde r and see if 8 you can do a little bit more. j 9 WITNESS SMITH: The evaluated item relative to 10 decreasing the setpoint for pressure or initiation of 11 main steam isolation valve had already been implemented 12 by almost all utilities from an 850, a mid-800's range 13 and above to 925. So when the report ev alu at ed the 825
- 14 we had already chopped most of that conservation margin 15 out. But the step had been taken much earlier by the 16 u tilities because various isolations were occurring, and 17 it is money.
18 BY MS. LETSCHE: (Resuming) 19 0 Mr. Hodges, in your opinion does Shoreham's 20 reduction in the number of challenges to SRV's by 56 21 percent as compared to the number of challenges in a 22 BWR-4 with three-stage Ta rg e t Rock valves constitute
- 23 compliance with the requirement of II.K.3.16 that
'"i 24 challenges be reduced substantially by an order of
()
25 magnitude?
/3 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
8665 (WITNESS HODGES) I think tha t we said several
(])
1 A 2 times we are really interpreting it as failures to close 3 and not just' challenges. And based upon the data that 4 we used in NUREG-0626, which was the basis for the 5 concern or where the numbers came from that are 6 expressed in II.K.3.16 and information contained since 7 then on the performance of the two-stage Target Rock 8 valves, it appears that if you look at failures to close 9 tha t are design-related, you've got approximately a 10 factor of eight improvement.
11 If you look only at just the stuck-opens, 12 y ou 'v e got a factor of about three. So at any rate that 13 is a very substantial change. The ones that are related 14 to the valve design I think are very significant, and I 15 recognize t h at as a significant improvement. So I think 16 they have gone a long way towards satisf ying II.K.3.16.
17 0 I understand that, and I know you've talked 18 about your concern with the SORV events. But I think my 19 question was a little more specific, and that is, do you 20 think that the reduction in challenges that has been 21 achieved at Shoreham, 56 percent, and tha t is a 22 reduction compared to what would be the case in a plant 23 with three-stage Target Rock valves,, do you think that
() 24 that complies with the stated requirement in II.K.3.16 25 that challenges should be reduced substantially by an O
ALDERSON REPORTING COMPANY,INC,
8666 I~ ' 1 order of magnitude?
x_/
2 A (WITNESS HODGES) In the very narrow sense of 3 the specifically stated requirement, no.
4 MS. LETSCHE: Judge Frenner, that completes my 5 cross-examination of this panel on 28(a)(vi).
6 JUDGE BRENNER: What is the time frame going 7 to be for LILCO's examination and then Staff's 8 examination?
9 MR. IRWIN: I've got just a few minutes, Judge 10 Brenner.
11 JUDGE BRENNER: Mr. Bordenick?
12 MR. BORDENICK: This is in the na ture of 13 redirect?
s
\> 14 JUDGE BRENNER: I don 't really know what to 15 all it with these combined panels, so I will call it 16 S ta f f e xamina tion. Yes, it would be redirect of your 17 witnesses and then questions of LILCO witnesses.
18 MR. BORDENICK: I don't think it is going to 19 be very substantial, if any.
20 JUDGE BRENNER: All right. faybe we can -- it 21 would be a surprise to me. Maybe we can finish the 22 panel.
23 MS. LETSCHE: Judge Brenner, let me just note
,m
() 24 for the record that I don't know what kind of 25 examination Mr. Irwin has in mind.
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ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
i 8667 (j 1 JUDGE BRENNER: I know you have a right to 2 further questions.
3 MS. LETECHE: N o, no, I wasn't going to say 4 that. With respect to cross-examination of the Suffolk 5 County wjtnesses, although from our off the record 6 conversations he has indicated that it would be brief, 7 the Suffolk County witnesses have authorized me to say 8 that, in an effort to complete this contention, they 9 would be willing to continue beyond the 2:30 stopping 10 point.
11 JUDGE BRENNER: We can't.
12 MS. LETSCHE I j ust wanted to make that f3 13 known.
5 I 14 JUDGE BRENNER: Thank you. Because it 15 wouldn't be a 15-minute or a half an hour continuous.
16 It would be a minimum of an hour, I'm sure. And even a 17 half an hour would get us into trouble.
18 MS. LETSCHE: I just wanted to let everyone 19 know that we were just as interested as everyone to get 20 it over with today.
21 JUDGE BRENNER: I know, and I don 't think 22 anyone ever suggested to the contrary.
23 EXAMINATION ON BEHALF OF APPLICANT
(";
\_J 24 BY MB. IRWIh:
25 0 Mr. Hodges, let ce start with you, and let me
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ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8668 m
k._, 1 start with the last question tha t was direc ted to you by 2 Ms. Letsche. I would like to try to understand it in 3 the context of your earlier answers, in which, as I 4 understand it, you had indica te d tha t the S taf f 's 5 concern as expressed in item II.K.3.16 of NUREG-0737 was 6 with a reduction of SORY events.
7 And as I understood a number of your earlier 8 answers, you felt that there had been an improvement on 9 the order of at least a factor of eight in the reduction 10 of SORY events which you understood to be applicable to 11 the Shoreham evaluation relative to a BWR-4 base case.
12 Is that basically correct?
13 A (WITNESS H0DGES) Approximately a factor of
(~))
\
14 eight that are attributable to valve design 15 improvements, if you are looking at only failure 16 problems that are related to the design of the valve.
17 0 And then there were additional reductions, 18 looking at it from the standpoint of reductions from the 19 challenge end, of the SORV events as well; is that 20 correct? In other words, a factor of three that you 21 have been talking about from low low setpoint and so 22 forth; is that correct?
23 Let me not tie you up in numbers, because I
')'
' 24 know that we've been wandering all over. If you want to 25 address that as wall, that's fine. But wha t I'm trying
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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'y 1 to get a t is whether you believe from a standpoint of 2 everall s reduction in SORY events in item II.K.3.16 an 3 adequate basis for a licensing decision has been J
4 demonstrated in this a pplica tion. And I realize we've 5 been rambling all over this area. Ms. Letsche asked you 6 whether you felt that the requirement of II.K.3.16 had 7 been complied with, and un til your last answer I thought 8 you had said yes, and then you said no to a narrow 9 question.
10 JUDGE BRENNER: Mr. Irwin, this is very long.
11 MR. IRWIN: I will start again if you would 12 like.
(~%, 13 JUDGE BRENNER: Let me see if I can help. And 1 i
\' /
14 it sounds like the kind of -- it sounds like our 15 ultimate finding by the time we put it together, 16 although you are certainly entitled to make a -- I think 17 ve understand the record on this point, and maybe this 18 helps.
19 The reason he said "substantially" as ooposed 20 to " compliance" at the end is beca use he ha s already 21 testified that he has got some other things he wants to 22 look at and he doesn 't want to preclude that. Am I 23 interpreting that right, Mr. Hodges?
r^5
- x. 24 WITNESS HODGES: Yes. I think I've stated 25 that as f ar as design-rela ted problems, th a t they are in rw f )
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
8670 O the de11re=x or waet we oo1a eccept es this ora = of 2 magnitude. I think I had said that an eight would be 3 oKsy, a three migat be okay, ss far as factors of 4 improvement.
5 But there are additional things I would like 6 to look at. It may well turn out that when we get 7 through we don't require any other thing, in which case 8 ve will accept this factor of eight. But I would like 9 at this point to hold my options open.
10 11 12 13 9 14 15 16 17 18 19 20 21 22 23 O v 24 25 O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8671
) 1 JUDGE BRENtiER: I don't know if this helps 2 you, too. I also think we have a record on what the 3 parameters of the open options are, and what might be 4 involved. Let me ask Mr. Hodges one other question.
5 Mr. Hodges, as I understand it, 6 notwithstanding the words in II.K.3.15 about this order 7 of magnitude, if they had come in with more than an 8 order of magnitude reduction, but you saw something else 9 that you thought could be done and they hadn't done it, 10 you are not hung up on the number so much as taking a 11 look at all reasonable avenues of improvement, correct?
12 WITNESS HODGES: That is correct.
n 13 BY MR. IRWIN: (Resuming)
\.
)
14 0 Let me make sure I know where we are. Without 15 precluding your in te rest in f urther improvements which 16 may be revealed by analyses being undertaken by LILCO or 17 o th erwise , is it your belief that the impro vements which 18 have been taken to date indicate substantial compliance 19 or consistency with the provisions of II.K.3.16 with 20 respect to a licensing decision in this case?
21 A (WITNESS HODGES) You just asked two different 22 questions, I think, in one sentence, and the answer to 23 the first one is yes, and the answer to the second one n
() 24 is, I am not quite sure yet.
25 0 Well, I guess then I need to know what more
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NY ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8672
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!, j 1 you need to find out in order to understand your 2 position with respect to a lice n sin g decision in this 3 case.
4 JUDGE BRENNER: All right, Mr. Irwin. It was 5 asked and answered. Iake my word for it. If you are 6 interested in getting your panel out of here, I am not 7 going to push othat people. I am sorry if you think I B am giving you a hard time. It wasanimportaNt area for 9 the Board. That is why we asked those questions, and we 10 are well focused on them. Do you think there is 11 something else that we don't have? He explained the se t 12 point changes he is looking at.
,f-~s, 13 MR. IRWIN: No. I think that in specifics the
\' '! 14 record is very well focused, and I will drop the 15 question.
16 JUDGE BRENNER: Well, if th e re is something 17 other than the set point changes.
18 MR. IRWIN: No, I was not trying to elicit 19 anything specifically further out of Mr. Hedges on 20 that.
21 BY MR. IRWINt (Resuming) 22 0 Mr. Smith, you were asked by Judge Brenner 23 shortly before the lunch break a general question, two (b
(_) 24 questions, in fact, concerning the MSIV set point 25 evaluation that LILCO is undertakin. Do you recall
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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)
8673 l
(_) 1 being arked those questions? '
2 A ( W ITlf ESS SMITH). I remember the conversation, 3 yes.
4 0 One question, as I recall, was whether the
/ 5 licensing proceedings that are now lii. progress had 6' affected'the timing or substance of LILCO's 7 investigation of that po ten tial design change or that 8 potential change.' Has it'l 9 A (WITNESS SMITH) No, it has not.
'10 0 Have'you,a general idea as to when LILCO's 11 evaluation-is likely to be complete on that change?
12 A (RITNESS SMITH) A time f rame of- the fall of, 13 this year or late in 1982.
9 ,
14 0 Mr. Malovch, on '_?uasday,.as I recall, you made 15 reference to the use of as built drawingr. and other .
16 the l41nda of inforcation availnble to fou f.
17 determinatio4 of SRV operability and riping integrity.
18 Do you recall tr at discussion?
19 A fWITNESS MALOVEH)- Yes, I do.
20 0 .Just so we hava it,in one pisce, can you i 21 cla rifIc the use yo u' mir.s ty p'ically of as built drawings 22 in th e, d'e t e r m i n a t. ira n of SFV opecability and piping
/ /
23 inte/ritT in your work?
r'^3 ,
( _) 24 A (WITNESS MAOLVRH) Okay. First o f all, in 25' fact, as built drawings have been re vie wed of a ll o f the
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- ALDERSC'1 REPORTING COMPANY, INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8674
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1 SRV discharge piping. There is two aspects to that 2 review. One is to assure the a pplicability of the 3 results of the test, given the difference in 4 configuration between the test facility and the Shoreham 5 plant. That review has included a review of the as 6 built drawings, and I might note that the review of the 7 as built drawings f ound tha t there were no differences 8 in the as built configuration as compared to the, let's 9 call it as designed configuration that would have been 10 significant enough to alter a conclusion on that 11 evaluation.
12 - Th e second aspect of the consideration is to 13 assure that the Shoreham discharge piping is adequate of 14 sustaining the load event, and therefore not adversely 15 loading the valve and affecting its operability. That 16 evaluation, the evaluation of as built piping in that 17 regard has been factored into the engineering models, 18 the mathematical models of the piping, and as we noted 19 the other da y, we will be performing analysis to confirm 20 some judgmental factors that have been made in our 21 evaluation, and that analysis will use medels reflect 22 the as built conditions.
23 0 Mr. Boseman, you were asked yesterday by Dr.
m
- 24 Carpenter wh ether you could inquire into two aspects of 25 the use of lubricants in SRV assemblies. Do you recall p
%,i ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8675 f (, ') I those questions from Dr. Ca rpen ter ? And if so, have you v
! 2 any kind of status report that you can provide to the 3 Boa rd on your inquiry?
4 A (WITNESS BOSEMAN) Yes, I do remember the two 5 questions. One specificsily was the basic question of 6 whether castor oil will polymerize in the environment in l
7 which the SRV is located. I did contact -- I did leave l 8 messages last night for individuals to get back to me 9 today, and at lunch I did ha ve a b rief discussion, and 10 for the temperature and radiation conditions in the area 11 and in the suspect areas of where this castor oil is 12 used, there is concerned that polymerization does occur.
13 Detailed evaluation will be undertaken as a 7- -
)
14 result of that discussion, so that we can determine what 15 kind of effect, if any, it might have on -- primarily 16 the concern is whether it would have an adverse effect 17 on the material, the seal material, for example, which 18 we already know of, but in the case of perhaps a 19 stickiness relative to sliding surfaces, th a t evaluation 20 is not complete. It is under way.
21 The other question I believe you asked me is 22 whether or not there were any materials, soe tfically 23 l ub rica n t type materials that were subject -- that were ps
\_.) 24 volatile, and excluding the castor oil, the only other 25 two lubricants that are used for threaded joints in
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ALDEASON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8676
(,) 1 particular are Never-Cease and a g r a phi te base ma te ria l, 2 neither of which are considered volatile, and they are 3 not inside the pressure or, shall we say, the fluid 4 boundary, the fluid flow or the wetted boundary. Those 5 lub ricants a re used to bolt up the bolted closures of 6 the valve.
7 JUDGE CARPENTER: Did you indicate that there 8 was no lubricant used on the C rings?
9 WITNESS BOSEMAN: No, sir. I indicated that 10 castor oil was used on an 0 ring, and you had requested 11 yesterday, you had asked a question with regard to 12 polymerization of castor oil. That is a lubricant. I c~s 13 addressed that as my first response.
( !
x'.) Castor oil appa rently was 14 JUDGE CARPENTER:
15 also used to help the sealing of the diaphram. Are you 16 telling me that castor oil is also used as a lubricant 17 on the 0 ring?
18 WITNESS BOSEMAN: Yes, sir.
19 JUDGE BRENNER: I guess I thought there was 20 another question. At least the one I was interested in, 21 you said that castor oil was no longer being used, but l
22 the date at which it had stopped being used was not that 23 long ago, and you also said it was used in the assembly n
(_) 24 process, and from all of that I inferred that even 25 though Shoreham is not operating, it could have been 1 O l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 m
8677 I[ ) 1 used in the valves that will be used at Shoreham, 2 depending upon what time frames are involved, and that 3 is why we asked that.
4 WITNESS BOSEMAN: Yes, that is being checked 5 also.
8 JUDGE BRENNER: I take it then our inference 7 was correct that it is possible that back a year or so 8 ago it could have been used for the same valves that 9 will now be installed at Shoreham?
10 WITNESS BOSEMAN: You are correct, Judge 11 Brenner. In addition, I was reminded tha t the area in 12 which it would be used, there is a modification that was 13 recommended by the SIL, Supplement 10. At that time, 14 that cleanup, that lubricant could be cleaned out in 15 tha t area and the parts replaced accordingly so that 16 there is no castor oil in it.
17 JUDGE BRENNER: And presumably part of the 18 checking vill be, A, to see if it was use( in the first 19 place, and B, if so, whether appropriate measures have 20 been taken?
21 WITNESS BOSEMAN: Yes, sir, that is standard 22 procedure.
23 JUDGE CARPENTER: May we have copies of SIL 10
,~_
\
1 (
l
\_) 24 at your convenience ? Or Amendment 10?
25 WITNESS BOSEMAN: Supplement 10. After the
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l ALDERSON REPORTING COi4PANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8578 1
meeting, I could get it. I don't have it right with !
())
1 s.
2 me.
3 JUDGE CARPENTER: Or include them with the 4 report that is forthcoming.
5 WITNESS BOSEMAN: Yes, sir.
6 MR. IRWIN: Judge Brenner, I don't have any 7 further questions for these witnesses.
8 JUDGE CARPENTER: What radiation level are you 9 assuming?
10 WITNESS BOSEMAN: The standard radiation level 11 for the normal dry well area, where the safety relief 12 valves are located. I don't have a number at my 13 fingertips.
9 14 JUDGE BRENNER: Mr. Bordenick?
15 MR. BORDENICK: Judge Brenner, I have no 16 further questions of this panel.
17 BOARD EXAMINATION 18 BY JUDGE MORRIS:
19 0 M r. Smith , I am sorry to interrupt you, but we 20 are really going to get up and leave at 2:30.
21 Was any consideration given to alternate 22 suppliers at the time the target rock valves were 23 purchased?
A
(_) 24 A (WITNESS SMITH) J udge Mo rris, it is difficult 25 to track back that far. Feing that LILCO had not been a LJ ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, 0.0. 20024 (202) 554 2345
8679
! ) _
1 utility with previous nuclear experience, it is my 2 belief that we relied very heavily on our NSSS 3 supplier's recommendation, and it was a known fact that 4 the three-stage target rock valve was a problem 5 character, and thst the two-stage, I believe there were 6 numerous reports given by General Electric to LILCO on 7 th? merits of going with that valve.
8 0 Having purchased these valves, an d presumably 9 the plant is designed to accept them, is it possible to 10 replace them with an alternate design?
11 A (WITNESS SMITH) Probably Mr. Boseman could 12 better anseer that.
( 13 A ('4 IT N E S S BOSEMAN) '41 t h the present standard.
t l 14 safety relief valves that GE uses in the product line 15 for the particular size in question, the answer is no, 16 without an impact on the arrangement you would have to 17 modify specifical'ly the discha rge end of the valve, not 18 the valve, but the piping. I could not take another 19 valve of nominally the same size as long as it met the 20 flow capacities, et cetera, and substitute it directly.
21 BY JUDGE JORDAN: (Resuming) 22 0 I would like one followup question. Ms.
23 Letsche asked you about the 13 possible cures for m
s > 24 reduction in challenges of II.K.3.16, and I would like 25 to be clear. Has LILCO or GE considered the 13 possible
( -
a ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WA3HINGTON, D.C. 20024 (202) 554 2345
8680 1 reductions? Would those, if they applied all 13 of 2 them, achieve a factor of ten reduction in challenges, 3 or is it LILCO's position that it is not possible to get l 4 a reduction of ten in challenges? l l 1 5 A (WITNESS HAYES) To answer your first 6 question, se did look in the owners' group report at all 7 of the 13 GE -- I am sorry, strike that --
NRC 8 recommended options, and we did evaluate them, and we 9 included benefit numbers based upon the analysis methods 10 that I had told you about earlier. We had concluded in 11 that report, looking at not only the NRC suggested 12 changes, a few of which, by the way, included changes e 13 which would impact valve failures as opposed to
( )
14 challenges, which was another indicator to us that they 15 were looking at both, but if you looked at just 16 modifi:1tions which affected challenges both in the NRC 17 and a few that GE had also considered, we couldn't reach 18 the order of magnitude reduction by just ch allenges.
19 JUDGE JDRDAN: That is all.
20 (Whereupon, the Board conferred.)
21 JUDGE BRENNER: Ms. Letsche?
22 MS. LETSCHE I have one question, Judge 23 Brenner.
,n.
O 24 RECROSS EXAMINATION 25 BY MS. LETSCHE:
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON O.C. 20024 (202) 554-2345
f 8681
( ) 1 Q Mr. Smith, with regard to the MSIV evaluation u./
2 that you have been talking about with the Board, is it 3 possible that that evaluation will be completed before 4 fual load, so that change, if you decide to make it, 5 could be implemented prior to fuel load?
6 A (WITNESS SFITH) It is not conceivable that 7 that change would be made prior to fuel load.
8 MS. LETSCHE: Thank you.
9 JUDGE BRENNER: You said it is not 10 conceivable?
11 WITNESS EMITH: That is correct.
12 JUDGE BRENNER: Why?
g 13 WITNESS SMIIH: On the present schedule --
\
14 JUDGE BRENNEP: I was going to ask you what 15 your assumptions are.
16 WITNESS SMITH: Even if I make an assumption 17 of September 20th, which is the present f uel load date, 18 and the analysis is done in the fall --
19 JUDGE BRENNER: Wait a minute. I don't want 20 to get into a schedula dabste, but we had a formal
! 21 report that the fuel load date was November something, a l
22 six-week slip or something. Did I make th a t up in my 23 mind?
^
l ( ')
\> 24 MR. REVELEY: So, you didn't make it up, 25 Judge. You have a letter indicating that tnera has been l ("%
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i ALDERSoN REPORTING COMPANY,INC, f
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8682 0 ' e six-weex e119- Thet is deiee oursued to see it it 2 will in fact endure.
3 WIThESS SMITH: Judge Brenner, let me add 4 this, that once the analysis is done, the set point 5 change would change all of the preoperational testing 8 tha t would be done associated wi th those particular 7 systems, and that is more of the impact than making the l 8 set point change itself, I believe.
l 9 JUDGE BRENNER: Well, let's assume you make 10 the change after you are in commercial operation. What 11 do you do then about all of the procedural changes and 12 so on?
13 WITNESS SMITH: The change would be made at 14 the first extended outage that would facilitate being 15 able to do the pre-op testing that would be necessary.
18 JUDGE BRENNER: Well, you are entitled to your 17 schedule, but it is July 30th, and here we are. And you 18 know, I judge the worth of a witness's testimony by the 19 way I a ssess the validity o f everything a witness tells 20 me, and the realism attached.
21 WITNESS SMITH: All I can add to tha t, Judge 22 Brenner, is that I have direction from my management to 23 assume a specific schedule and work towards it, no b 24 matter what I have to do. I don't m a '< e the final 25 decision. There are many factors beyond my licensing p
b ALDERSON REPORTING COMPANY, :NC, 400 %RGINIA AVE., S.W., WASHINGTON O C. 20024 (202) 554-2345
8683
() 1 responsibilities that come into th a t .
2 JUDGE BRENNER: Okay. That is very fair.
3 That is a little different than the ea rlier concise 4 statement that it is not conceivable, and I certainly 5 understand your last answer.
6 MS. LETSCHE: That is all I have.
7 JUDGE BRENNEB4 Does anybody else have 8 anything else?
9 (No response.)
10 JUDGE BRENNEP: Okay. I guess we are 11 completed with this panel. All ri gh t, we are, and I 12 would like to thank all of you.
7 ; 13 MS. LETSCHE: I suppose that would be subject
! i
~
14 to when we get all of this additional information that 15 is going to be forthcoming with respect to the open 16 items from the stsff. As we indicated earlier, if 17 Suffolk County felt it was necessary at that point to 18 request a recall --
19 JUDGE BRENNER: We will evaluate any further 20 request in light of the record and the reasons made for 21 the recall and so on, but we have made no ruling now 22 tha t as far as the Board is concerned, that we are 23 holding the litigation on this issue open.
O)
(_ 24 MS. LETSCHE: I just wanted to restate my 25 understanding of where we were, Judge Brenner.
f^8
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8684
( 1 JUDGE BRENNER: I don't mean to imply that you 2 would have a standard of reopening of the record on 3 sudden new information, but there would be -- suffice it 4 to say it would b3 those kinds of considerations, what 5 the additional information means in light of the 6 decision we hsve to make, and in light of the record 7 previously adduced.
8 MS. LETSCHE: I was just stating our intention 9 to do whatever we felt was appropria te based upon 10 wha tever is forthcoming.
11 JUDGE BRENNER: Yes, and I hope you do that, 12 because your review will assist th e Board in focusing on
,-- 13 what the other information contains.
!\')J 14 Well, I would like to thank all of you very 15 much, some of you for your time and efforts in assisting 16 us in understanding this subject. Some of you may be 17 here next week to assist counsel. I don't know. Some 18 of you will be here on other issues. Mr. Hodges, I am 19 not going to say good-bye to you until this hearing is 20 over.
21 (General laughter.)
22 (Witnesses excused.)
23 JUDGE BRENNER: If there is nothing else on s
) 24 any other matters, we will adjourn at this time.
25 MR. IRWIN: I have 1 happy snnouncement, and q%_/
ALDERSON REPORT:NG COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 tha t is that there are signed settlements of two issues 2 which we can either try to distribute to tne Board this 3 afternoon -- I have got them upstairs --
4 JUDGE BRENNER: No, make it next week.
5 MR. IRWIN: These are ones you ha ve heard 6 about. They are ECCS cutof f and the notice of disabled 7 safety systems.
8 JUDGE BRENNER: Maybe I should state this as 9 far as the Board is concerned. The only matters pending 10 before us'for ruling now is any action that we take on 11 the SAI conflict question, and we are waiting to hear 12 from the other parties as to whether they are going to 13 file a response or not, and we will be informed of that 14 next week by the other parties, and we, of course, are 15 aware that the responses from LILCO and the staff have 16 been bef ore us for soce time now. We haven't forgotten 17 them, and we have been working on them.
18 If there is something else that parties are 19 waiting for a ruling on from us, tell us, because we 20 don't like to get too backed up on our rulings.
21 MR. REVELEY: We are aware of nothing else, 22 Judge.
23 JUDGE BRENNER: Good. All right. I hope (m
sm) 24 everybody has a nice weekend, and we will be back here 25 Tuesday at 10:30. Remember that next week we are going v
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8686 (O
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1 to be adjo.2rning st 2:30 promptly on Thursday rather 2 than Friday.
3 JUDGE JORDAN: I have one further item. I 4 probably won't be back, at least not soon. I have 5 another job I have to do. But I have enjoyed working 8 with all of you. You have shown great professionalism 7 and expertise on the part of the witnesses. I have 8 enjoyed it.
9 JUDGE BRENNER: And we appreciate Judge 10 Jordan's presence, too, of course, and depending upon 11 how long the case lasts, he may or may not be assisting 12 us on other matters.
13 (Whereupon, at 2.30 p . m. , the hearing was S 14 adjourned, to reconvene at 10:30 a.m. the following 15 Tuesday, August 3, 1982.)
18 17 18 19 20 21 22 23
'x 24 25 g
U ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
NUCLEAR REGULATORY COMMISSICN O -
This is to certify that the attached proceedings before the BEFORE THE ATOMIC SAFETY & LICENSING BOARD ,
in the matter of:. Long Island Lighting Company (Shoreham Nuclear Power Station)
- Date of ?roceeding: Julv 30, 1982 Docket !! umber: 50-322 ot 1
? lace of ?roceeding: Riverhead, New fork were held as herein appears, and. that this is the original t: anse:-ip thereo: for the file of the Co==ission. .
Ray Heer O f f i d a l .i e p o r t e r ( T y p e d )
nem >
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on OfficiaY eporter (Signature) l
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3
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