ML20058H722
| ML20058H722 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/05/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8208090058 | |
| Download: ML20058H722 (221) | |
Text
- _. . _ _ _ _ _ _ _ _ _ _
NUCLEAR REGULATORY COMMISSICN 9 -- T gr "
ATOMIC SAFETY PND LICENSING BOARD
%. wN T '
O In the Matter ef:
LONG ISLAND LIGHTING COPPANY )
) DOCKET NO. 50-322-OL (Shoreham Nuclear Power Station) )
O DATE: August 5, 1982 PAGES: 9134 thru 9302 AT: Riverhead, New York
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.uDERSON /* REPORnXG O /-t 400 Virginia Ave., S.W. Washin g=n, D. C. 20024 Q Telephc=e: (202) 554-2345
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9134
() 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 - - - - - - - - - - - - - - - -
-x.
5 In the Matter of :
6 LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL 7 (Shoreham Nuclear Power Station) a 8 - - - - - - - - - - - - - - - - -x 9
10 Riverhead County Complex 11 Legislative Hearing Room 12 Riverhead, N.Y.
13 Thursday, August 5, 1982 14 The hearing in the above-entitled matter 15 convened, pursuant to notice, at 8435 a.m.
16 BEFORE:
17 LAWRENCE BRENNER, Chairman 18 Administrative Judge.
19
- 20 JAMES CARPENTER, Member 21 Administrative Judge 22 23 PETER A. MORRIS, Member
() 24 Administrative Judge 25 O
i l ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9135 O i ArrEARANCES.
2 On behalf of Applicants 3 W. TAYLOR REVELEY III, Esq.
4 ANTHONY F. EARLEY, Esq.
5 DONALD P. IRWIN, Esq.
6 Hunton & Williams 7 707 East Main Street 8 Richmond, Va. 23212 9
10 On behalf of the Regulatory Staffs 11 RICHARD BLACK, Esq.
12 DAVID A. REPKA, Esq.
13 Washington, D.C.
14 15 On behalf of Suffolk Countys 16 KARLA J. LETSCHE, Esq.
17 Kirkpatrick, Lockhart, Hill, 18 Christopher & Phillips 19 1900 M Street, N.W. .
20 Washington, D.C. 20036 21 22 23 24 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
-W --
9135-A Q 1 CONTENTS 2 WITNESSES DIRECT CROSS REDIRECT RECROSS BOARD 3
Marvin W. Hodges, 4
Leonard J. Calone, Harry T. Carter, 5 Eugene C. Eckert, Henry C. Pfefferlen, 6 John A. Rigert, William P. Sullivan, 7 By Ms. Letsche 9150 8
(AFTERNOON SESSION P. 9245) 9 Marvin W. Hodges, to Leonard J. Calone, Harry T. Carter, 11 Eugene C. Eckert, Henry C. Pfefferlen, 12 John A. Rigert, 13 William P. Sullivan t 14 By Mr. Reveley By Judge Morris By Judge Carpenter 9256 9261 9273 15 By Ms. Letsche 9284 16 EXHIBITS 17 SUFFOLK COUNTY NO. IDENTIFIED RECEIVED REJECTED
'0 39 9171 9173 19 40 9189 41 9229 20 36 9248 37A 9251 21 37B 9252 LILCO NO.
23 18 9298 24 25 O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W.. WASHINGTON, D C. 20024 (202) 554 2345
9135-B 1
f)')
u CONTENTS (c ont ' d) 2 MATERIAL BOUND IN TRANSCRIPT 'PAGE 3
S 4 Settlement agreements concerning SOC Contention 9, dated .. 9138 July 23rd, signed by counsel for all of the cognizant 5
parties; LILO, the staff, SCC and Suffolk County 6 " Resolution of SC Contention 28 (.al (.1). and SOC Contention 7A(.ll, ECCS Cutoff," signed by counsel for those same 7 four parties.
8 Suffolk County Exhibit 39 ................................. 9173 9
Memo from Joel J. Kramer to Robert L. Tedesco, regarding .. 9249 10 Safety Evaluation Report Input Exhibit No. 37A 11 IE Bulletin No. 8 2-17 on the failure of 76-185 control . . . . 9 252 rods to fully insert during a scram at a BWR. Exhibit No.
12 38 13 Cover page of the emergency shut down emergency procedure . 9253 9 number 29.010.01. Exhibit No. 40 15 Residual Heat Removal (RHR) System procedure, number 23.121.01 (cover page through page 9) Exhibit No. 41 ..... 9254 16 An Analysis of the Reliability of Light Water Reactor ..... 9299 17 Power-Actuated Pressu're-Relieving Valves And Safety (Relief) 18 Valves And Their Comoonent Parts Using The Nuclear Plant Reliability Data Sys' tem (NPRDS) 19 LILCO' S RESPONSE TO BOAFD PEOUEST OF AUGUST 3,198 2 FOR. . . . 9300 20 SRV RECORD REFERENCES 21 RECESSES: MORNING NOON =
22 9168 9244 23
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() 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA /,vi, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9136
' E E S .C E E D 1 E .G 2 2 (8s35 a.m.)
3 JUDGE BRENNER: Good morning. Le t us take 4 what I think are the only miscellaneous items as quickly 5 as we can.
6 The first item, the closing date for the 7 deposition of Mr. Jones, should it be September 7 or 8 should it be later?
9 MR. REVELEY: September the 7th I think is 10 fine with us, Judge Brenner.
11 MS. LETSCHE4 Judge Brenner, I talked to my 12 people last night after the hearing, and they were going 13 to get in touch with people from Richmond. I have not 14 heard back from them, and if I could let you know during 15 the morning break for sure what the answer to that is, I 16 would appreciate it.
17 JUDGE BRENNER: That will be fine. The point 18 is unless there is a strong reason, we think the 15th is 19 too late. In fact, we are nervous that the 7th is too 20 late, f rankly; and you were here for the c'onversation 21 yesterday. I am setting it for the 7th so that if Mr.
22 Jones ends up with a big problem that week, and we 23 certainly want to try to be courteous with respect to 24 his time in view of his other important responsibilities 25 for the County; but I hope truly that the parties can O
I ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9137
() I take that deposition much earlier than the 7th.
2 MS. LETSCHE: Judge Brenner, I understand 3 that. I just want to verify it with Mr. EcMurray.
4 JUDGE BRENNER: I know you understand .'.t. I 5 just want you to show this part of the transcript and 6 that part to your co-counsel. All right. Come back to 7 me after the break on this.
8 We have two settlement agreements agreed to 9 and signed by all of the cognizant parties, and we are 10 prepared to approve both of them. They are settlement 11 agreement concerning SOC Conten tion 9, notification tha t 12 a safety system is disabled , dated July 23rd, signed by 13 counsel for all of the cognizant parties -- that is, 14 LILCO, the staff, SOC and Suffolk County.
15 The other agreement is entitled " Resolution of 16 SC Contention 28(a)(1) and SOC Contention 7A(1), ECCS 17 Cutoff," signed by counsel for those same four parties.
18 This has the resolution, then an Attachment 1 which is 19 referenced in the resolution as an integral part thereof.
i 20 As always, we commend the parties for their 21 ability to settle issues. We recognize the possibility l
22 that we may be hearing more with respect to some aspects 23 of this. The ECCS cutoff resolution particularly
() 24 indicates to us even from reading the final document the 25 hard work that must have gone into it on the part of all
()
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9138 O i verties, and it is c1 ear to us hat as of 1 oortent 2 consideration to the parties, and we think this is a 3 sensible resolution. And even if some aspect of the 4 dispute ultimately comes back to us for litigation, it 5 is going to be a focused, inte111 gent dealing with it; 6 and we appreciate the efforts of all parties to put 7 things in that posture.
8 I note from tire to time the form provides for 9 the Board to sign it. We approve it on the record to instead, and we will bind both documents in at this 11 point.
12 (The information referred to follovss) o
14 15 16 17 18 19 20
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21 22 23 24 25 0
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
LILCO, JulyJB, 1982 6'
Ly -in *1 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) )
SETTLEMENT AGREEMENT CONCERNING SOC CONTENTION 9 --
NOTIFICATION THAT A SAFETY SYSTEM IS DISABLED Following the submission of pre-filed testimony on SOC Contention 9 -- Notification that a Safety System is
) -
Disabled -- discussions were held between the parties that have resulted in the resolution of the Contention.
The parties have agreed to the following:
- 2. LILCO will install, prior to the conclusion of the first refueling outage, an annunciator in the control room that monitors the status of the six safety-grade power feeds at the Remote Shutdown Panel. This annunciator will enable the operators to know whether electrical power is
() available to the remote shutdown panel. The alarm will be wired in a f ail-safe mode so that any interruption of
electrical power or the disconnection of any of the alarm I wiring will automatically activate the alarm.
- 3. LILCO will also install, prior to the conclusion of the first refueling outage, in the remote shutdown panel enclosure, a manually-actuated system status display. This display will consist of indicating lights for each of the following systems:
- a. Reactor Core Isolation Cooling System
- b. Residual Heat Removal System
- c. Reactor Recirculation System
- d. Nuclear Boiler System
- e. Service Water System
- f. Reactor Building Closed Loop Cooling Water System
() 9 Fuel Pool Cooling System
- h. Instrument Nitrogen System These indicating lights will provide a consolidated display of the status of those systems controlled from the remote shutdown panel. Station operating.proceddres will be revised as necessary to require that the manual alarm at the remote shutdown enclosure will be initiated when a system inoperative alarm is received in the control room if the system, as controlled from the remote shutdown panel, would also be not operative. Copies of the revised procedures will be transmittedito SOC, and Suffolk County.
- 4. LILCO will ensure that Station Operating Procedures are revised as necessary to require that, when surveillance testing for operability has been performed in the control
() room after maintenance, the testing will also be performed at the remote shutdown panel. Copies of the revised procedures will be transmitted to SOC ans Suffolk County.
S. Should the NRC Staff require, or should LILCO otherwise make changes to the remote shutdown panel which are compatible with making the changes agreed to in this Agreement prior to the conclusion of the first refueling outage, the changes identified in this Agreement shall be performed at the same time.
Counsel for Long Island Coundel for Shoreham Lighting Company Opponents Coalition WM 4 L Counsel for NRC Regulatory
- h M[ M Counsel for SuffoLE County Staff DATED: July 23, 1982 O
l
7 N'
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) )
)
RESOLUTION OF SC CONTENTION 28(a)(i)
AND SOC CONTENTION 7.A(1) -- ECCS CUTOFF Suffolk County ("SC") and the Shoreham Opponents Coalition (" SOC") have submitted Contentions 28(a)(1) and 7.A(1), respectively, each of which contests whether LILCO has
{} complied with the TMI Action Plan requirement of NUREG-0737, Item II.K.3.21, concerning automation of the restart of the Core Spray ("CS") and Low Pressure Coolant Injection ("LPCI")
systems after manual termination of system operations.
SC and SOC have pursued these contentions because erro-neous operator actions at TMI in manually terminating emergency core cooling ("ECC") materially contributed to the severity of that accident. SC and SOC believe that if an automatic restart feature had existed at TMI, the severe core damage might never have occurred. Thus, SC and SOC believe that thorough investi-gations should be undertaken to determine whether features can
() be added at the Shoreham Nuclear Power Station ("SNPS") to lessen the likelihood that operator actions in shutting off ECC systems could aggravate the severity of accidents.
LILCO has previously performed or contracted for anal-() yses concerning automation of the LPCI and CS systems at Shoreham. These analyses are reported in FSAR Volume 16,Section II.K.3.21. Based upon these analyses, LILCO concluded that changes to the LPC: system should not be undertaken, pri-marily because of perceived " penalties of increased system com-plexity, reduced system reliability and restricted operator flexibility." FSAR, p. II.K.3.21-1.
SC and SOC do not necessarily agree with LILCO's posi-tion regarding the LPCI system. More important to SC and SOC, they believe that the existing analyses have not sufficiently r- considered possibilities for automated restart of the CS sys-L tem, whose logic, in the opinion of SC and SOC, is less complex and thus might be more easily modified than that of the LPCI system. Specifically, the existing analyses have not evaluated the feasibility and effects of an automatic CS restart feature which could be overridden by operators if the circumstances so required. Accordingly, SC and SOC believe that further CS-specific analyses must be performed to fully address the concerns reflected in NUREG-0737.
LILCO has agreed to undertake analyses requested by SC and SOC to determine whether the CS system can feasibly be
(} modified. This Resolution embodies that agreement and ensures that the deficiencies believed by SC and SOC to exist will be adequately addressed.
. Accordingly, the following is the agreement among the
() undersigned parties:
- 1. LILCO agrees to perform, at its expense and through its contractors, a study, more fully described in Attachment 1 hereto, of the technical feasibility, reliability effects, costs and other relevant aspects of installing at SNPS an auto-matic restart feature with a manual reset and manual override capability on the CS system (hereinafter, "CS Restart Feature"). The study will be undertaken on an expedited basis and will be completed as soon as possible. In no event shall it be completed later than October 1, 1982, except with the consent of the other parties hereto, which consent shall not be O unreasonably withheld. Not later than August 20, 1982, a writ-ten interim progress report will be made to the parties to the agreement, and upon request by any of them, LILCO will make available personnel performing the study to discuss progress on it to date. The study will belong to LILCO, which shall, how-
, ever, provide for its use by the Parties and the Atomic Safety and Licensing Board in connection with this Agreement.
- 2. The study, when completed, shall be promptly dis-tributed to all parties. During the 14-day period following the Parties' receipt of the study, upon the request of any other Party to this Agreement, LILCO will make available per-sonnel who performed the study to discuss its results, along v.. fg
l
-4.
l with analyses and other documents which underlie or pertain to l
() the study. On or before the fourteenth day following receipt of the study, the parties shall exchange their views as to the desirability of installation at SNPS of the CS Restart Feature evaluated in the study. The parties shall promptly thereafter report to the Atomic Safety and Licensing Board their positions with respect to installation of the CS Restart Feature at SNPS.
The parties' submission will be jointly made unless there are disagreements, in which case separate simultaneous submissions may be made.
- 3. If the parties are agreed on the appropriate course of action with respect to the CS Restart Feature in light of the results of the study, they shall recommend that the Board incorporate the results of such agreement in its decision in this matter. If the parties do not agree, then the parties may litigate, on an expedited basis before the Board, whether the SNPS CS system, without a CS Restart Feature, is consistent with the provisions of NUREG-0737 Item II.K.3.21. In such event, the issues to be litigated shall be limited to (a) the necessity of installation of a CS Restart Feature at SNPS and whether, without it, LILCO has demonstrated that it complies with NUREG-0737 Item II.K.3.21 or has adequately justified an exemption therefrom in light of the results of the study and
(}
any other material available to the parties; and (b) any other
-S-matters relating to or deriving from the CS Restart Feature and (3
V resulting from the study that remain in dispute among the par-ties, the most likely of which presently contemplated by the Parties is the possibility of lesser modification to the CS than the ECCS Restart Feature. Any such litigation will be limited to the CS system and will not allege that automatic restart or other changes should be made to the LPCI system. SC and SOC (or either of them) shall resubmit any such contention at the time the parties notify the Beard of their disagreement on the necessity for inclusion of the CS Restart Feature.
- 4. Suffolk County Contention 28(a)(i) and SOC Contention 7.A(1) are withdrawn, subject to potential resubmis-
~}
sion and litigation in accordance with the terms set forth in paragraph 3 hereof.
COUNSEL FOR S $ 7 hoar (6at6) 2 O COUNSEL FOR LILCO
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2/w/u, (Date)/~
SUFFOLK COUNTY
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h N hk bW M~ ~7[lo[gL CO'UNSI(JL FOR SOC " (Date)/ COUNSEL FOR NRC Staff (Date)
Approved by ASLB this day of July, 1982.
ATTACHMENT L PARAMETERS FOR STUDY OF AUTOMATIC RESTART FEATURE ON s SHOREHAM CORE SPRAY SYSTEM U This Attachment is an integral part of the " Resolution of SC Contention 28(a)(i) and SOC Contention 7.A(1) -- ECCS Cutoff" in the Shoreham Operating License proceeding and describes the characteristics of a restart feature to be eval-uated for installation on the Core Spray (CS) system at the Shoreham Nuclear Power Station ("SNPS"). The study will be performed by General Electric Company with any necessary assistance from the Stone & Webster Engineering Corporation.
- 1. The study will evaluate a CS automatic restart fea-ture with manual reset and manual override capability which lf will initiate automatic restart of the core spray pumps at Level 1 trip, following restoration of water level after a LOCA signal.
- 2. Core spray pumps and injection valves operation shall be capable of being manually overriden by the operator.
- 3. The study shall investigate the feasibility of designing the system with an indication on the 601 panel. Such indication shall contain a legend clearly so indicating when-ever the system has been overridden. The system design shall be consistent with the provisions of Regulatory Guide 1.47.
- 4. The study shall, in addition to describing the
!"i
(> design referred to above, include consideration of the following matters:
=2-(a) the technical feasibility of the CS Restart Feature designed in accordance with the study; (b) its effects, if installed, on other reactor control circuitry; (c) its effects on reactor safety system reliabil-ity, both for the CS system and for other safety systems generally; (d) any other anticipated beneficial or detri-mental side-effects for either safety system operation or normal operation of the reactor; and (e) cost and schedule impact of implementation (i) l' prior to commercial operation, and (ii) subse-quent to commercial operation.
- 5. While the study will focus on a CS Restart Feature for SNPS, it is recognized that the study may identify other modifications to the CS system which, while not constituting a full restart capability, might be feasible and addrecs some or all of the concerns of NUREG-0737 Item II.K.3.21. Without implying any obligation for the study to identify or evaluate alternatives to the CS Restart Feature, it is agreed that if such alternate modifications are identified during the study, they shall be included in the interim and final reports called l II for in this agreement.
1
9139
() 1 NR. IRWINs I have copies which I can give to 2 the parties and the Reporter at this point.
3
( JUDGE.BRENNER: Fine.
4 I guess the other item is the sequence of what 5 we might expect when we come back on August 24th in 6 Hauppauge. And as part of that I would like to 7 reascertain whether it is correct that we cannot 8 continue with the ATWS issue because of schedule 9 conflict of Mr. Hinor, I guess it was.
10 MS. LETSCHE No, Judge Brenner, there is no 11 problem with Mr. Nino,r's schedule for the first couple 12 of days after the break.
13 JUDGE BRENNERs Good. I guess I had misheard O 14 that or misremembered what I thought I had heard. So 15 the immediate course of action after the break will be
- 16 to pick up with Suffolk County's testimony on Contention 17 Suf folk County 16, ATWS.
18 What will we do af ter that ?
19 MR. REVE1EYs I think we would like to stick 20 with the schedule we had, Judge, which would take us 21 n ex t to SC 27, SOC 3, post-accident monitoring, then to 22 S C 21, Mark II, then to SC 3, SOC 8, ICC, followed by SC 23 25, SOC 19A --
I 24 JUDGE BRENNER: Mr. Reveley, I am sorry.
l 25 Could you give me a moment?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
9140
() 1 (Discussion off the record.)
2 JUDGE BRENNER: Please start over.
3 NR. REVELEY: After ATWS, SC 27, SOC 3,
{
4 post-accident monitoring; then SC 21, Mark II, followed 5 by SC 3, SOC 8, which is ICC; then SC 25, SOC 19A, RPV 6 integrity and testing. And it could be tha t we vill 7 suggest to you after the break that those two be shif ted 8 -- we are not certain at the moment -- ICC and RPV 9 integrity and testing. And then SC/ SOC 12, SC 13 to 15, 10 which are QA.
11 We would also propose to insert as convenient d any issues that remain from the settlements that are nov 13 being worked on should we not be able to resolve all O 14 aspects of each settlement.
15 JUDGE BRENNER: All righ t. And consistent 16 with your last comment, for now we are not inserting 17 back into the schedule the three human factors 18 contentions or ECCS pump blockage about which we will 19 hear some day.
20 MR. REVELEY: Well, ECCS pump blockage I think 21 is at the moment a truth. We are down to I think only I
l 22 one word where there may be some disagreement. I am 23 absolutely confident ECCS pump blockage will go the way 24 of all flesh.
l 25 (Laughter.)
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9141
() 1 JUDGE BRENNER Which way is that?
2 (Laughter.)
3 MR. REVELEY: I am certain ECCS pump blockage 4 will be settled on a meaningful and amicable basis. As 5 to all of the other settlements that we are working on 6 -- there are those that were on the list I gave you last 7 Friday -- I am also confident progress will be made.
8 There may nonetheless remain some issues, particula rly 9 in the human factors area, that we must litigate, but we 10 do not know what those issues are yet.
11 MS. LETSCHEs Let me also just add to that 12 that another possibility where an issue might remain is 13 on Contention 24, materials cracking. We might have to O 14 stick in --
15 JUDGE BRENNERs I am a little surprised you 16 have got post-accident monitoring that far up front 17 because -- hopefully you will use the break to narrow 18 that, because we remind you that we believe strongly 19 that that issue can be narrowed now that further .
20 information has been provided through the testing.
i 21 HB. REVELEY: We believe so also. The problem 22 we run into, Judge, is when you look at each of the 23 remaining issues, every one of them has its own problem, l
() 24 which is why we were having difficulty ordering them.
mean Mark II, for example, has the Humphrey concerns.
I 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9142
() 1 They have got to be engaged in some fashion.
2 Post-accident monitoring has a suggestion for settlement 3 from us to the County, plus the staf f's necessity to 4 decide what the SECY paper means. RPV integrity and 5 testing we think can be settled in part, but that effort i
6 has not yet begun. ICC will not settle. It is a very ;
7 difficult issue, and people are using the time to 8 develop the necessary information to ensure that when we 9 reach it it is handled well. And QA, of course, is a 10 trackless morass.
11 JUDGE BRENNERa Well, you know, you have just 12 very pungently and succinctly identified why we think QA 13 can be put in a better posture for litigation. That is O 14 not necessarily a settlement, which we doubt would 15 occur. In fact, we are not sure that we would be ready 16 to approve a total settlement when we have questions in 17 the area also.
18 But we discussed this before. There are a lot 19 of factual matters involving QA, and there can be 20 s tipula tions of fact focusing on which instances might 21 be illustrative so we do not have to slog through 20 22 when five will do. And I also expect those type of 23 discussions will benefit the parties as well as the 24 Board.
25 All right. We understand that discussions are
()
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
9143
() 1 con tinuing to take place. Obviously, you will have to 2 apprise us of any change in the status of SC 27 by that 3 last week before the break.
(}
4 MR. REVELEY: I think to the extent there is 5 change in the status, it will be the change suggested on 6 the paper I gave you on July the 30th, namely that items 7 E, F, I, and J may settle, if any of them settle. Item 8 C has been removed by iodine monitoring settlement 9 already, and Item K deals with thermocouples, which may 10 well go completely to the ICC contention where they also 11 figure. The rest of the items I do not think on that 12 contention are subject to settlement.
13 JUDGE BRENNER: All right. Also recall that O 14 any time the parties think it would be helpful to put 15 witnesses for all parties on the stand together for 16 upcoming contentions, you let us know. We are planning 17 on doing that for any aspects of SC 27 that are not 18 settled, so as to that one it is the other way around.
19 The party can tell us if there is a strong objection, 20 but thatiis what we are planning to do. But we will be j 21 flexible. It is an experiment. If in mid-course it l 22 appears not to be working, we will entertain a request 23 for adjustment.
/ 24 JUDGE CARPENTER: I just santed to say to th e j (,7 l
l 25 County in particular I can appreciate that this deprives O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
9144
() 1 the County's counsel for that moment of being able to 2 consult, so that for that period when all of the 3 witnesses are sitting as a panel, you see that that is
{
4 particularly advantageous to the Board to get very 5 crisply and logically the different views and the .
6 different lines of evidence tha t all parties have to 7 present simultaneously.
8 So I think over the break if you could think a 9 little bit about some way in which the possible impact 10 on you might be attenuated in the spirit of seeing what 11 the Board 's needs are and the Board also looking very 12 carefully at the County's needs with respect to that.
13 So I do not think it necessarily has to be the whole O 14 f ormat in that style, but I think it might be very 15 effective, particularly with respect to the Board's turn 16 if all witnesses were available simultaneously, and so 17 we can get some eyeball-to-eyeball interplay.
18 MS. LETSCHE: We will certainly consider it, l
19 J udge Ca rpe n te r. Frankly, other than Judge Brenner's 20 men tion of it the other day, it was not anything th at 21 had over occurred to us, and frankly, we have not even 22 focused on exactly how it would work or how it would 23 affect us, but we will do so over the break.
() 24 JUDGE CARPENTER: Thank you.
25 JUDGE BRENNERs With respect to issues that we O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9145
() I have not scheduled yet because the staff review has not 2 been completed, which may be for reasons that LILCO was 3 not ready for the review to be completed -- I am not 4 pirning any blame; I am just stating the status of it --
5 we received the status letter reports from staff counsel 6 the other day, which we apprecia te very much. It is 7 very helpful to be kept apprised in that fashion.
8 At some poin t, certainly by early in 9 September, we expect the parties to meet even on those 10 issues, and even though the staff's review might not yet 11 have culminated in a written evaluation, in a spirt of 12 early negotiations so that the parties are kept informed 13 as to what is occurring and what is open on the review, O 14 and we can ctart getting possible settlement reports on 15 those issues very close to the time, if not 16 simultaneously with the staff's manifestation of 17 completion of its review by issuing some written 18 result. And we will leave the timing up to the parties 19 as to when it would be most beneficial to begin that 20 process; but we expect it to begin no later than early 21 September and hopefully even before that. Do not wait 22 for the completion of the review to start is what we are 23 saying. -
( 24 MR. REVELEY: Let me add one thing to that, 25 Judge. So far as we are concerned, the company is very
(
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l 91u6 ,
i
() 1 eager to avoid the normal progress of events on these 2 contentions. In other words, we do not simply want 3 people to conduct some discovery and then go away and
{
4 file written testimony and then start a settlement 5 process; because what we frequently have found is we do 6 not really figure out what the issues are until we see 7 the County's written testimony. Rather than doing that 8 ve would like to come to the Board with a settlement 9 agreement on the contention and wi th testimony clearly 10 focused on whatever it is that remains in dispute, if 11 anything.
12 Now, I think we can work that out with the 13 other parties, that we have not had a chance to talk to 14 them about it. If we cannot, then we vill probably ask 15 you to change the procedure that now exists which 16 contemplates the normal progress and replace it with 17 another procedure which contemplates the process that 18 has been going on in this proceeding and the real world l 19 for the last couple of months on all of the issues 20 except the four big ones.
21 JUDGE BRENNER: Well, I think wha t I just said 22 is consistent with that. We are changing the procedure 23 in effect based upon what I said prior to your comment.
24 And the idea is for the staff, I guass, to take the 25 initiative and let the parties know when your experts O
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() 1 are ready to meet with them, and tha t readiness should 2 be before the completion of a written review at a live
() 3 4
status report settlement negotiation session.
In addition, depending on when these issues 5 that we have deferred already for litigation and the 6 extent of what is left for litigation after these 7 discussions, and where we are in the course of other 8 issues we are litigating, and all of these complicated 9 factors, that is a long way of saying we would entertain 10 a suggestion of litigating these issues in Bethesda if 11 ve are there already, if we have completed our business 12 here on other issues. But we will hear from the parties 13 on that.
O 14 And I should disclose, I had a quick 15 conversation in the hall with Mr. Black that stimulated 16 my last comment. He asked if we had established 17 definitely that we would litigate all issues here , and I l
18 said not necessarily. And I have now disclosed that 19 quick conversation, and so the parties will be thinking .
20 about it with respect to these issues. We will 21 entertain that request with respect to other issues, but 22 I do not imagine we will get the request with respect to 23 other issues.
j 24 MR. REVELEYs As far as LILCO's concerned, we 25 are certainly amenable to litigate some issues in O
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O ' setne am-2 JUDGE BRENNER I thought that since I have to 3 pay taxes there, I ought to spend one day a year there.
{
4 (Laughter.)
5 MR. REVELEY: We would even be willing to 6 litigate in Richmond.
7 (Laughter.)
8 (Discussion off the record.)
9 JUDGE BRENNER I think that concludes all 10 other matters that we have to take up before the break, 11 and we can launch into the testimony.
12 Are there any other matters?
13 MR. BLACK I would like to just reiterate 14 what I think the Board and parties know, but Mr. Fodges 15 is not available due to a previous commitment that third 16 week in August. So to the extent that we could 17 hopefully focus questions to him, that wouln be helpful, 18 if it becomes obvious that we may not finish this panel l
19 today.
20 JUDGE BRENNER4 That must be what I 21 remembered. I knew some witness had a problem that 22 week. All right. We will continue without him if we 23 are finished with him. But if it deprives the staff of
() 24 their ability to cross examine the County -- that is, if l 25 you can find nobody else to advise you -- hopefully, you O
I l
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() I can overcome that. Also because of Mr. Hodges' 2 involvement not just in this issue but in so many other
() 3 4
issues with respect to the systems that, after all, interrelate at one point or another in the reactor, we 5 would certainly expect, and I know we do not have to 8 direct, that Mr. Hodges read the transcript of that week 7 on the ATWS issue. And if there is anything that the 8 staff feels needs correction as a result of that, we 9 vill entertain tha t request, too.
10 MR. IRWIN: Judge Brenner, a quick note on the 11 SRY requests which we received f rom . the Boa rd on 12 Tuesday. I will have by this afternoon responses to the 13 two questions which you put to me, and I will have a 0 14 more definitive status report from Mr. Boseman for Judge Carpenter.
~
15 16 JUDGE BRENNER: Thank you.
17 All right, Ms. Letsche. We are under a bit of 18' a time pressure, as you know, today. I certainly do not 19 vant that time pressure to inhibit you from doing 20 anything you need to do that is material. On the other 21 hand, I would hope that you would try to be sensitive to 22 it.
23 Whereupon,
( 24 MARVIN W. HODGES 25 LEONARD J. CALONE l )
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() 1 HARRY T. CARTER 2 EUCENE C. ECKERT 3 HENRY C. PFEFFERLEN
{
4 JOHN A RIGERT 5 WILLI AM P. SULLIV AN 6 having previously been sworn, resumed the stand and were 7 further exaained and testified as follows:
8 CROSS EXAMINATION ON BEHALF OF SUFFOLK COUNTY -- Resumed 9 BY MS. LETSCHEa 10 0 Mr. Carter, if an operator has activated the 11 standby liquid control systea and injected the sodiua 12 pentaborate into the reactor to shut down the plant, do 13 you know how long it would take to clean up the reactor O 14 and remove all the boron aft 1r.that?
15 (Panel of witnesses conferring.)
16 A (VITNESS CARTER) It would take approxiaa tely 17 12 to 14 days.
i 18 0 Would that require a shutdown and inspection l
l 19 of the fuel and the vessel internals in addition to 20 cleaning it out?
21 (Panel of witnesses conferring.)
i 22 A (WITNESS CARTER ) I guess that may depend upon 23 the situation or the reason why you injected the boron ,
() 24 25 to begin with. I think just to clean it up I do not think an inspection would be required if all we did was
)
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() 1 inject the sodium pentaborate into the reactor.
2 0 Mr . Hodges , do you agree tha t there would not
'N 3 be any inspection of the fuel or the vessel internals (Q
4 required after the entire sack of sodium pentaborate had 5 been emptied into the raactor?
6 A (WITNESS HODGES) If there had been no reason 7 to challenge the fuel integrity limits during the 8 transient when that would hava been injected or either 9 for a spurious injection, I would see no reason to 10 inspect the fuel. Other brands of reactors operate with 11 boron in the coolant regula rly with similar materials 12 for fuel cladding and structures, and there is no 13 particular damago. And I would see no reason unless the 9 14 fuel limits had been challenged.
15 0 Er. Carter, how long would the total outage be 16 following an injection?
17 A (WITNESS CARTER ) Well, again, I think you 18 would have to take into consideration the reason that 19 you injected it to begin with. If for some reason you 20 injected it during an ATWS, I think maybe the cleanup 21 may be the small portion of the outage.
22 (Counsel for Suffolk County conferring.)
23 0 Mr. Carter, as;uming that it was a mistaken
(,r) j
/ 24 injection of the sodium pentaborate, can you give me a 25 general range or an idea of how long the outage would be?
r%
N.
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() 1 A (WITNESS CARTER) I think that would be very 2 difficult. I think it would be based on a lot of other 3 outside agencies and the time f rame that we would be
[
4 starting up with. Just for me to come up with some sort 5 of estimate myself without maybe inputs from other 6 people would be very difficult.
7 Q Can anyone else on the panel answer that 8 question, give us an estimate of the approximate length 9 of the outage assuming a mistake, mistaken injection of 10 the entire contents of the SLC tank?
11 A (WITNESS CALONE) I would say that if we 12 injected the entire tank , our estimates are 14 days to 13 clean up, and certainly the NRC would be notified.
O 14 There will be discussions with the regulators, and if 15 there were no obstacles from the regulators or any 18 additional studies tha t would have to be made, I would 17 think that once we have cleaned up the boron we would 18 return to service.
19 0 Has GE or anyone else that the panel can speak 20 for performed a study of the cost of the cleanup that 21 would be involved following a mistaken injection of 22 boron? And let me amend that not to just a cleanup but 23 the outage that would be required following such an 24 event.
25 (Panel of witnesses conferring.)
l
( ,
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() 1 A (WITNESS PFEFFERLEN) GE has not done an in 2 depth study because it is a plant-dependent thing. But
() 3 4
an inadvertent injection, if that is what you are looking at, I think it would depend upon the ability to 5 clean it up, and tha t is the impact of an inadvertent 6 injection. We have looked a it materials-wise. We do 7 not see any problems that would be residual after such 8 an injection.
9 Q Well, maybe I should ask LILCO or CE if any to other plant-specific studies have been done. I am 11 talking about the cost of doing it, the cost of doing 12 that kind of cleanup or inspection or whatever else 13 would be required.
14 A (WITNESS PFEFFERLEN) There have been a number 15 of studies of different plents that I have heard about, 16 a nd again, I think depending upon the cleanup capacity 17 of the plant, the outage time could be quite 18 significant, and I think that is again very 19 plant-dependent. So there is a whole range of cost .
20 impacts that may be quoted. We did not participate 21 directly in developing these things, but it is a very 22 plant-specific question.
23 0 Mr. Hodges, are you familiar with the
() 24 information in NUREC-0460 about thencost impact of inadvertent injection?
25 O
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() 1 A (WITNESS HODGES) Only to the extent that I 2 have read the NUREG and I am familiar with the figures.
() 3 4
I know to some extent the bases for that, that the largest numbers were based, I think, on plant outages of 5 three months for plants that had low capacity cleanup 6 systems. So with the information here today that 7 Shoreham can do it in 12 to 14 days, I think the lower 8 range of the numbers that are in there would be more 9 appropriate. I just do not remember what the numbers 10 a re .
11 (Counsel for Suffolk County conferring.)
12 Q Mr. Carter, you are involved in operator 13 training, I know. Are the operators at Shoreham aware 0 14 of the cleanup requirements or outage requirements that 15 would come up after an erroneous injection of boron?
16 A (WITNESS CARTER) Yes, they are. Obviously, 17 if you inject boron into the reactor, you have to clean l 18 it up, and they are aware of that.
l l 19 (Counsel for Suffolk County conferring.)
20 JUDGE BRENNER: Mr. Carter, is that pa rt of 21 the formal training program, to make them aware of that?
22 WITNESS CARTER: I do not know whether it is 23 part of the formal training program. I know we teach
( 24 the standby liquid control system, and they know if you 25 inject poison in you have to clean it up. I do not know O
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() I whether there is a specific sentence in there that says-2 that. I know I have in my --
I just know just from the 3 general training that they know that.
( ])
4 WITNESS HODGES: Judge Brenner, I think the 5 biggest problem is there is a tech spec limit on the 6 conductivity of the reactor water, and in order to be 7 able to s+tisfy that tech spec limit, you would have to 8 remove essentially all of the boron.
9 WITNESS CALONE: If I may add, the operators 10 do understand that injecting sodium pentaborate into the 11 reactor would result in an outage to clean it up. They 12 also understand that if the procedural step indicates to 13 them that they are to inject sodium pentaborate, they 14 are to do that. Not to do that would be a violation of 15 procedure.
16 We do have other procedures that deal with the 17 standby liquid control that basically tell the operator 18 if you have reached a point of injecting sodium 19 pentaborate, then inject it and do not wait. So it 13 20 clear in some of our procedures, although not 21 specifically laid out in the 024 procedure, tha t th e 22 operator is to inject it when he gets to the point of 23 injection and not worry about it. There are no
( 24 precaution statements that say really be sure you want 25 to inject this stuff.
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() 1 JUDGE BRENNERa Okay. Now you are coming 2 close to what I have in mind. Is there any discussion 3 in the training program as to what the operator should
{
4 do if in doubt as to <.hether the operator is in a 5 situation where it should be injected or not injected ?
6 WITNESS CALONE: The operator is taugh t to 7 keep the plant in a safe condition, and if there is any 8 doubt as to safety, he would inject it. You always get 9 to the gray area. That is why in most of our 10 procedures, including the emergency procedure where it 11 says 6 percent power or the suppression pool at 110 12 degrees you inject sodium pentaborate, there is no 13 debate about it.
O 14 JUDGE BRENNER: Are there any sort of 15 assurances given during the training program to the 16 operators that if they are in doubt, to go ahead and de 17 it, in those types of terms?
18 I understand that if the requirements of the 19 procedure obtain -- and let me come back to the 6 20 percent requirement at the end -- they are to do it, and 21 I understand your testimony that clearly they are 22 trained to do that and obey the procedure. But I am 23 trying to hypothesize the situation where the operator N
/ 24 is in some doubt as to whether the reactor is in that 25 situation.
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() 1 (Panel of witnesses conferring.)
2 WITNESS CARTER: When I ta ugh t the procedure, 3 I told them that they had to inject when they met those
{
4 conditions, and there was no qualifica tion statement on 5 that. They were told to inject.
6 WITNESS PFEFFERLENs I think it is important 7 to recognize that we have talked yesterday and 8 previously about various spectrums of ATWS's, and I 9 think there is no question in anyone's mind here on the 10 panel that if it were a major ATWS, there would be no 11 question in the operator's mind that he has to take some 12 action.
13 When you get to the borderline in the gray O 14 areas that I have heard mentioned, I think this is a 15 very minor ATWS which really and truly the operator 16 would have time; so we have to separate the two ends of 17 tha t spectrum, I think, in the thinking here.
18 WITNESS CALONE: In addition to that, 19 previously I guess there always was sort of a gray area 20 as far as injection goes. There was no clear, defined 21 point at which you inject it. There used to be words 22 like so many rods out, and we talked about that. The 23 number of rods out do not really mean anything. The s
24 question is are you critical and wha t power level.
25 The emergency procedure guidelines as ther O
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() 1 exist or our procedure bs 31cally gives the operator 2 clearcut, definiti - indication as to what point he must 3 inject standby liquid control, and I think prior to the (V')
4 emergency procedures that guideline was not in 5 existence. I think there may have been some doubt prior 6 to that, but I believe that under the current procedure 7 and the guidelines there is no doubt that they will 8 inject it if one of those three conditions arises.
9 JUDGE BRENNERt All right. Let me tell you 10 wha t is on my mind but not follow it up now. I am 11 concerned that there is some ambiguity with respect to 12 that 6 percent parameter, because I think that condition 13 6 percent of neutron flux parameter, because I think 9 14 that condition, unlike the temperature rising, always 15 exists, and it is a matter -- or very of ten exists as 16 the event starts and as you go in, even before the 17 t ra nsien t , through the transient and so ons and 18 therefore, there is some implicit judgment as to when to 19 pay attention to that parameter as distinguished from 20 stating as soon as it exists. Because if you follow 21 tha t literally, the operator would always go right to 22 standby liquid control without even trying the manual 23 scram, which I do not think is intended, and in fact, if
/~'
I understand Mr. Hodges' testimony correctly, is not (a<-) 24 25 desired.
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(_ 1 I do not want to pursue it now. The reason I 2 mention it is when we put it all together, it might 3 relate to this araa of justifiable doubt, as Mr.
(
4 Pfefferlen pointed out, as to when other steps should 5 indeed be taken first, and the area of if you have got 6 doubt at this point in the transient, the standby liquid 7 control should have been injected. And so there is the 8 combination of in the training as to what the operator 9 should do without fear of his job or whatever, and also to the area of if there is ambiguity in the procedure, we 11 should take a look at whether it is appropriate to have 12 that ambiguity or not. And so it may get covered, and 13 otherwise perhaps somebody more expert than me will 14 follow up with you on it.
15 Maybe I am misunderstanding the total of 6 16 percent, but in any event we will clear it up one way or 17 the other by the end of this with you.
18 BY MS. LETSCHE: (Resuming) 19 0 Mr. Hodges, a minute ago Mr. Pfefferlen stated 20 a conclusion that he felt the entire panel would agree 21 with about there being no doubt as the operator making 22 the decision to use the standby liquid control system.
23 Are you in agreement with all of the conclusions he (G/j 24 stated in that answer?
25 A (WITNESS HODGES) I think generally I agree n
\s/
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l i
() 1 with him, and one reason I agree with him is that the 2 philosophy that went into the emergency procedures 3 guideline, which has been the basis for the Shoreham
( )
4 procedures, is that the operator has guidance. He has 5 the procedures to iollow, and if he deviates f rom those 6 procedures, he is in trouble with the company and with 7 the NRC. And so if he has got the procedures to follow, 8 generally he will follow those procedures. The problem 9 comes when there is no procedure to follow, and he is 10 having to " wing it," as occurred at Three Mile Island.
11 So the ides here was to cover a wide variety of 12 situations with the guideline and the procedures to get 13 into all sorts of degraded conditions and to try, to the 14 extent that we can, to visualize ahead of time the 15 things that will be happening, and therefore provide 16 guidance to the operator so that he has procedures to 17 follow even in very unusual situations.
18 And now for this ATWS situation you do have 19 guidance. I may tend to go along with Judge Brenner a 20 little bit about the 6 percent power, but I think that 21 the 110 degree temperature limit is very clear, and I 22 think it is a very clear basis that the operator when he 23 gets to th a t point will take that action. So I do not
( 24 have much doubt that he would take that action when he 25 gets to tha t limit.
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1 (Counsel for Suffolk Counti conferring.)
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( ,) 1 Q Mr. Pfefferlen, is there any concern about the 2 possibility of a chemical reaction or corrosive effects f; 3 from the sodium penoborate acting on any ma terials with V
4 the primary pressure boundary?
5 A (WITNESS PFEFFERLEN) I am not aware of any 6 concern in that area.
7 0 Has that been investigated?
8 A (WITNESS PFEFFERLEN) Yes, it has.
9 0 What is the basis for the concern that Mr.
10 Hodges mentioned earlier about the conductivity of water?
11 A (WITNESS PFEFFERLEN) When you operate a 12 reactor you want to operate it with clean water, and e 13 14 that is the measure of the conductivity.
why you would have to clean up to get the water cleaned, And that is 15 so that you wouldn't continue long-term operation with 16 impure water from whatever source. I think that is the 17 only basis. Maybe someone from LILCO can expand on the 18 water treatment and what have you.
19 (Panel of witnesses conferring.)
20 I really am not too knowledgeable in this 21 area. All I can say is that I know it has been looked l
22 at and there has been no indication of concern in this I I
23 a rea .
(/~3
,/ 24 A (WITNESS HODGES) I suspect part of it would
)
25 relate to the fact that if you have many impurities (v~)
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() 1 because you do have a boiling boundary, you would tend 2 to get a crud buildup at tha t boiling boundary. That
) 3 would relate to part of it. And it may also relate to (v~N 4 the f act that if you had fuel that tended to leak a 5 little bit, that might be a means of picking tha t up, 6 also.
7 But the point is that there is definitely a 6 tech spec limit, and it is a very low limit on the 9 conductivity. And they are not supposed to operate 10 their plant above that limit, so you would have to clean 11 up the system to the point where it satisfies that limit.
12 JUDGE BRENNER4 Ms. Letsche, you are getting 13 rather far afield now, and I want you to know that. It 9 14 is pertinent to establish t'n a t the reactor might be in 15 an outage. It is pertinent to establish what the 16 operator is told in advance about that possibility. But 17 it is not pertinen t to see if there are things that have 18 not been thought about, because if they have not been 19 thought about, then it is no longer pertinent to whether 20 the operator is considering those problems.
21 (Counsel for Suffolk County conferring.)
22 JUDGE MORRIS 4 Mr. Ca3nne, during this pause, 23 is it your understanding that the principal ingredient rm b)
I 24 in the cost of the outage is the cost of replacing fuel?
25 WITNESS CALONEs Replacement fuel?
o
(
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9164 O aea1 ce eat va er' 2 JUDGE MORRISs Yes.
3 WITNESS CALONE: Yes, that would be the 4 largest cost that would be involved with any outage, I 5 would think.
6 JUDGE MORRISs Thank you.
7 BY MS. LETSCHE (Resuming):
8 Q Gentlemen, I would like to move to a 9 discussion of the procedure 29.024.01, a copy of which 10 is attached to your pre-filed testimony. And followino 11 up on Judge Brenner's suggestion , I would like for us to 12 conduct this discussion of the procedure assuming a 13 particular ATWS event, an ATWS transient, which would 14 include -- basically, it is going to be the one that Mr. -
15 Hodges was discussing yesterday.
16 Assume for me that you are operating the 17 reactor, it is operating at full power, and that there 18 is a total failure to scram the reactor; that the fTWS 19 involves an MSIV closure. Assume the operation of the 20 recire pump trip, but assume that there is no operation 21 of ARI.
22 I would also like you to assume that you are o
23 beginning with a 90 F suppression pool temperature, 24 and a vessel pressure in the normal operating range.
25 And we will assume, as I think somebody stated a
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() 1 yesterday, that there are two operators in the control 2 room.
N 3 The first thing I would like for us to all be s
(V 4 on the same wavelength on before we gc through the 5 procedure is exactly what would be happening over the 6 course of time with respect to the four parameters that 7 we understand the reactor operator is going to be 8 looking at, and that would be reactor power, reactor 9 pressure, water level above the top of the active fuel, 10 and the suppression pool temperature.
11 And I want to get from the panel their 12 estimates of, and rough estimates -- and I am not 13 talking about precise numbers, but rough estimates -- o f
\# 14 wha t those parameters would be at various time points 15 during the course of this transient we have postulated.
16 MS. LETSCHE: Judge Brenner, in order to do 17 this in the most ef ficient way, I have a proposal. In l 18 order to get tnis information, -- and I believe Mr.
19 Hodges was talking about some of it yesterday, and that 20 the gentlemen on the panel probably are able to come up 21 with these kinds of estimates I am talking about -- I 22 have prepared a little chart that has the time periods 23 between zero time when the event begins and 10 minutes
() 24 25 after the beginning of the transient, with divisions for 1 minute, 2 minutes, 3 minutes, 4 minutes, 5 minutes and
(
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() 1 then the 10-minute period.
2 And I think it might be helpful if the panel 3 could take a couple of minutes to co n sult and basically,
{
4 fill in the approximate values for each of these 5 parameters at each of those time periods. And I would 6 like to show the Board what we have prepared and show it 7 to counsel and the witnesses and see if that would. be 8 the most efficient way to proceed.
9 JUDGE BRENNERs Why don't you just show it to 10 all of us?
11 MR. REVELEY: I think, Judge, the panel is 12 being asked to do a f airly sophisticated bit of work
_ 13 very quickly, and they should feel absolutely free to 14 say that one cannot do it under these time constraints.
15 JUDGE BRENNERs That is correct.
16 Ms. Letsche, do you have a fourth copy?
17 MS. LETSCHEs I can get it right away.
18 JUDGE BRENNER4 That is okay, we will share it.
19 ( Discussion off the record.)
20 MS. LETSCHEs Judge Brenner, let me emphasize 21 that I am not looking for precise numbers at all.
22 JUDGE BRENNERa Wait a minute. Let me ask the 23 witnesses to wait, also. It would have been better to
() 24 25 do this before we started, although I recognize we started early this morning.
( -
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\m)% 1 MS. LETSCHEs Yes, Judge Brenner, we had a few 2 time constraints.
3 JUDGE BRENNER: I hesitate to take a break
(}
4 now, but since it migh t result in saving time later, why 5 don't we break until 9:30 and in addition to the 6 witnesses looking at it and , therefore, being able to 7 talk wi th their own respective counsel, counsel might 8 vant to talk with each other and make sure and see.if 9 you can agree on a way to get the information in the 10 most efficient way, if it can, in fact, be gotten in 11 this kind of timeframe.
12 JUDGE MORRISs Ms. Letsche, are you asking for 13 numbers for these time intervals, or would you be 14 satisfied with a rough plot?
15 MS. LETSCHE: I would be satisfied with a 16 rough plot, Judge Morris, just to get an idea of where 17 we are in each one of these parameters at each one of 18 the time points. Maybe just an X on the little chart.
19 WITNESS HODGES: Are you asking this only of 20 the LILCO panel or the total panel, which --
21 JUDGE BRENNERs At some point or another, Mr.
22 Hodges, I am sure somebody will ask you wha t you think, 23 so you will be involved in at least looking at what l 24 LILCO has done. And to tha t extent, I imagine to do 25 that correctly you have to see if you can do it O
(V ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., NASHINGTON. D.C. 20024 (202) 554 2345
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() 1 yourself, also.
2 MS . LETSCHE 4 Before we take the break, Judge
() 3 4
Brenner, to assist the panel, let me make one more point about the assumptions we are making on this transient.
5 That is, when we go through the procedure, and in 6 connection with filling out these little plots, we are 7 assuming that you are going to go through the procedure, 8 29.0204.01 to the point of injecting standby liquid 9 control.
10 JUDGE BRENNER: Why don't we handle all other 11 questions off the record, and if when you come back 12 there are changes in the groundrules, we can hear about 13 it. So maybe I should make it 9:35 so you can have a 0 14 chance to talk.
15 WITNESS CALONE: If I may, just a question.
16 We have been given assumptions. If we need additional 17 assumptions, can we make them ourselves?
18 JUDGE BRENNER: I want you to work out 19 everything off the record and then come back --
20 including the very important area of what assumptions 21 are being made. -
22 (A short recess was taken.)
23
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9169
() 1 JUDGE BRENNER: Let's go back on the record.
2 MS. LETSCHE: Let me just ask this of Mr.
3 Hodges.
( It is not related to what we were talkino about.
4 BY MS. LETSCHE (Resuming):
5 0 We were talking yesterday about reducing the 6 time necessary for the standby liquid control system to 7 be effective in connection with the flow rate of that 8 system. Would it be possible to change the size of the 9 pump without changing the size of the piping, and in 10 that way, increase the flow rate and thus increase or 11 reduce the time necessary for the SLC to be effective?
12 NR. REVELEYs I do not want to be 13 uncharitable, since this is an opportunity to fill the O 14 gap, but that question is beyond the scope of this 15 con te ntion , in our judgment.
16 JUDGE BRENNER: It will only become important 17 if it materially affects the time involved in terms of 18 acting, and if it is not going to do that -- in order 19 words, I would rather ask that question first.
i j 20 MS. LETSCHEs I will be glad to do that, if 21 you want to, Judge Brenner.
22 JUDGE BRENNER: Well, it could be relevant 23 later and it doesn 't sound like it is going to be a very
( 24 long line, so 1 vill allow the question on that basis.
25 It could, however, remain irrelevant if it is not
)
l l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9170
() 1 ultimately tied up.
2 WITNESS HODGES: I am not that familiar with
() 3 4
what kind of space limitations they may have, where the pumps a re. But with that caveat, I would think it would 5 be possible, maybe not practical -- I don't know about 6 practicality --
but possible, probably.
7 BY MS. LETSCHE (Resuming):
8 Q Mr. Hodges, if you make -- by changing the 9 pump size, if you make the system effective more 10 rapidly, would that reduce, or rather, would that 11 increase the amount of time that the operator would have 12 to make the decision to turn the system on?
13 A (WITNESS HODGES) Well, the way you stated the O 14 question I am not sure I know how to answer it, but let -
15 me answer the question I think you tried to ask.
16 If you have the higher flow rate system, then 17 basically, you are working against the same time, the 18 suppression pool temperature limits, and therefore, the l 19 operator would have more time to acts more time before 20 he had to turn on the standby liquid control system.
21 0 That answered the question I intended to ask.
22 Thank you.
23 JUDGE BRENNER: Let's'go off the record.
l
() 24 25 (Discussion off the record.)
JUDGE BRENNER Back on the record. Let's l ()
l ALDERSoN REPORTING COMPANY,INC, t
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
9171
( 1 proceed.
2 BY MS. LETSCHE (Resuming):
f3 v
3 0 Gentlemen, I have been handed a copy of these 4 filled-in tables. Let me just, for the record, have 5 this document marked as Suffolk County Exhibit No. 40.
6 JUDGE BRENNER: No, that is 39.
7 MS. LETSCHE: This will be Suffolk County 39 8 for identification.
9 (The document referred to 10 was marked Suffolk County 11 Exhibit No. 39 for 12 identification.)
13 BY MS. LETSCHE (Resuming):
14 0 I guess just for the record, this is something 15 that the panel agrees on in terms of the movement of 16 each of these parameters on this graph reactor power, 17 reactor pressure, water level and suppression pool 18 temperature over the time period of time zero to 10 19 minutes after the beginning of the transient, yhich I 20 postulated when we began this discussion. Is that 21 correct?
22 A (WITNESS CALONE) Well, within the timeframe 23 given and the quick mental calculations to be made, I l 24 would say that we agreed, yes, this is a general trend.
25 A (WITNESS HODGES) I think a lot of emphasis has O.
v ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9172
() 1 to be put on general trends as opposed to exact numbers 2 in this case. These are estimates without referring to f'N V
3 calculations, without going back and referring to 4 figures in reports. And so, these are best judgments.
5 0 Yes. I think we all understand that. These 6 are not figures that anyone is going to be bound to; 7 they are approximate values based upon the panel's 8 collective judgment.
9 A (WITNESS C ALONE) In addition, I would like to 10 state that while we consider an ATWS highly improbable, 11 the scenario you have proposed is at the extreme low end 12 of the probability scan that an ATWS would even be in.
13 0 Okay, gentlemen. Now, we will work with the 9 14 assumptions or the conditions on Suf folk County Exhibit 15 39 to tell us generally what will be happening in the 16 plant during the occurrence of this transient. And I 17 would now like to go to procedure 29.024.01 that was 18 attached to your testimony and discuss what the operator 19 would be doing.
20 JUDGE BRENNER: Ms. Letsche, I suggest that we 21 might as well admit this into evidence; certainly, at 22 least bind it in now, and I suggest perhaps admit it in, 23 although we can defer that if anybody wants to defer it.
( 24 MR. REVELEY: We have no objection to 25 admitting it, Judge.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9173 O i nS. terscuE5 thet is fine, audoe arenner.
l 2 JUDGE BRENNEB4 All right, it is admitted into l
3 evidence as Suffolk County Exhibit 39 and bound into the l l 4 transcript at this point.
5 (The document previously 6 marked Suffolk County 7 Exhibit No. 39 for l
8 identification was 9 received in evidence.)
i 10 (Suffolk County Exhibit 39 followst) 11 12 13 f
O 14 15 16 17 18 19 20 21 22 23 24 25 O
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9174
() 1 BY MS. LETSCHE (Resuming):
2 Q Mr. Calone, just to orient on these ,
l 3 procedures, starting with the symptoms section, 1.1,
(
4 these are symptoms that the operator is supposed to be l 5 aware ofs first of all, that there is a valid scram l 6 s ys tem , a valid scram signal or condition due to a 7 reactor transient and all control rods do not fully 8 insert, as indicated on the full core display. Is that 9 display on the 603 panel?
10 A (WITNESS CALONE) Yes, it is. But before we 11 get into the procedure, I think we ought to give you our 12 assumptions on the scenario.
gs 13 JUDGE BRENNER: Yes. I was going to suggest V 14 that myself. Go ahead.
15 WITNESS CALONE We made the following 16 additional assumptions. We assumed the manual scram 17 did not work. We assumed that subsequent attempts to 18 scram any rod did not move any rod, and that all the 19 rods stayed in the position they were at 100 percent 20 power.
21 We assumed that the service water temperature o
22 was 75 F, or on the high end of our annual variation o o 23 which is between 28 F and 75 F. So we used the
( 24 higher end of the service water.
25 We assumed that the feedwater would coast down ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9175 1 and cut off in 20 seconds. We assumed that in about 2 2 minutes the operator took control of the re actor ,
3 pressure via the relief valves, and we assumed that the 4 suppression pool cooling was placed into service.
i 5 (Panel of witnesses conferring.) k-6 In addition, at level 2 we assumed that HPCI 7 and BCIC auto-started.
8 (Counsel for Suffolk County conferring.)
i 9 l
10 y 11 12 13 14 15 i
16 17 i
18 19 20 21 22 23
'~
24 25 O
ALDERSON REPORTING COMPANY,INC, i
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
s s
9176
() 1 EY MS. LETSCHE: (Resuming) 2 0 Just so that I can make sure the record is p}
q 3 clear, Mr. Hodges, are any of there assumptions that Mr.
4 Calone just mentioned dif f eren t from any of those that c 5 you used in your testimo.1y yesterday?
6 A (WITNESS HODGES} They are consistent with the 7 scenario we described yesterday.
8 JUDGE BRENNER: Are you talking about the 9 description you gave me yesterday, Mr. Hodges?
10 WITNESS HODGES: Yes, sir.
11 JUDGE BRENNER: We assumed a failure of HPCI 12 and RCIC yesterday, or lack of opera tion , I thought .
13 WITNESS HODGES: We failed RHR, and I didn't OP 14 discuss the service water temperature, but that would 15 have been at its maximum.
16 JUDGE BRENNER: All right. Thank you.
17 WITNESS H0DGES: I'm sorry. That is one 18 difference from what we discussed yesterday. I think 19 they are assuming that out in time here you get first 20 one and then the second RHR system on. Initially in the 21 transient neither is on. So thelo is that difference in s 22 the transient that they have gone te vere from what I 23 assumed yesterday.
BY MS. LETSCHE: (Resuming) l 24
[ 25 0 okay, Mr. Calone, I'm going back to the x ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9177 O)
(- 1 procedure now. The full core display mentioned at 1.1 2 is on the 603 panels is that correct?
() 3 4
A (WITNESS CALONE) That is correct.
Next it talks about a rod position printout on 0
5 the computer. Where is that information available in 6 the control room?
7 A (WITNESS CALONE) In close proximity to the 8 reactor operator's desk.
9 Q Where is it in relation to the 603 panel?
10 A (WITNESS CALONE) Three or four feet to the 11 left of the panel.
12 Q It then mentions the f our-rod display. Is
-^s 13 there just -- well, where is that located? Where is (d
14 that display ?
15 A (WITNESS CALONE) On the 603 panel.
16 0 Is it anticipated in this item of the 17 procedure that the operator is going to look at just one 18 display?
19 A (WITNESS CALONE) No, he will not. .
20 0 How many will he look at? And I'm talking 21 about the number of displays. Each display is of four 22 rods, four-rod groups, right?
23 A (WITNESS CALONE) If you're talking about the
- 24 last statement, four-rod display, it is uncertain as to 25 how many he would look at. The f astest method of ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9178 obtaining information is the full-core display and the
(]) 1 2 rod position printout. Tha t gives him the full core f'\ 3 versus the four-rod display, which Only gives him four 4 of the 137 control rods.
5 0 Moving down to part 1.2 of the procedure, 6 another symptom here. First it talks about reactor 7 pressure increasing abruptly. Where is that indicated 8 for the operator?
9 A (WITNESS CALONE) It is on the 603 panel, and 10 it is also annunciated and associated with high reactor 11 pressure.
12 (Panel of witnesses conferring.)
13 0 At what pressure does the annunciator go off?
14 A (WITNESS CALONE) The actual. pressure has not 15 been deter?.ined because of the test program to set those 16 limits. It is on the order of 1,030 or 1,025. The 17 scram point is 1043. That is set.
18 (Counsel for Suffolk County conferring.)
- 19 Q Looking at Suffolk County Exhibit 39 for 20 reactor pressure, is this assuming that basically that 21 at time zero you're going to have that annunciator lit?
22 A (WITNESS CALONE) At the beginning, before the l
23 transient, we are at normal operating pressure, which is
() 24 slightly over 1,000 pounds.
transient will begin.
That is where I assume the 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9179
(} 1 A (WITNESS ECKERT) Let me add, that peak shown 2 there at 1300 th a t we talked about before, that is at
/"\ 3 approximately ten seconds. So the annunciator would 4 take place on the way up toward that, in the four or 5 five-second point.
6 Q Mr. Calone, going back to section 1.2, it 7 talks about the neutron flux indication increasing 8 abruptly. Where is that indicated for the operator?
9 A (WITNESS CALONE) It is located on the 603 10 panel.
11 Q Is that the APRM's?
12 A (WITNESS CALONE) That is correct.
13 0 And is that condition represented by that peak
) 14 in the last graph on Suffolk County Exhibit 39 righ t 15 around time zero?
16 (Panel of witnesses conf erring. )
17 A (WITNESS CARTER) Yes, that is represented by 18 that peak.
19 I would like to say, a t this poin t in time you 20 would have valid scram signals both off power and 21 pressure, with no rod movement.
22 Q Continuing in section 1.2, it states that, 23 "Either reactor pressure or the neutron flux indication
() 24 25 will increase abruptly and may go off scale."
it -- what is the difference that will happen to make an What is ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 23 AS
9180 1 opera tor determine that those indications have gone off 2 scale?
(q 3 A (WITNESS CA10NE) The indicator will be up
\
4 against its high level stop. In other words, at the top 5 of the scale. And by the way, there are six indications 6 of APRM's and they should all be up there if that is 7 what the problem is. If it was a single line, it could 8 gc a channel f ailure and not an ATWS.
9 (Counsel for Suffolk County conferring.)
to O What is the maximum reading that would be on 11 scal.e for the APRM's, and how far does the off-scale 12 reading go?
13 A (WITNESS CALONE) The range on the APPM is
% 14 zero to 125.
15 (Counsel for Suffolk County conferring.)
16 A (WITNESS CALONE) If you are talking th e peak ,
17 the chart in your exhibit ind'i cates the power will go to 18 150. That would be off scale.
. 19 A (WITNESS ECKERT) Can I add that I have 20 labeled that peak thermal power, and that is what the 21 heat flux kind of parameter would be on the f uel? The 22 actual neutron flux spike is taller than that, and would 23 clearly be pegged at their high scale. It may be up in 24 the 300 or 400 percent range for that short period at 25 the peak.
O ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
9181 1 Q Af ter they mention the off-scale, it talks O 2 about being on recorders and meters. Are these 3 recorders and meters referencing just the APRM's, or is W 4 there other equipment being referred to there?
5 A (WITNESS CALONE) APRM's are indicators and 6 recorders, so they are meters and recorders. The 7 pressure also has a recorder and an indicator.
8 0 And these are all located on the 603 panel?
9 A (WITNESS CALONE) That is correct.
10 0 The next item, 1.3, says, "The safety valves 11 may lift." What is it that the operator has to look at 12 to find that out?
13 A (WITNESS CALONE)' He gets an annunciator 14 indicating that he has -- that safety valves have 15 lifted. He also gets indicating lights on the 602 16 panel, where the saf ety valve position switches are 17 located, indicating that the valves have been called to I
l 18 open.
l 19 (Counsel for Suffolk County conferring.)
20 0 How far away is the 602 panel from the 603 21 panel?
22 A (WITNESS CALONE) Well, they are adjacent.
23 They abut against each other. Distance-wise to the 24 indicators is probably six feet, but they are visible 25 from the 603 panel. You don't have to walk over there pJ ALDERSON REPORTING COMPANY, WC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
l 9182 1 to see them.
2 (Counsel for Suffolk County conferring.)
s 3 0 Okay, Mr. Ca lone , I think -- well, let me ask
\ 4 youa How long is it going to take for the operator to 5 identify the existence of the symptoms listed in this 6 procedure?
7 A (WITNESS CALONE) As I mentioned previously, I 8 believe it was yesterday, in my experience at the 9 simulator and having witnessed other operators perform 10 the different ATWS scenarios, it is my opinion that an 11 ATWS is recognizable within seconds of the occurrence.
12 JUDGE BRENNER: Mr. Hodges, do you have an 13 opinion on tha t also.
f\
s ,) 14 WITNESS HODGES: I would tend to agree. I 15 don't have a lot of experience in the control room, but 16 what little simulator experience I have had and what I 17 know about how f ast these parameters will go through 18 their trip limits, I would expect within seconds he 19 would recognize that he had an ATWS.
20 BY MS. LETSCHE (Resuming) 21 0 I should say, Mr. Hodges, if at any point you 22 have anything to add on any of these questions, I am 23 sort of addressing them to Mr. Calone, but feel free to 24 jump in.
g 25 A (WITNESS HODGES) Generally, if I have a O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 1
9183 i
1 disagreement I would bring that up. Otherwise I am 2 going to try to keep quiet.
y 3 JUDGE BRENNER: We were going to ask Mr.
\/ 4 Hodges that question anyway, because we remembered Mr.
5 Calone's testimony on that point yesterday, and since it 6 came up again we jumped in.
7 BY MS. LETSCHE: (Resuming) 8 Q Mr. Calone, assuming that the operator is 9 going to recognize the existence of an ATWS within 10 seconds, when does he go and get this procedure?
11 A (WITNESS CALONE) The operator should be able 12 to perform the immediate actions without the procedure.
13 He vill get the emergency procedure, this procedure, as hN x ,/ 14 soon as he has a chance to. But the immediate actions 15 he will handle immediately. Subsequent actions, he vill 16 have the procedure in front of him, the first step of 17 which is to verify that all immediate operator actions 18 have ta ken place.
19 Q So are you saying that the operator, who is 20 going to be performing all of the steps in section 3 of 21 this procedure, is not going to have the piece of paper 22 in front of him until he has finished all of the steps 23 in section 37 g
24 (Panel of witnesses conferring.)
25 A (WITNESS CALONE) As we previously mentioned, O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9184 1 immediate operator actions are to be memorized by the 2 operator. We just had -- our presen t opera tors in 3 training just took their NPC SRO exam yesterday or 4 Tuesday. In that exam they were asked immediate 5 actions, and as a matter of fact one r,f the questions I 6 believe was on the ATWS procedure. So they did not have 7 the procedure in front of them at that time.
8 Q I guess my question is, aren't the operators 9 trained to go and get the appropriate procedure, or are 10 they trained to just go ahead and do it and get it 11 af terwa rds?
12 A (WITNESS CALONE) It depends upon the time 13 frame. If you are in an immediate -- if you have to k 14 perform an immediate operator action, you have to 15 perform immediate operator action. You don 't wait for 16 the procedure. We expect the operator to have the 17 procedure memorized to the point of subsequent action, 18 at which time the first point of the subsequent action i 19 is to verify that he performed all of the immedia te 20 actions.
21 (Counsel foc Suffolk County conferring.)
l' 22 A (WITNESS CA..ONE) Let me add another point i
23 again. Back to the simulator. We do this procedure 24 without a procedure in hand until we have got the system llgg l 25 stabilized and the subsequent actions are in eff ect.
I b
U ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345 I
l_______-_______________
9185 1
0 Moving on to section 2, the automatic actions O 2 there. There are two listed at this point in the 3 procedure. Proceeding along, the operator isn't W 4 supposed to take any actions with respect to either of 5 those two items, is he?
6 A (WITNESS CALONE) They are an indication to 7 him as to what should have happened automatically. The 8 operator is always instructed to take the automatic 9 action if it did not occur.
10 0 So one of the things the operator would have 11 memorized and knows he is supposed to do is to go and 12 make sure that the safety relief valves have been 13 actuated and make sure that the recire pump has been h 14 tripped?
15 A (WITNESS CALONE) That is correct.
l 16 0 And does he verify that the SRV's have been 17 actuated?
18 A (WITNESS CALONE) He has indicating lights on 19 the 602 panel, as I previously mentioned. He also has a 20 pressure recorder on the 603 panel that would probably 21 indicate an increase in pressure rise and then a 22 termination of the pressure rise, indicating that the j 23 safety valves have lifted. So he has two indications
/- 24 tha t they are in the lif t condition.
\ ~w) 25 In addition to that, we do have, I believe it O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9186 1 is, pressure sensors on our tailpipes on the safety O 2 relief valves, which would also annunciate, telling him 3 the safety relief valve had lifted.
W 4 0 And how does he go about verifying that the 5 recirc pump has tripped?
6 (Panel of witnesses conferring.)
7 A (WITNESS CALONE) The controls for the recirc 8 pump are on the 602 panel directly adjacent to the 603 9 panel. He has indicating lights for the status of the 10 recirc pump that are readily available to him and easily 11 seen.
12 I believe there is an annunciator associated 13 with the recire pump trip, and maybe someone else can
/%
(y_) 14 confirm that. I know we have an annunciator for it.
15 I'm not sure it is on the automatic system, though.
l 16 (Panel of witnesses conferring.)
l 17 A (WITNESS CALONE) I've been told that we will l
18 get an annunciator saying the recire pumps have 19 t ri pped .
20 0 Well, assuming it takes the operator a matter 21 of seconds to identify that he is in an ATWS situation, 22 how much time is it going to take him to verif y the fact 23 that these two automatic actions have taken place, the 24 two that are referenced in section 2 of the procedure?
25 A (WITNESS CALONE) Verifica tion is rapid. He l ()
l ALDERSON REPORTING COMPANY,INC, j 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
9187 1 doesn't have to go anywhere to find out. It is a
)
J 2 scanning process. Again, probably within five seconds.
3 0 So generally he is going to get up to the 4 immediate operator actions that he has memorized, that 5 he has to take within about 15 seconds from time zero, 6 is that right?
7 A (WITNESS CALONE) I would say 15 seconds is 8 probably on the long side. I would say more somewhere 9 between seven and ten seconds.
10 A (WITNESS HODGES) Maybe I misunderstood your 11 question. He has memorized immediate actions, and those 12 really go beyond 15 seconds, which include things like 13 starting up the RHR pumps and such. But the actions we O)
N, 14 have been talking about up to this point are I think on 1 15 the first 15 seconds.
16 0 I think that is what I intended by my 17 question, Mr. Hodges. I think we are on the same 18 wavelength here.
19 Okay, we are now at the point where the l 20 operator is going to start worrying about the immediate 21 operator actions on this procedure. The first thing it 22 says here is to manually scram the reactor per SP 1 23 29.010.01, emergency shutdown. Is this a procedure that 24 the operator is going to have to go and get?
25 A (WITNESS C ALONE) No, that is a standard O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
I 9188 l l
g 1 emergency shutdown procedure which, again, is memorized V 2 in immediato actions. But those three subsequent steps 3 are the basic steps of SP 29.010.01, which is basically W 4 to manually scram, push buttons, place the mode switch 5 in shutdown, and verify all rods are inserted.
6 MS. LETSCHE: Just to help the record, I would 7 like to have marked as Suffolk County Exhibit No. 40 for 8 identification the first page of the emergency shutdown 9 procedure that is referenced here, SP No. 29.010.01.
10 The copy I'm marking is Revision 3, effective date Hay 11 14, 1982, and I am only marking the first page of that 12 exhibit.
13 JUDGE BRENNER: I guess I lost that one if you O
14 gave us a copy of that one.
15 MS. LETSCHE: No, I had not provided you with 16 a copy, so you didn't lose it, Judge Brenner.
17 I will give the witness a copy of the entire 18 procedure so that he has that for his reference.
19 JUDGE BRENNERs Is there a reason why we are 20 marking just the first page? Can you tell me what 21 you're going to do with it?
22 MS. LETSCHE: I think Mr. Calone is going to 23 tell us that only the stuff on the first page is needed 24 here.
25 JUDGE BRENNER: All right, it is so marked for O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9189 1 identification as Suffolk County Exhibit No. 40.
( 2 (The document referred to 3 was marked Suffolk County W 4 Exhibit No. 40 for 5 identification.)
6 BY MS. LETSCHE (Resuming) 7 0 Mr. Calone, do you have a copy of what's been 8 marked as Suffolk County Exhibit No. 40 before you?
9 A (WITNESS CALONE) Yes, I do.
10 0 And do you have a copy of the entire procedure 11 also?
12 A (WITNESS CALONE) Yes, that's correct.
13 0 The reference in the ATWS emergency procedure h 14 to the emergency shutdown procedure, does that require 15 the operator to perform any of the actions other than 16 those on the first page of the emergency shutdown 17 procedure?
18 MR. REVELEY: Judge, I object. Why are we 19 talking about it? Doesn't it assume that the reactor is 20 scramming?
21 JUDGE BRENNERs I'm sorry, I didn 't hear that, 22 Mr. Reveley.
23 MR. REVELEY: That seems to assume the reactor 24 is scramming. 3.2 begins, "If the reactor scrams and g
25 all rods insert and power is decaying, then continue in O
V j ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9190 1 SP 29.010.01."
2 MS. LETSCHEa Judge, I'm talking about step 3 3.1.
4 JUDGE BRENNER That is what I th ought.
5 MR. REVELEYs Excuse me.
6 WITNESS CALONE: Yes, at the poin t of the 7 manual scram the operator does utilize the immediate 8 actions of SP 29.010.01, which is basically, as I 9 indicated, outlined on the bottom there. If you stayed 10 in 29.010.01, you get to step 3.3, which says you go to 11 procedure 29.024.01 if all rods do not insert. And that 12 is why you would be here.
13 BY MS. LETSCHE4 (Resuming)
I 14 0 Where are the manual scram push buttons?
15 Well, first of all, is there more than one push button 16 that must be activated?
17 A (WITNESS CALONE) Yes, there are dual push 18 buttons.
19 0 And where are they located ?
20 A (WITNESS CALONE) On the 603 panel.
21 Q Is the arming and depressing of that button 22 one action or are there two separate things that have to 23 be done?
g 24 A (WITNESS CALONE) Arming requires twisting a 25 collar around the button and then depressing the button ,
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON, D C. 20124 (202) 554-2345
I 9191 1 two separate functions on one switch, two separate 2 f unctions on each switch. So it is a twist and push.
3 0 You do that with both hands at the same time?
4 A (WITNESS CALONE) It is operator technique. I 5 always use two hands. Twist and push.
6 0 The next step is to place the mode switch in 7 shutdown. Is that a separa te switch ?
8 A (WITNESS CALONE) Yes, that is on the center 9 of the 603 panel.
10 0 And what does the operator look at in order to 11 perform step 3.3.3 on the emergency procedure to verify 12 all rods are inserted?
13 A (WITNESS CALONE) Well, again, as I mentioned
) 14 before, there are several mechanisms to make that I
15 determination. He may have had the full core display up 16 on a CRT. If he wanted to do that, he may be running 17 that way. He could look at his full core display, which 18 is on the 603 always. He can request -- push a button 19 on the process computer, which is directly behind his l
l 20 desk, and get a printout of the control rod positions.
21 There is another mechanism of moving the mode 22 switch, that would also indicate whether all rods are in 23 or not. He would use any or several of those mechanisms 24 to verify that.
g lg 25 Let me indicate, on the full core display, if O
ALDERSON PEPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9192 1 there's a scram there is little blue lights associated U<x 2 with each control rod which lights up, indicating that 3 the control rod has scrammed. Normally when he puts the 4 mode switch to shutdown he looks up and looks for a sea 5 of blue, which indicates he has got a scram.
6 0 Does that full core display indicate to him 7 whether he has a complete insertion or a partial 8 insertion?
9 A (WITNESS CALONE) The indicating lights tell 10 him whether the rod is full-in or not f ull-in, not the 11 intermediate position exactly. It wouldn't give him the 12 number of the position. It would just tell him that the 13 rod is fully inserted or it's not fully inserted.
l 14 (Counsel for Suffolk County conferring.)
15 0 Mr. Calone, if a rod is partially inserted or 16 not fully inserted, is that going to satisfy the 17 condition in 3.3.3 for the opera tor, or does he assume 18 that means that the rods are not inserted?
- 19 A (WITNESS CALONE) I don't understand.
20 0 It wasn't a very good question.
l 1 21 What indication does the operator have to have l
22 in order to determine, to say, well, I've now verified l
23 tha t all the rods are inserted?
g 24 A (WITNESS CAiONE) The one I use all the time
! 25 is the process computer edit or the CRT as a visual.
O 1 ALDERSON REPORTING COMPANY. INC, l
l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
1 9193 1 But the other ones are also used, that is the full core 2 display or the mode switch.
3 0 Where is the CRT display?
W 4 A (WITNESS CALONE) On the 603 panel.
5 0 And how long does it take to get the process 6 computer printout?
7 A (WITNESS CALONE) I can't answer that 8 specifically because we just went to high speed line 9 printers in there, and I know the paper flies out of 10 those things like a son of a gun, but I don't know. I i 11 would say within a few seconds, but I can't give you a 12 definitive answer.
13 A (WITNESS HODGES) Also, for the scenario that h 14 I thought we were going through, it boiled down very 15 simply, he icoks. If most -- if not all of the rods are 16 out, so he doesn't have the sea of blue, his APR H's are 17 reading high, so he knows the rods are not in. And so 18 he very quickly has determined that he does not satisfy 19 the scram condition and he proceeds on through the l
20 procedures.
21 Q About how long is it going to take for the 22 operator to perform the three steps that are encompassed 23 in step 3.1 here, to do the manual scram and determine gggg 24 that he has not inserted all the rods?
25 A (WITNESS CALONE) We did make an estimate on
)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9194 1 that and we figure about seven seconds from the time he
(}
2 manually starts performing his scram emergency g 3 procedure, which is to arm and depress, place the mode 4 switch in shutdown, and verify all rods are inserted, to 5 be about seven to eight seconds.
6 0 Now, at this point is the operator going to 7 move on or is he going to try to do this again?
8 A (WITNESS CALONE) That would depend upon the 9 scenario. If we are talking about the scenario that you 10 are into, he is not really going to get down to the 11 point of attempting a multiple rod insertion. He has 12 got the other immediate actions that he has to take.
13 However, if he did rescram the reactor because power was 14 down and all of the rods did insert, he would then move 15 out of this procedure and back to the SP 010.01, which 16 is your exhibit, to continue to shut down.
17 But it is difficult under any scenario to 18 say. Which immediate actions he is going to take right 19 now depends upon that scenario. If we're going to get 20 back to your scenario, then he is probably not going to 21 try to rescram.
22 0 I do want to be talking about my scenario. I 23 vanted to make that clear. I just wanted to ascertain lllh 24 from you that at this point, assuming the rods are not 25 inserted, after he has done 3.1 he is then going to go C>
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
a .95 1 down to the next step, he is not going to try to
/}
2 manually scram it again.
('\ 3 A (WITNESS CALONE) I want you to understand 4 that step 3.1.1 is a man ual scram, and ste p 3.1.2 is 5 also a manual scram. Those are both manual scram 6 signals. So besides not getting his automatic scram, he 7 has in effect tried scramming the reactor two times, 8 once with the push buttons and once with the mode 9 switch.
10 JUDGE BRENNERs Mr. Calone, maybe this is 11 where your six percent comes in, I'm not sure. And I 12 hope this isn't too diverting if I'm wrong. But if you 13 look at just before you start 3.1, you are going to be
(
Nl 14 above -- reactor power is going to be above six percent 15 at that point, correct?
16 WITNESS CALONE: Yes, that 's correct.
17 JUDGE BRENNER: Now, if I follow your 18 parameter literally, the operator would initiate standby 19 liquid control even before 3.1. But that is not what is 20 intended, as I understand it.
21 WITNESS CALONE: That is correct, that is not 22 the intent. The intent is to inject standby liquid 23 control if power does not decrea se to below six l ll 24 percent.
25 JUDGE BRENNER: Okay. If power is above six O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
I 1
9196 I l
l (3 1 percent after completing the 3.1 steps once, each step V
2 once, is the operator then required to initiate standby l 3 liquid control, or does he have the option of trying 4 again to manually scram the reactor?
5 WITNESS CALONE: At that point in time, except 6 for the 3.3 that says trip the recire pumps, because 7 tha t was supposed to be an automatic action, he would 8 probably trip the recirc pump. And if he is above six 9 percent power at tha t point , he would inject standby 10 liquid control without subsequent attempts to scram the 11 r ea ct or .
12 JUDGE BRENNER: Well, don't you think this 13 procedure is written as an ambiguous as to when to pay 4 14 attention to that six percent?
j 15 WITNESS CALONEt From a training aspect, no, I 16 don't.
17 JUDGE BRENNER: That is not the question I 18 a sk ed .
19 WITNESS CALONE: Well, again, I tried to 20 iterate the f act that in the immediate operator actions 21 the operator knows all of the steps he has to take. In 1
22 the training when we went through the procedure, we i
23 discussed the different options that are available to l
24 him. And you can say that steps should be up front or
. gggg l 25 in back.
(
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 5b4 2345
9197 1 The operator has to respond to the situation, O 2 and in our training we indicate to the operator which 3 are the delicate areas. Power level in the reactor is a T 4 delicate area. If you can't get it down, you must do 5 something, either inject rods or inject some additional 6 poison. The way that is done is by standby liquid 7 control.
8 JUDGE BRENNER: But as part of training, as I 9 understand it, operators do a lot of refreshing on their 10 own, which includes rereading these procedures from time 11 to time, either in preparation for testing or beyond, to 12 keep thing s fresh in their mind throughout their 13 careers, correct?
) 14 WITNESS CALONE: Yes, that is correct. We 15 also have simulator refresher courses also.
16 JUDGE BRENNER: Well, shouldn't the procedure 17 as written be consistent with what you are telling them 18 in training, so that he vill be refreshed correctly?
19 WITNESS CALONE: I don't think that difficulty 20 really exists from, again, my experience in the training l
21 area. Having been in the classes with the operators and 22 having been taught this lesson plan or procedure, in 23 this case, I don't think that difficulty really is 24 something that we have a concern with right now.
25 JUDGE BRENNERs I haven 't gone th ro ugh the O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
I 9198 l
I 1 changes outlined in the proposed procedure guidelines
}
2 that we have been p rovided, and over the lunch break I 3 expect the parties to figure out how we are going to 4 work whatever is pertinent on that aspect into the 5 record.
6 But can you show me where in the guidelines, 7 if anyplace, this question is addressed? That is, where 8 to put the indication of when to pay attention to the 9 above six percent power parameter?
10 WITNESS CALONE: While Mr. Carter is looking 11 that up, you have got to remember, we're going to talk 12 about a guideline now, which is now a step by step 13 procedure.
14 JUDGE BRENNERs Yes, I know.
15 WITNESS CALONE: The procedure will be 16 developed from that guideline, incorporating the 17 a pp ro pria te steps.
18 JUDGE BRENNER: That is why I said if it is 19 addressed.
20 WITNESS CARTER: In the referenced guideline, 21 it shows up in contingency number 7, C.7-1.
22 JUDGE BRENNER: Could you give me that page 23 number again? I'm having trouble with the numbering of 24 these pages.
gggg 25 WITNESS CARTERS It is almost to the back of O
ALDERSON REPORTING COMPANY. INC.
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9199 1 the guideline. It is C.7-1.
2 WITNESS PFEFFERLEN: It is within five pages '
S 3 of the end.
\# 4 (Pause.)
5 JUDGE BRENNER: Okay, the guideline is there 6 and in this case they are using an example of three 7 percent in brackets, indicating that it can be adjusted 8 for particular reactors. I guess I,would have to do 9 some more looking on my own to figure out where in the 10 sequence, if any, where the guidelino recommends that it 11 be put in the -- the guideline clearly recommends that 12 the parameter be included in the procedure.
13 I don't know if the guideline will tell me O
's,) 14 where in the sequence of the procedure.
15 WITNESS CARTER: This would probably be an 16 entry condition into another procedure, which would be 17 level power control.
18 WITNESS HODGES: In the emergency procedure 19 guidelines there, the first major procedure I think is 20 reTctor control, is broken into several subparts, one 21 for level, one for power, pressure. And in that part, 22 the part that would be reactor power -- and I think that 23 it's designated as an R0 in that subsection of the 24 guidelines -- it discusses the criteria for going to gggg 25 contingency 7.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9200 1 JUDGE BRENNER: All right. I certainly recall 2 the testimony that procedures are being proposed and are 3 under development, and that some of them are complicated 4 enough where you wouldn't want to introduce them right 5 away before adequate training and so on, and the urgency 6 of the time is a function of whether the procedure that 7 you presently have is acceptable. And the testimony is 8 that you believe that it is acceptable .
9 In my mind that doesn't preclude all changes.
10 That is, there are changes that can be made that do not 11 involve a year's implementation time to get the 12 operators up to speed.
13 WITNESS CA10NE Judge Brenner, that is not a h Id true statement. We do not have procedures under 15 development ba sed upon the ne w guidelines. I would like 16 to make a statement, just to clarify the record about 17 the guidelines.
18 There presently exist two presently -- forget 19 about the Rev. 2. There presently exists two types of 20 guidance, emergency procedure guideline, Rev. 1, and the 21 General Electric letter of guidance for ATWS. In the 22 emergency procedure guideline, Rev. 1, we have generated 23 six emergency procedures dealing with reactor control.
24 From the General Electric letter of guidance, we have (glg 25 developed one procedure, ATWS, which is attached to our O
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9201 1 testimony.
\q
~) 2 The emergency procedure guideline, Rev. 2, 3 merges those two into a single guidance, emergency 4 procedure guideline Rev. 2. If and when that is 5 a pp roved for use, what actually then happens is our old 6 total of seven procedures are all redone to come up with 7 new emergency procedures based upon the current 8 guidelines.
9 Now, while our procedures pretty well follow 10 the steps, even though in Rev. 2 there are some 11 distances, but nc*hing really major -- but there are 12 some differences -- we still have to go back and put it 13 into the proper format, which is the Rev. 2 format.
h 14 So we are not talking singularly here of the 15 ATWS procedure for Rev. 2. We are talking all of our 16 emergency procedures, which would be seven procedures.
17 JUDGE BRENNER: I understand that, or I 18 understood it af ter your testimony yesterday. And Mr.
19 Carter helped me on that yesterday, too.
20 But it is not just a matter of incorporating 21 your present procedures attached to your testimony with 22 the other procedures through the Rev. 2 process that is 23 going on, because we also heard testimony that some of l 24 these things with re sp ec t to ATHS, regardless of what 25 part of what procedure they end up with, may change.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9202 )
i l
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g-) 1 One of the things that may change is some indication of QJ l 2 when the operator should pay attention to the six 3 percent parameter as an action requirement to initiate 4 s ta nd by liquid control.
5 And even if you hadn't said that, I would have 6 been pursuing the same line anyway. It wasn't your 7 telling me that that stimulated that.
8 WITNESS CALONE: I understand what you are 9 saying.
10 JUDGE BRENNER: Mr. Hodges, this is going to 11 be a very unspecific question. What do you think about 12 this?
13 WITNESS HODGES: The overall guidelines, the 14 ATWS guidelines, or the mechanism for incorporating 15 them? I'm not sure what you're asking.
16 JUDGE BRENNER: As promised, it was totally 17 unspecific. My possible concern that there is too much 18 ambiguity, that is inappropriate ambiguity. Some 19 ambiguity is appropriate. We understand that. But 20 inappropriate ambiguity with respect to when the 21 operator should decide that the condition of being above 22 six percent power level requires initiation of an 23 ATWS.
g 24 And to flesh out the concern a little bit, if 25 the operator knows tha t there is some time when the O
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9203
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1 reactor is above that condition for which he shouldn't 2 act and initiate standby liquid control, yet other times 3 when he should act, we worry about that.
4 And assume that LILCO's testimony is correct 5 that in the training program it is explained to the 6 operator, as F.r. Calone explained it here. I'm granting 7 him that assumption. Nevertheless, what do you think of ,
l 8 the procedure as written? l
)
9 WITNESS HODGES. Personally, I would prefer 10 that it did not use the six percent criteria there, that 11 is, for actuating it, but use it instead as a criteria, 1
12 if you were at the 110-degree temperature limit and you 13 were above six percent, rather than "or." I would use 4 14 it more as an "and" statement. I think the appropriate 15 actions to take at this point are not to inject the 16 standby liquid control system, but trying to do it with 17 the rods, because that is the fastest way of getting it 18 down.
19 And so I think that is the way to go and get 20 the reactor shut down , if a t all possible. I think the 21 BWR owners group subgroup has worked on these guidelines 22 and has considered this in some detail, and have been 23 very careful in how they worded it, and I liked their gggg 24 wording. And it basically refers it to doing it on a 25 suppression pool temperature. I think that is a more O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9204 1 practical way of doing it.
2 JUDGE BRENNER: All right.
3 WITNESS CALONE4 Judge Brenner, not to get '
4 into Rev. 2, but in Rev. 2 they use an "and" statement 5 for injection standby liquid control power level, which 6 is the APRM down scale and the 110 degrees in the 7 suppression pool. Our procedure as written is an "or" 8 statement, and it is technically more conservative from 9 an injection point of view than even the new guidelines 10 a re .
- 11 JUDGE BRENNER: I was going to get at that 12 with Mr. Hodges, that from the stand point of a possible 13 concern of initiating standby liquid control too la te, l 14 given what you just said, Mr. Hodges, that wouldn't 15 happen because you think it is okay if it is not 10 initiated until 110 degree suppression pool temperature 17 is reached?
18 WITNESS HODGES: I don't see a safety problem 19 with initisting it early. I just think f rom a practical 20 standpoint they probably won't do it early.
21 JUDGE BRENNERa Your concern is he might do it
. 2:2 too early, too early rather than too late?
23 WITNESS HODGES: I'm not concerned with his gggg 24 doing it early. There's no problem with his doing it 25 early.
r'T
- s ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345 l
9205 1 JUDGE BRENNER: No, I mean that might be the 2 effect of the procedure as written, that is leading the 3 operator into initiating standby liquid control before 4 a ttem pting manual scram.
5 WITNESS HODGES: Yes.
6 Understand, if I were an operator in a control 7 room and I had good guidance and I thought I could get 8 them in manually and I wasn't at the 110-degree limit 9 yet, I think I would probably keep trying f or a little to while until I got there.
11 JUDGE BRENNER4 If the operator initiates 12 s ta nd by liquid control --
13 WITNESS HODGES: Ihey point out, I would be in 14 violation of my procedures at that point.
15 JUDGE BRENNERa It's in the area of trying to l 16 teach an old dog now tricks with a different procedure.
17 Mr. Hodges, if the operator has initiated 18 standby liquid control before manually scramming the l 19 reactor, is there any reason why he cannot immediately l
l 20 proceed with manually scramming the reactor anyway?
21 WITNESS HODGES: I think he would, once he had 22 initiated, he would go back and continue trying to get 23 the rods in any way he could.
gggg 24 WITNESS CALONE Yes. Let me make that clear 25 from a training point of view. While he would inject A
\_]
ALDERSON R5 PORTING COMPANY,INC, 400 VIRGIN:A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9206 g~ 1 standby liquid control, he would then proceed to try to 2 insert additional negative reactivity, basically the 3 control rods.
W 4 Again, that is another difference between the 5 Rev. 2 and our procedure. Our procedure basically has 6 him inject the full content of the standby liquid 7 control independent of subsequent rod injection. The 8 quidelines, the new guidelines, indica te that once you 9 have all rods in you can secure injection of sodium. So 10 ve are conservativo on that, also.
11 BY MS. LETSCHE (Resuming) 12 0 Let me just clarify one thing, Mr. Calone. We 13 have gone up through step 3.1 of this procedure. So far h 14 are all of these things -- all of these actions, will 15 they have been performed by the same operator?
16 A (WITNESS CALONE) Yes. Are you going to 17 bypass 3.2?
18 0 No, I wasn't going to. I wanted to see where 19 we were at the end of 3.1.
20 Now, assuming that when the operator does step 21 '3.3.3 he is not able to verify that all the rods are 22 inserted. What is the next thing he is going to do?
23 MR. REVELEYa You're skipping 3.2.
gg 24 WITNESS CALONE: Yes, she is skipping 3.2.
25 You're talking about we would have to continue O
%d ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9207 1 down into this procedure. 3 2 would get us out of the 2 procedure only if all the rods were inserted.
3 JUDGE BRENNER: You are also getting back to 4 what has turned out to be Mr. Reveley's premature 5 objection of about a half an hour ago.
8 BY MS. LETSCHEs (Resuming) 7 0 We are assuming for the purposes of this 8 discussion, Mr. Calone, that we are going to -- that you 9 do not have rod insertion as a result of this manual to scram. At that point is the operator going to go to 11 step 3.3.3?
12 A (WITNESS CARTER) I think on the scenario that 13 we propose the pumps tripped.
h 14 0 Well, let me ask -- that is true, we have 15 assumed tha t the recirc pump trip operates in this 16 transient. Does step 3.3 require the operator to take
, 17 any action at this stage to verify tha t or to retrip it, 18 or is any action contemplated by this step?
19 A (WITNESS CALONE) It is a reminder step for 20 him to trip the pumps if they did not trip, yes.
21 Remember, we are in automatic action, immediate operator 22 action now, and your scenario has us hanging on, if you 23 look at the chart, at about 40 percent power. So he glg 24 will inject standby liquid control at this point.
25 0 I'm sorry, did you say he would?
t's ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
9208 g3 1 A (W ITN ESS CALONE) Yes.
V 2 0 So the operator would not go through all of 3 these other steps required here. He would immediately 4 jump over to step 3.67 5 A (WITNESS CALONE) Well, you say he immediately 6 jumps over to 3.6, and I am saying, yes, he will inject 7 standby liquid control because his power level is high.
8 Now, the attemps to scram, which is the 3.5 9 section, is supposed to be being done concurrently and 10 not sepa ra tely . So we do get to 3.6 rapidly.
11 JUDGE BRENNER: Mr. Calone, what does the 12 operator have to do to verify it in tha t reminder step, 13 that the recirc pumps have tripped?
h 14 WITNESS CALONEa As I previously stated, it is 15 basically a look at the indicating lights on the recirc 16 pump control switches.
17 JUDGE BRENNER: And those are the same lights 18 he can see while he is performing those 3.1 steps?
l 19 WITNESS CALONE: Yes, he can see them.
20 JUDGE BRENNERa So we shouldn't get into the 21 mind set of thinking of these things as a sequential l 22 operation, even though, because you have to write one 23 line before another, the representation of that is lower 24 down on the page ggg 25 WITNESS CALONE: Yes, that is correct. As you i
l ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9209 1 1:.dicated, the operator ref reshes himself via th e 2 procedure. So in his mental set he has to have the 3 steps that are going to occur and the steps that he 4 should perform.
5 So in his study we talk lesson plans and we 6 talk procedures. We don't have lesson plans for 7 procedures. Procedures stand as their own training 8 device, and the operator is taught lesson plans on 9 systems and procedures on procedures.
10 (Counsel for Suffolk County conferring.)
11 JUDGE BRENNER4 M s. Letsche, since we have 12 been asking about what the operator has to do for each 13 step we have discussed, are you going to ask about what h 14 the operator has to do to initiate the standby liquid 15 control?
16 MS. LETSCHE: Yes, Judge Brenner, I do intend 17 to do that, although I was planning on doing it going 18 through the procedure.
l 19 JUDGE BRENNER: I understand that. But the 20 testimony has, as far as I'm concerned, has got us to 21 that step in the procedure right now.
22 MS. LETSCHEa That is true, Judge Brenner, and 23 I will ask that in just one second.
gggg 24 BY MS. LETSCHEs (Resuming) 1 i
25 C Referring to Suffolk County Exhibit No. 39,
(~
'% )
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345 l
l 9210
<~'s 1 your charts, Mr. Calone, the last one on there, reactor U
2 power, there is a little arrow which sa ys "sta rt SLCS,"
3 pointing to --
I don 't know what time period tha t is 4 supposed to be. Is that the reference that -- does that 5 reflect the statement you just made, that at this point 6 after section 3.2 the operator would inject standby 7 liquid control?
8 (Panel of witnesses conferring.)
9 A (WITNESS CALONE) We are saying that, based 10 upon our estimates on time frame for your scenario, that 11 roughly, that in less than one minute standby liquid 12 control would be injected. So we just put the arrow to 13 indicate that it was some time less than a minute.
4 14 0 Based upon your time estimates, he would reach 15 that decision at about the point where all he had done 16 or all he had tried to do to scram the reactor was the 17 manual scram step in 3.17 He would not have tried the 18 other ones in 3.5 yet?
19 A (WITNESS CALONE) Under the scenario you 20 proposed, I would say that's true.
21 (Counsel for Suffolk County conferring.)
22 WITNESS CARTER: I would like to say 23 something. I think at this point in time we should be gggg 24 reminded that all of the rods are still out and the 25 power is at 40 percent.
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9211 1
0 Moving over just so we have a point of 2 reference, to Section 3.6 of the emergency procedure, 3 Mr. Calone, going to step 3.6.1, the operator is to
{y
\ 4 start either A or B standby liquid control pump. First 5 of all, this is going to be the same operator we have 6 been talking about who has been at the 603 and 602 7 panels?
8 A (WITNESS CALONE) It is the same operator who 9 has been at the 603 panel and has scanned the 602 panel 10 for the automatic action. Yes, the same operator.
11 Q And what does he do to start either the A or B 12 pump?
13 A (WITNESS CALONE) At Shoreham, he has to unlock O)
\x_ 1-4 a key switch and turn it to either A or B, and that 15 starts one of the pumps and fires both the squibb valves.
16 0 Where does he get the key?
17 A (WITNESS CALONE) The key is in the control 18 room in the key locker.
19 0 Where is the key locker located with respect 20 to the 603 panel?
l 21 (Panel of witnesses conferring.)
22 A (WITNESS CALONE) It is -- well, let's put it l
23 this way. As part of the control room there is a watch 24 engineer's office, and it is in his office that the key 25 is located. It is about 35 feet, roughly, from the 603 O
V ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9212 0 1 panel to the locker, I would say.
O 2 0 Is there any procedure or control over which 3 operator or what operators may get the standby liquid 4 control key? Or does anyone have access to that?
5 A (WITNESS CALONE) The key to the key locker is 6 under the control of the SRO in the control room. So 7 the locker key is always in the control room, as the SRO 8 is required to be there, and he would get the key. He 9 is not the same operator that is on the 603 panel.
10 0 Okay. So the 603 panel operator has to get 11 the SRO to get the standby liquid control key? In that 12 right?
13 A (WITNESS CALONE) The 603 operator just turns
% 14 around and says, Get me the standby liquid control key, 15 yes.
16 JUDGE BRENNER: Mr. Calone, is that SRO 17 trained to start getting that key as soon a there is a 18 scram signal?
19 WITNESS CALONE: As soon as there is a scram 20 signal or ss soon as there is an ATWS.
21 JUDGE BRENNER: As soon as there is a scram 22 signal. That was my question. If you want to fill in 23 more information in your answer, go ahead.
g 24 WITNESS CALONE: No, he would not immediately 25 turn to the locker every time we have a scram. It would ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
1 9213 gg 1 be go to the locker if he needed one of the keys that U
2 are required to operate any key lock switch on the 3 control board, or anywhere else throughout the plant.
4 The other aspect is the SRO is a trained 5 operator, and I would expect that if he is in the 6 control room he also has recognized an ATWS, and without 7 being told he may or may not go for the key. I cannot 8 commit to that and say that he will, but certainly, it 9 is the reactor operator's position on the front board to 10 recognize and evaluate the situation and probably 11 request the standby liquid control key.
12 JUDGE BRENNER: He has the key to the key 13 locker on his person ?
h 14 WITNESS CALONE: That is correct. It would be 15 turned over shift to shift. There are two SR0s on 16 shift; one or both may be in the control room. There is 17 always one in the control room and each of th ose 18 individuals has a key to the key locker.
19 JUDGE BRENNERs Is that typical design, that 20 the standby liquid control system has to be initiated by 21 a key device?
22 WITNESS CALONE: I cannot answer that f or 23 other utilities.
gggg 24 JUDGE BRENNER: I wonder if General Electric 25 and then Mr. Hodges can answer that.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
, 9214 1 WITNESS ECKERT: The answer is yes.
2 JUDGE BRENNER Why is that?
3 WITNESS ECKERTs I really do not know why it 4 has been tha t way for all of these years. It has not 5 been a system needed for shutting down normally in the 6 plant, and it has been designed this way.
7 WITNESS CALONE I can't shed great light on 8 it, except that in many instances when you take an 9 action and you want to be certain that you want to do 10 tha t action, you do certain things to make it more 11 obvious that you are doing that, taking that action. In 12 some cases it may be a key; in some cases you may have 13 to push two buttons at the same time with each hand, it h 14 may be just a human factors thing to prevent an 15 inadvertent operation by a single act. Or an overt 16 action on your part that you wanted tha t action to occur.
17 JUDGE BRENNER: Well, Mr. Hodges, let me get 18 your opinion as to whether you agree that that is a 19 typical design.
20 WITNESS HODGESs Yes, that is a very typical 21 design. I think maybe there have been one or two plants 22 recently that have gone to the practice of keeping the 23 key in the lock rather than in the locker, but that is a 24 standard design.
lgggg 25 JUDGE BRENNER: As you often do, you O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9215 1 a*4 ti cipa ted my next question. Other than the one or two d(~s 2 that you think may be going to that, has it, in the 3 past, been typical for the key needed to actuate standby 4 liquid control to, in turn, be locked somewhere else so 5 that you needed a second key?
6 WITNESS HODGES4 I think it has been standard 7 practice for the SRC to be in charge of the key, and to 8 have it in a locker somewhere.
9 JUDGE BRENNER: Mr. Calone, are you worried at 10 all as to whether there would be a problem unlocking 11 that first lock , which is on some presumably non-saf ety 12 grade key locker? I am actually being very serious.
13 You have a possible weak link in the chain here.
h 14 WITNESS CALONE: I certainly never looked at 15 tha t lock as having to be safety related or not safety 16 related, but we did run some time checks to get keys 17 from the locker. The key like the standby liquid 1
18 control key or those keys required in, shall we say, 19 quick timeframes are readily identifiable on the first 20 panel in the key locker. And the scenarios that we have j
21 run -- and we have checked the key, getting the key --
22 was approximately 20 seconds from the time the 23 individual requested it until the time he had it put in Ig 24 his hand.
25 So those are runs where we tried to get a (D
%)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9216 3
1 general feel for how much time we are losing, if you 2 vant to use that word, by not having the key on the 3 panel.
W 4 JUDGE BRENNER The operator opens the locker; 5 what does he see?
6 WITNESS COLONE A page with keys on it. And 7 there are 35 keys on the first page, I believe. And the 8 standby liquid control is in the first 10 I think.
9 JUDGE BRENNER: Do all the keys look alike?
10 WITNESS CALONE: I don 't know. If they were 11 on the same panel they would be numbered.
12 JUDGE BRENNER: There is a number on the key?
13 WITNESS CALONE: I can't answer that right h 14 now. I think there is a number on the tag. In other 15 words, it is a hanging tag, but I don ' t know the answer.
16 JUDGE BRENNER: What would happen , Mr. Calone, 17 if there was some difficulty in opening tha t locker?
18 WITNESS CALONE: I would assume that at the 19 expense of the locker, the key would still be gotten out 20 of there. I cannot see us not, say, if we needed a key l 21 for an operation situation and we couldn't get into that 22 locker through normal means, that we would get into that 23 locker one way or another. But now we are talking l
24 timeframes.
I 25 JUDGE BRENNER: Do you think it is a good idea l
(
ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9217 1 to introduce this complication into the process of being 2 able to initiate standby liquid control? That is, 3 having to depend on opening another locker and once that 4 locker is opened, the problem in (a) opening the locker, 5 and (b) pulling out the right key from the locker?
6 WITNESS CALONE: In the ATWS scenario, you 7 know, on standby liquid control injection, we discussed 8 the improbableness of the whole scenario. But that 9 point aside, there are a bunch of other keys that are in 10 there that are constantly being acce ssed during the 11 time. It is not that it is a one-shot deals it is going 12 to work this time and not another time. So the locker 13 is constantly accessible f or all the keys in there. It 4 14 is just that standby liquid control happens to be there, 15 also.
16 JUDGE BRENNER: That is a good point. Is 17 there a procedure, and if so, of what frequency, to 18 verify that the right keys are in the right place?
19 Particularly, the standby liquid control key.
20 (Panel of witnesses conferring.)
21 WITNESS CALONE At the present time, that 22 procedure is currently in draf t. We are just getting 23 our keys pulled together and the locker is being set gggg 24 up. But I think it is a good point, to have some kind 25 of verification in there that the keys are in the proper A
U ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
i 9218 1 place.
2 JUDGE BRENNER: Is the standby liquid control 3 key lock itself tested from time to time? Can that be 4 done without ir.itiating standby liquid control?
5 WITNESS CALONE: There are surveillances that 6 require us to initiate the firing of the explosiv' 7 valves, the squibb valves, and I believe we do that 8 every 18 months. The system itself is run locally by 9 pushbutton to verify that the pumps are running, but 10 once you turn that key lock switch to the A or B system, 11 the squibb valves would fire. So currently, on the tech 12 specs I believe we only fire them and verify the switch 13 operation once every 18 months when we actually have to h 14 inject some demineralized wa ter in to the vessel.
15 JUDGE BRENNER: If someone were to suggest a 16 requirement to keep the key of the standby liquid 17 control switch in an interim period until the Commission 18 decides what it wants to do, would there be a reason we 19 are not focusing on as to why you think that is a bad
! 20 idea?
l l 21 WITNESS CALONE: I don 't see why we would not l
22 be able to comply with an item like that.
23 JUDGE BRENNER: I know you would be able to 24 comply physically. I want to know --
j gg
[
i 25 WITNESS CALONE: Well, we wouldn't have an f'
ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345 l
9219 1 objection for another reason. I don 't see any problem, 2 again. My determination has always been that the key 3 lock or any other mechanism of that type is to make the 4 operator aware that he has taken an action that would 5 not normally be taken. He has got to be sure of what he 6 is doing, and I don't think we would have a problem with 7 that.
8 JUDGE BRENNER: I guess what I wanted to make 9 sure you were thinking of, and it sounds like you did, 10 leaving the key in the lock would not leave a situation 11 where the switch easily could be inadvertently actuated 12 by brushing up against the key or something like that.
13 I am not sure whether just jiggling it would cause a 14 problem, or if you actually have to give it a turn.
15 WITNESS CALONE: It is a turn position. We 16 could leave th e k e y in the switch itself in the locked 17 position.
18 JUDGE CARPENTERS May I just pursue this just 19 a little bit further, in between the condition that 20 Judge Brenner was just describing of the key in the 21 lock. You have indicated several times how impressed 22 you are with the low probability of this event. Would 23 you agree with me that risk is a combination of gggg 24 probability and consequence.
25 (Panel of witnesses conferring.)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l l
9220 1
1 WITNESS CALONE: Yes, I would say that is a 2 standard definition.
3 JUDGE CARPENTER: So let's speak in terms of W 4 risk. I am curious as to why I have seen in many 5 buildings where there is concern about fire, small metal 6 enclosures with a glass window and a small metal hammer 7 that says " break in case of fire." Has any 0 consideration been given to keeping this key, which 9 might be important in attenuating risk to the public, in 10 such a device, not in the lock where the chairman of the 11 board might inadvertently twist it? Having had tha t 12 problem in my own lab with the president of a university 13 vis a vis having to go to two keys, to be sure that only h 14 one key is required and anybody in the control room can 15 get it as fast as he needs it.
16 WITNESS CALONE: I am sure, Jadge Carpenter, l
1 .
l 17 that there are probably many ways of making the key I
18 available readily. Your suggestion certainly is 19 possible. Judge Brenner's position certainly is 20 possible. We wouldn't like to hang things on a control l
21 board because of the fact that it clutters and confuses l 22 and adds another human factor thing.
1 23 Certainly, we are anxious to eliminate the gggg 24 possibility of inadvertent operation of that switch, 25 either by leaning on it or other methods. And your
}
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9221 l I method certainly is a way that could be considered to O 2 keep it available.
3 JUDGE CARPENTER: That is not my method; I W 4 think it is a very common method.
5 WITNESS CALONE: Okay.
6 JUDGE BRENNER: That just nerves to illustrate 7 why the best of all events is not for a board to 8 unilaterally come up with a solution to something that 9 bothers a board. So I suggest that LILCO and the staff, 10 or LILCO by itself, think of some way to avoid needing a 11 lock to work in second locker, either by eliminatino, by 12 whatever means LILCO thinks would best serve its 13 purposes without causing any other problem, and let us 14 know.
15 And I don't know if that means leaving the 16 other locker unlocked or leaving it locked, but having 17 it easily breakable or leaving the key on the panel or 18 something we haven't thought of yet, because you are in 19 the best position to think of problems that we wouldn't 20 think of.
21 WITNESS CALONE: Okay, that is fine.
22 BY MS. LETSCHE (Resuming):
23 0 Mr. Calone, still in step 3.6 of this 24 procedure, does the opera tor, af ter he gets the key and 25 turns on the pump, does he then do something to verify O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
9222 I the rest of this; that the contents.of the tank are
)
2 being injected?
3 A (WITNESS CALONE) Yes. Let me get into 4 something that we talked about yesterday. I believe it 5 was Judge Brenner who asked about how an operator knows 6 he is injecting into the vessel, and I did not 7 appropriately give him th e right information on one 8 aspect.
9 I had mentioced inadvertently the fact that to there may be ammeters associated with these pumps, which 11 there are not. The main indication that an operator has 12 that he is injecting is the pressure indicator on the 13 upstream side of the squibb valves.
4 14 Now, the pressure indicator, if the pump does 15 not sta r t , basically reads zero. If the pump starts but 16 the valves fail to fire, the pressure will read " relieve 17 valve pressure." If the pumps start and the valves do 18 fire and you actually do have injection, you will be 19 reading about 150 above reactor pressure. And if you 20 have a lower pressure, then you would have an indication 21 of a pipeline failure. So it is really the pressure 22 indicator itself tha t is the most meaningful thing for 23 the operator on initiating standby liquid control.
gggg 24 Subsequently, he would see a level decrease in 25 the standby liquid control tank, which is on the 603 l
() I ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9223 w 1 panel, and eventually, he should see a reduction in
{d 2 neutron power in the reactor core.
rS 3 0 Where is the pressure indicator?
(d \
4 A (WITNESS CALONE) On the 603 panel.
5 0 You said eventually he will see a reduction in 6 the neutron flux. What time period are you talking 7 about there bef ore he will see that?
8 (Panel of witnesses conferring.)
9 A (WITNESS CALONE) Is your question associated 10 with the drop in the tank level or in neutron flux level?
11 0 Neutron flux.
12 (Panel of wi tnesses conf erring. )
13 A (WITNESS CALONE) On the order of 5 minutes.
14 (Counsel for Suffolk County conferring.)
15 JUDGE BRENNER: Incidentally, Mr. Calone, 16 whenever you say something is on a panel, I assume that 17 means the front of the panel. Is that correct?
18 WITNESS CALONE: Yes, Judge Brenner, that is 19 correct. ,
20 BY HS. LETSCHE (Resuming):
21 0 M r. Calone, going to Suffolk County Exhibit 22 39, the last chart on there which shows reactor power, 23 the place where you have the " Start SLCS" on that chart 24 reflects the time necessary to get the key and to do all 25 of the steps up to the point where the operator is going O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9224 1 to decide to inject the SLCS, is that right?
(Jg 2 A (WITNESS CALONE) Yes. In our assumptions, he 3 had to get the key, that is correct. That is why we are
{~T
' 4 up to about a minute.
5 0 Now, the point at which the pressure level --
6 which is at about 40 -- then slopes down to about a 7 little bit below 25, that is not attributable to the 8 SLCS, is it?
9 A (WITNESS ECKERT) That is right. It is to responding more at that point to the fact tha t feedwater 11 is shown to be going off, up in that third, from the 12 bottom chart. The subcooling turns and the water level 13 is starting to reduce and core flows are reducing and I
'x_\) 14 tha t reduces the power.
15 0 Do these things you just mentioned, Mr.
16 Eck ert , do they all take place without additional 17 operator action? Is that right? Other than what we 18 have discussed so far?
, 19 A (WITNESS ECKERT) There is a step in the 1
20 procedure, but that was also in the estimate here, as we 1
21 prepared this chart, that the feedwater pumps on this 22 plant are driven by steam turbines that take their steam 23 downstream of the isolation valves. And in this event, 24 those valves shut at the beginning, and those turbines ggg 25 ran out of steam, and we believe that they would end up O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9225 fs 1 being incapable of supplying anymore feedwater flow U 2 right out there at about 30 seconds.
3 (Counsel for SuffoAk County conferring.)
W 4 0 Again referring to Suffolk County Exhibit 39, 5 in light of your answer on when the neutron flux effect 6 would be seen, -- and the effect I am talking about is 7 from the standby liquid control, tha t that would start 8 at about 5 minutes, -- I assume that given your graph 9 here, that the real effect is sort of off this scale 10 after 10 minutes, is that right?
11 A (WITNESS ECKERT) Yes.
12 A (WITNESS CALONE) Yes, that is correct.
13 0 I would like to go back now, Mr. Calone, to l 14 step 3.4 of the procedure. Who is it in the control 15 that would be performing this step commencing 16 suppression pool cooling by using the RHR system?
17 A (WITNESS CALONE) The second opera tor would 18 perform the step of putting suppression pool cooling 19 into effect with the knowledge that he is blowing steam 20 through the suppression pool and it is beginning to heat 21 up. It is not that physically his temperature is 22 rising. He knows the situation of safety valves 23 lifting, safety valves lifting or HPCI or RCIC running 24 adds heat to the suppression pool, so that would be a 25 normal function for him to perform in starting to cool O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9226 1 the suppression cool.
(')N u
2 0 Now you said he is going to know th i s . What
('X 3 has he looked at to know that?
4 A (WITNESS CALONE) I don't understand what does 5 he look at.
6 (Panel of witnesses conferring.)
7 0 How is that he comes to the conclusion that he 8 has to commence suppression pool cooling ?
9 A (WITNESS CALONE) He has really several things 10 that will get him there. The basic scenario gets him 11 there. He has safety valves lifting; that immediately 12 tells him he is adding heat to the suppression pool and 13 he is going to have to commence with suppression pool
{N
\/ 14 cooling.
o 15 If he doesn't respond to that, at 90 he 16 will get a high temperature in the suppression pool 17 alarm, and the response to that alarm is to commence 18 suppression pool cooling. And that is where you start 19 into a scenario.
20 And thirdly, I thought it was obvious, but 21 just to say it, step 3.4 tells him if he is in this 22 procedure to commence suppression pool cooling.
23 0 Well, given our time sequence we are talking gggg 24 about -- and this is something the second operator is 25 going to be doing. We have the first operator doing all (h
u)
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9227
(] 1 of the stuff we have been talking about already. Where L
2 in the timeframe is operator two going to perform step p 3 3.47 v 4 A (WITNESS CALONE) Step 3.4 is really a response 5 to a problem of pool heatup. He is not worrying about 6 it. The first thing he is worrying about is the scram 7 shutting down the reactor and getting his boron in. It 8 is an immediate operator action. But in this scenario 9 that you have, he would get to it within some short 10 timeframe, but he would not be doing that as a priority 11 to shutting down or injecting standby liquid control.
12 In the scenario that we looked at on your 13 chart, we are saying about 3 minutes into the transient.
\ In order to do this step, is the opera tor t/ 14 0 15 going to get a copy of the procedure that is referenced 16 here, SP.121.01? That is not an emergency procedure, is 17 it?
18 A (WITNESS CALONE) No, that is a normal 19 operating procedure for the RHR system.
20 (Panel of witnesses conf erring. )
21 The reference there of 23.121.01 as the normal 22 operating procedure for the suppression pool cooling 23 would have to be referred to at some time. He would not gg 24 pull it out to commence suppression pool cooling, not to 25 get it started. After he has got it started he would
/^3 N-)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON, D.C. 200 3 (202) 554 2345 i
l 1
9228 1 then pull the procedure and verify proper valve lineup.
2 But he has an indica tion on the board tha t tells him he
/~3 3 is in suppression pool cooling. l
\T
'/
l 4 The RHR system, besides having an indication, j 5 also has a mimic; so he follows his mimic and he can get 6 it on and then he will verify after it is on, through 7 the procedure, that he has it on in the proper 8 configuration.
9 A (WITNESS HODGES) Just an added comment. In 10 addition to his having memorized the procedure for doing 11 this, this is not a rare occurrence, his ha ving to start 12 this system. And one of the systems is already lined up 13 for pool cooling. So it is a very simple process for ON Ns ,) 14 him to start it up, and he has done this a number of 15 times before, this ATWS event, presumably.
16 0 This isn 't one of the procedures that the 17 operators are required to memorize, is it, this RHB 18 operating procedure?
19 (Panel of witnesses conferring.)
20 A (WITNESS CALONE) No, this procedure is not 21 required to be memorized. It is one of those evolutions l
22 you go through so often that you know how to do it.
23 However, we do require the operator, at some subsequent l 24 time, to verify, using the procedure, that he has 25 performed the proper action. But in the situation here 1
l ALDERSON REPORTING COMPANY,INC, l
400 VIRGINTA AVE S.W, WASHINGTON, D.C. 20024 (202) 554 2345
9229
- 1 where he has no time to get the procedure and work his 2 vay through it, he would just line it up and go into 3 suppression pool cooling.
4 (Counsel for Suffolk County conferring.)
5 MS. LETSCHE: I would like to have marked as 6 Suffolk County Exhibit 41 for identification a portion 7 of the SP 23.121.01. The copy I have is Revision 1, the 8 effective date October 23, 1980. I am only marking for 9 identification the first 10 pages of that procedure, to although the entire proced ure consists of a total of 53 11 pages, and I will give an entire copy of the procedures 12 to the witness for his reference.
13 JUDGE BRENNER: Are you going to give us 14 copies, too?
15 (The document referred to 16 was marked Suffolk County 17 Exhibit 41 for 18 identification) 19 MS. LETSCHE: Yes. .
20 JUDGE BRENNER: Ms. Letsche, do you think you 21 vill finish in about another half hour?
22 MS. LETSCHE I think I might be able to, 23 Judge Brenner, I will certainly try.
l 24 JUDGE BRENNER: So as identified , it is marked 25 for identification as Suffolk County Exhibit 41.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9230 ;
1 BY MS. LETSCHE (Resuming):
2 Q Mr. Calone, do you have a copy of what has 3 been marked as Suffolk County Exhibit 417 4 A (WITNESS CALONE) Yes, I do.
5 Q Can you indicate what portions of that 6 procedure -- and I hope they are in the part I copied --
7 are the portions that the operator would perform in 8 doing step 3.4 of the ATWS emergency procedure?
9 A (WITNESS CALONE) Yes. On page 3 on the Index 10 you will see under " Normal Performance", Section 8.1.4, 11 which is on page 8. And if you turn to page 8 there is 12 a procedure for manually initiating suppression pool 13 cooling.
r~
(N V
\
14 Q And the operator would -- he wouldn't go and 15 get this procedure, but he would perform all of the 16 steps in Section 8.1.4 of this procedure in complying 17 with the ATWS emergency procedures step 3.47 18 A (WITNESS CALONE) He will initiate suppression 19 pool cooling without this procedure. Subsequently, he l 20 will get the procedure and verify that he has, indeed,
[
- 21 performed all of the required steps.
22 A (WITNESS ECKERT) Can I interject here one 23 point. We put down the time at which they thought they l 24 would get to this step, in responding to the event, 25 sensitivity of the event, to the time of starting these O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9231 I heat exchangers is not very great at all because at (J^)
2 these pool temperatures, the heat exchangers are not
(~}
% i 3 taking a lot of heat out. So that if they were 5 V 4 minutes later than this in getting them running, we 5 would see something like a 2 degrees difference in the 6 peak pool temperature, so we are talking about that kind 7 of a term.
8 0 Mr. Calone, in terms of the order in which 9 operators are going to be doing things, we have 10 discussed that they are going to be identifying the 11 event and manually scramming and turning on the standby
_ 12 liquid control is the next thing they are going to be 13 doing; the RHR commencement.
'N ) 14 A (WITNESS CALONE) I would say that pretty 15 rapidly af ter they have gone through their immediate 16 operator action, the other operator actions we have 17 talked about, including injection of standby liquid 18 control, that the suppression pool cooling will be 19 initiated due to the pool heat-up.
20 0 And about how long is it going to take the 21 operator to perform whatever he has to do to achieve 22 that and be ready to do something else.
23 A (WITNESS CALONE) Under the scenario of an RHR 24 heat exchanger, one is normally lined up to the pool.
gglg 25 That is a rapid turn-on. The second one is normally O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O C. 20024 (202) 554 2345
s ,
' ~ 9232 r x, 1 lined up for low pressure coolant injection, and that
(-)
2 would take him about a minute to recycle the vaves to 3 put them in the proper cond.ition. So the first RHR
'4 system would come on, I would say, in less than a 5 minute, and the second one probably within one to two 6'4. minutes, and that would put both RHR systems into 7 suppression pool cooling.
8 (Panel of wi tnesses conf erri,ng. )
9 A In g'e n e ra l , to realign tha t $HR system, we 10 have got to operate three valves and turn the pump on.
11 If that is your next question.
12 0 The time estimate you gave us includes the 13 time that the operator would have to take to perform ON
\
x_) 14 that, is that right?
15 A (WITNESS CALONE) Yes.
16 0 Okay. Movin g on to step 3.5 of the procedure, 17 --
1 1
l 18 JUDGE BRENNER: Ms. Letsche, remember l
l 19 yesterday when we discussed -- or I guess discussed and
\
20 you listened - , the possibility of a voidiig the l 's l 21 necessity, yet consistent with your achieving your 3
- t l .
22 purpose on cross examination as I read the cross plan, 23 of upper bounding, enveloping the event, which I think gggg 24 you have done given the assumptions you have asked the l And I don't think going through the 25 witnesses to make.
s l
m s %
ALDERSON REPORTING COVPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
9233 p 1 other steps is going to add anything in terms of the U
2 timef rame of when the operator is going to act and so on.
3 But if you disagree, that is okay, you can l
4 tell me that. But I ask you to consider that.
5 (Counsel for Suffolk County conferring.)
6 BY ES. LETSCHE (Resuming):
7 Q Let me ask you this question, Mr. Calone.
8 Looking at all of the steps listed as subsets of step 9 3.5, the various actions listed in there, how long would to it take for an operator to go through and try each one 11 of these? I am talking about a total now, and not 12 individually. But to perf orm all of these steps.
13 A (WITNESS CALONE) I would be guessing. I would 14 have to go through them step by step. Some of them are 15 rapid. 3.5.1, he will make three attempts to move a 16 control rod; if that doesn ' t move, he is going to stop.
17 So that is five seconds, or let's say 10 seconds for the 18 select time to be included.
19 Bypass the scram discharge volume high level 20 scram switch -- that is right on the 603 panel; he just 21 turns the switch. The reset buttons are about two feet 22 from him on the same panel. He twists those two 23 switchs. That is another five seconds.
llll 24 3.5.2.1, that is a subset of 3.5.2. 3.5.3, 25 confirm all scram valves are open by observation of fm
\_)
ALDERSON REPORTING COMPANY. INC.
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I l
l 9234 1 scram valve position lights. Those lights are on the
)
2 603 main panels they are all blue lights. If they are 3 not all up there, then the valves have not scrammed. In 4 your situation, he would have no blue lights indicating 5 that none of the valves scrammed, or none of the control 6 rods scrammed.
7 De-energizing the RPS system, we would have to 6 send the operator to the relay room and pull some fuses.
9 Two to three minutes to do that.
10 Vent air from the scram air system -- he has 11 to go into the reactor building at elevation 63 which is 12 the same elevation as the control room. Five minutes to 13 go and try that.
\x_) 14 3.5.3.3. is restoration of the breakers in 15 those air valves, so that is a subsequent action to 16 restoration. Bypass the scram discharge volume high 17 level scraa switch -- that is on the 603 panel. Reset 18 the RPS trip and verify the vent and drains -- that is 19 also on the 603 panel. Five or six seconds on that.
20 I don't know the whole thing. It depends on 21 how many times you want to redo it. You can spend hout 22 on it or you could go through it once in probably five 23 minutes.
t g 24 JUDGE BRENNER: M r. Calone, am I correct that 25 under the scenario that the county has asked you to l
O ALDERSON '1EPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9235 1 assume, which we have been discussing and which is, in
(])
2 part, represented by Suffolk County Exhibit 39, standby f^\ 3 liquid control would have been initiated because of the 4 requiremens of 3.6 before going through the 3.5 steps?
5 WITNESS CALONE: That is correct. And just to 6 be clear, the fact that we have gotten into 3.6 and not 7 all of the other steps doesn't mean we don't eventually 8 try to continue to move those rods in. That is the most 9 effective and efficient way of reducing reactor power.
10 So while we have now taken immediate actions, we 11 continue trying to shut the reactor down.
12 One other statement. When I got into the 13 items to be performed in the field, that is performed by O
x-) 14 the field operator and not the individual in the control 15 room, or the individuals in the control room. There are 16 two field operators on each shift.
17 (Counsel for Suffolk County conferring.)
18 BY MS. LETSCHE (Resuming):
19 Q Mr. Hodges, what is the reliability assumed by 20 the staff in evaluating the effectiveness of the 21 operating procedures and training proposed by LILCO to l
l 22 mitigate an ATWS event? What reliability do you assume l
23 with respect to the operator actions?
h 24 A (WITNESS HODGES) I don 't think we assumed a
{
25 reliability number. We assumed basically that the rm u
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345
923 6
(} 1 operator was going to follow the steps.
2 A (EITNESS CALONE) Let me add to th a t briefly.
3 Mr. Hodges yesterday, in discussing ATWS and training in
{~)
\/
4 the NRC, indicated that there were no reviews of ATWS S training, and he may or may not -- or that may or may 6 not be a true statement. The statement I did want to 7 make about training in general is that the ICE branch of 8 the NRC do make audits and visits to the plant under the 9 plant's staff qualificatior criteria. And in that -
10 review, they do look at training, operator training; 11 they interview instructors and participants, they look 12 at schedules, cost content, lesson plans, exam results, l
,. 13 et cetera.
X-) 14 I am not trying to say that I can show you 15 that ATUS specifically is being addressed or looked at 16 but I can say the training program as a whole is being 17 looked at, and has had favorable reviews by the NBC.
18 JUDGE BRENNEB4 Er. Hodges, for what is worth 19 you may recall I pursued something along those lines 20 with you yesterday, also. Did you talke to ICE in 21 gathering the information that you gave us yesterday?
22 WITNESS HODGES: No, I didn't. I only talked 23 to people within the Office of NRR.
llll 24 JUDGE BRENNER: I guess I should have been 25 clearer with you yesterday. The one personal example I
}
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
I l
9237 1 told you I know of did involve ICE people looking at
)
2 lessons plans and so on.
g 3 WITNESS H0DGES: As I say, I did not check 4 with IEE. I am not th a t f a milia r wi th all the things 5 they do. I lid check with people within NRR and 6 discussed it with them, and they related what they did, 7 and that is what I was expressing.
8 JUDGE BRENNER: Okay.
9 JUDGE MORRIS: Is either of you familiar with 10 what the inspection people do by way of observing the 11 procedures or training?
12 WITNESS HODGES: I am not. Maybe one of these 13 others is.
14 WITNESS CALONE4 Could you rephrase the 15 question a little bit? I don't know what you mean when 16 you say "what they do." I have a general involvement as 17 plant management as to the exit and the entrance 18 reviews, and some of the discussion on training 19 philosophy and that kind of stuff. I don't physically 20 follow them around. I can give you a list of items that 21 they normally check, but I couldn't specifically say 22 they did this or this or this on a very unique basis.
23 JUDGE MORRIS: No. I am merely trying to llll 24 establish whethat or not NRR personnel, in this case, 25 those who are assigned to the inspection function, do in O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9238 l
1 fact do some kind of inspection of training and the 2 quality of procedures and the ability of the operators
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3 to carry out those procedures. I am not looking for any
\~ 4 details at all.
5 WITNESS CALONE: I can't answer for NRR. We 6 have been dealing with ICE and they have just finished a 7 five-day review of our training program with no 8 outstanding findings. So I assume that from a training 9 program point of view context, schedule, they did have to discussions with operators in the class, they did sit in 11 on some of the classes, they reviewed the training 12 folders of individuals, they reviewed lesson plans and 13 that typr of thing. And there were no outstanding
'x,j 14 objections.
15 We also did just take the NRC exam, and I 16 guess to some extent the exam is the culmination of the 17 training program. But the program has been looked at 18 over the years, and we have always fared well in the 19 general program. Again, I don't know if they 20 specifically look at the ATWS training.
21 22 23 ltII>
25 i
l I
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9239
{) 1 WITNESS HODGES: Maybe I misunderstood your 2 question a little bit. You said the inspectors, and the fN 3 Office of Inspection and Enforcement is separate from 4 the Office of NRR. And I talked to the people within 5 NRR, and their primary check is basically the operator 6 licensing exam where they test the operators.
7 I am not familiar with what the Office of 8 Inspection and Enforcement does on this.
9 JUDGE MORRIS: Thank you. Just having some 10 knowledge myself, I wanted to have it on the record that 11 the inspection part of NBC does look at these things.
12 BY HS. LETSCHEa (Resuming) 13 Q Mr. Eckert, are you familiar with what is
(%
\ s-) 14 referred to as the ten-minute rule for the design of 15 safety-related systems in nuclear power plants?
16 A (WITNESS ECKERT) I do not know that it is a 17 rule, but it has been discussed certainly as we talked 18 about assumptions for when manual actions are taken in l
19 different transient sequences.
20 JUDGE BRENNERa She means rule of thumb rather 21 than rule. Does that help, Mr. Eckert?
i 22 WITNESS ECKERTs Yes.
l 23 BY MS. LETSCHE (Resuming) gll 24 0 Is the reliance at Shoreham upon the operator 25 action of turning on the standby liquid control system l /^
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ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9240
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v 1 in the first minute or so of an accident consistent with 2 that ten-minute rule of thumb?
f'l 3 MR. REVELEY Judge, let me point out again 4 and make my standard objection that once more we are 5 talking about whether or not to automate the SLC, the 6 primal issue as to BWRs in the ATWS rulemaking.
7 JUDGE BRENNER4 No. I think she is still in 8 tha t interim area of the efficacy of the interim 9 measures, and she has come up with a different ya rd s tick 10 this time.
11 HR. REVELEY: Let me have one more bite then.
12 JUDGE BRENNER: I think we have got the answer
,, 13 to the question throughout this record is one of my 14 problems with it.
15 MR. REVELEY: The Commission obviously is 16 familiar with the ten-minute rule of thumb. The 17 Commission is f amiliar with BWRs and their standby l
l 18 liquid control arrangements. Obviously, the Commission 19 had to have taken into account precisely what Ms.
20 Letsche is talking about in making its interim finding.
l 21 Enough said.
l 22 JUDGE BRENNER: Well, you are a good attorney, l
23 Mr. Reveley, and what you have done is dressed up in a llll 24 form you thought would be more palatable your initial 25 argument introducing the contention; that is, the l
O l
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345 l
9241 1 Commission must have had these parameters in mind within
)
2 which any reasonable utility must be taken to fall 3 within. That is not a very great extension to the point 4 you just made.
5 And, yes, we get to the points, as we have 6 indicated on our rulings on the motion to strike, we are 7 squarely within what the Commission obviously considered 8 and assumed; but one problem we have here in this 9 proceeding which we have caused you to share with us is 10 that the Commission when they write some of their 11 statements are not always thinking of all of the 12 ramifications of those of us who later have to read and 13 apply them. And it is not always perfectly clear what h 14 the Commission had in mind. And when you are talking 15 about using it to bar a contention or to bar an area of 16 inquiry, I suppose reasonable people would differ as to 17 how clear that indication would have to be in order to 18 take that action; and we have tried te make our 19 judgments accordingly. .
20 B ut I do not see -- I am going to allow the 21 answer in a moment, but I do not see where it is 22 productive, because we know what ten minutes is as a 23 measure, and we have got all of the testimony as to how llg 24 long this is going to take. And I want you to recall 25 the testimony of Mr. Hodges yesterday who told us -- and O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, O C. 20024 (202) 554 2345
9242 1 this is a paraphrase -- do not worry about the tiee; (L w) 2 take a look at the parameters. And it is when you reach 3 those parameters that the actions are taken, and that is
('T
)
\
4 what counts.
5 Do you recall the question, Mr. Eckert?
6 WITNESS ECKERT: Yes, I think so.
7 What we prepared here was our realistic 8 estimate when we really think the operator will take 9 these actions, not based on some arbitrary rule of thumb 10 or whatever. And I firmly believe that this time frame 11 is when he will do it. He has had indications of 12 isolation valve closure. He has had indications that a 13 scram should have taken place from that signal, that he
\jx 14 should have had a scram from high flux in the reactor, 15 tha t he should have had a scram from high pressure in 16 the reactor, potentially even f rom low water level in 17 the reactor. And he has very clear indications that the 18 rods did not go in and tha t the power did not go down.
19 And especially in this type of sequence here that you 20 have constructed that perhaps is the most serious threat 21 or whatever you want to conjecture there, he would very 22 definitely take actions in this time frame and get that 23 system going.
24 MS. lETSCHE: Judge Brenner, that completes g
25 the County 's cross examination at this time. I do, ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W., WASHINGTON D C. 20024 (202) 554-2345 l
9243 1 however, intend to do what you suggested which is look 2 over the guidelines which we received yesterday. And I 3 did have a conversation last night with Mr. Earley in
(~\
s T
'~ 4 which certain portions were identified as being 5 pertinent to ATWS and possibly of interest to the 6 County; and we will review that over the break and 7 determine whether we desire to pursue it any further.
8 JUDGE BRENNER: All right. And I also invite 9 LILCO, if it chooses, to put any portion of tha t 10 procedure into the record.
11 While we are talking, we are going to break 12 for lunch in a moment, and we will be on a one-hour 13 break.
's_s 14 In addition to -- while we are on the subject 15 of putting things into the record, the Board may or may 16 not want to use Section 15.3 of the basic SER as part of 17 our consideration of this matter. It has been well 18 focused on, I think, and I am saying it expressly so 19 tha t it is not a surprise later. It has been focused on i
j 20 through our comments yesterday, as well as the fact that 21 15.3 of Supplement 3, which refers back, was put in.
I l 22 You have also got almost the same language, not in 23 evidence but in one of your exhibits for identification g 24 by way of the enclosure to the memo. It talks about 25 what types of things the staff is going to look for as
(~h
%J ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9244 p 1 to what should be in the procedure. Therefore, it is
%)
2 arguably more pertinent than the section of the 3 supplement that was put in or as pertinent anyway.
4 So it is in evidence, and we are going to feel 5 free to use it, and I wanted the parties to know that.
6 For convenience, if it can be arranged, maybe we can get 7 copies to bind in after lunch, if that is possible.
8 All right. Let us break until 12: 45.
9 (Whereupon, at 11:45 a.m., the hearing was 10 recessed for lunch, to be reconvened at 12: 45 p.m., the 11 same day.) .
12 13 14 15 16 17 18 I
19 l
20 21 22 l
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ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
9245 1 AFTERNCON SESSION (v~N 2 (12445 p.m.)
l 3 JUDGE BRENNEF: Back on the record.
4 Does the County have anything further after 5 the break? You were going to consider whether you did.
6 MS. LETSCHEs No, Judge Brenner, we do not at 7 this time, although af ter the two-week break I will let 8 you know if we determine that we want to do anything 9 related to the revised guidelines that have been 10 submitted on this ATWS material.
11 I did check and find out, however, about the 12 deposition of Mr. Jones, and I will just tell you that 13 while I am thinking of it. I understand that the time 14 and date has actually been set for September 1st, I 15 believe. The parties have agreed on that. So your idea 16 of putting in the 7th would certainly be all right 17 apparently. It has been all decided, as I understand it.
18 JUDGE BRENNER: Do you need a subpoena still?
19 MS. LETSCHE4 Judge Brenner, I think that it 20 has been agreed that that is the date that he is going 21 to be able to appear. The parties have agreed on that.
22 JUDGE BRENNER: I do not know whether you have 23 agreed that under the subpoena he will appear on that 24 date.
25 MS. LETSCHE Yes, Judge Brenner, that is what O
U ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9246
() 1 we have agreed.
2 JUDGE BRENNER: Does LILCO still need the l 3 subpoena?
4 HR. REVELEY: That would probably be prudent.
5 JUDGE BRENNER: Okay. I will make it a time 6 prior to September 7 with the on the record 7 understanding that parties are going to try their best 8 to have it that first week. And it appears as if in 9 fact that has been settled.
10 (Discussion off the record.)
11 JUDGE BRENNER: Back on th e record.
12 Should we bind in any of the County's exhibits 13 for identification which were not previously bound in?
14 And I guess if I knew which ones they were I would do it.
15 MS. LETSCHE Judge Brenner, I think it would 16 make sense to bind into the record, and I would just 17 move them into evidence at this point also.
18 JUDGE BRENNERs Well, let us get a handle on 19 which ones they are and which ones you are moving into 20 evidence.
21 (Discussion off the record.)
22 JUDGE BRENNER: The Reporter reminds me that l 23 39 is already in. Well, let us take it. The first one lllh 24 was 36, I believe, which is the comments of the staff 25 consultant, am I correct? That was bound into the 3
(O ALDERSON REPORT:NG COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON. D.C. 20024 (202) 554-2345
9247
() 1 record but was not admitted into evidence.
2 Are you moving this into evidence, and if so, (O) 3 you had better tell me the purpose and why it deserves
\J 4 to be moved in.
5 MS. LETSCHE: Judge Brenner, it was something 6 that we discussed. It apparently is going to, according 7 to Mr. Hodges, it is staff comments that were made, 8 human f actors comments made about these procedures.
9 According to the LILCO testimony they were acted upon or 10 not acted upon given Mr. Hodges ' comments. They were 11 documents produced by the NRC staff, and I think it is 12 appropriate to have them in evidence.
rm
()
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13 14 JUDGE BRENNER4 Well, my own opinion is that this deserves no independent evidentiary weight as 15 standing for the fact that these are some sort of things 16 which should be or need be done with respect to changes 17 to the procedure. To the extent they stand as comments i 18 that were made by an individral in the employ of the l
19 staff, under contract to the staff, they have been used, 20 those have been focused on, and you have got them in for 21 identification. So 're would assign no evidentiary 22 weight to this beyond the use already put. And in light l 23 of that I guess I will deny your request to move it into 24 evidence.
1 25 Well, does anybody else want it in evidence?
l
(^) i ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE S.W., WASHINGTON. D C. 20024 (202) 554-2345
9248
() 1 MR. REVE1EYs No. We were going to object to 2 it, Judge, for those reasons and also because the 3 particular revision of the procedures to which the 4 comments are keyed is not in the record, and thus, this 5 particular document could be confusing.
6 JUDGE BRENNER: That is true. With the ones 7 ve discussed we cleared that up. Of course, if this 8 document were important or useful, we could overcome 9 that problem ; but there is no need to do that in light 10 of the other problem.
11 Given the problems with it, in the absence of 12 a witness who can be cross examined as to why these (x
\
13 comments make sense or do not make sense in the view of 14 the author of the comments, we will not admit it into 15 evidence.
16 (The document previously 17 marked Suffolk County l
l 18 Exhibit No. 36 for 10 identification was 20 rejected.)
l 21 JUDGE BRENNER: All right. Thirty-seven is l 22 the memo from Mr. Kramer to Mr. Tedesco. I would like l
23 to bind it in at a minimum; that might be su.tficient.
lh 24 But I will hear you if you want to do something 25 different. You only used --
well, there were some O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S W., WASHINGTON. D C. 20024 (202) 554 2345
9249 1 questions about the attachment.
2 (Exhibit 37A follovsa) 4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 l 19 -
20 i 21 22 23 -
24 25 O
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
.9
- by EhCLOSURE 9 7
[ /
, UNITED STATES N kg -
NUCLEAR REGULATORY COMMISSION fLg y),; ;i
. g k W ASWNGT ON, D. C. 20555 February ll, 1982
(. g
'o....
Docket No. 50-322 g.
V . .
MEMORANDUM FOR: Robert L. Tedesco, Assistant Director -
for Licensing Division of Licensing FROM: Joel J. Kramer, Deputy Director Division of Human Factors Safety
SUBJECT:
SAFETY' EVALUATION REPORT INPUT:
SHOREHAM NUCLEAR POWER STATION - UNIT 1 (SNPS-1)
EMERGENCY OPERATING PROCEDURES AND ANTICIPATED
. TRANSIENTS WITHOUT SCRAM Enclosed are our SER inputs for Section 13.5.2, Operating and Maintenance '
Procedures, which include the TMI Task Action Plan (TAP) Items I.C.1 -
Short-Tenn Accident Analysis and Procedures Revision, I.C.7 - NSSS Vendor Review of Procedures, and I.C.8 - Pilot Monitoring of Selected Emergency G Procedures for Near-Term Operating License Applicants. Also enclosed U is Section 15.3, Anticipated-Transients Without 5~ cram ( ATWS).
The applicant's program for developing Operating and Maintenance Procedures is generally consistent with the guidance provided in Regulatory Guide 1.33 and ANSI 18.7-1976/ANS 3.2, and therefore is acceptable for issuance of a full power license. The enclosed supplement input for Section 13.5.2 completes our review of this item.
The Emergency Operating Procedures are consistent with the requirements of I.C.1 and I.C.8 for the issuance of a full power license pending incorporation of the following items: (1) making the changes that were identified during the reactor simulator exercise, and (2) adding infor-mation to specific areas in the procedures that was not available when they were written; these areas were denoted by the word "Later".
This input completes our review for Items I.C.1 and I.C.8. The applicant has committed to having procedures reviewed by the NSSS vendor as required by Item I.C.7. This will be confirmed by DHFS review of the applicant's resolution of vendor comments prior to issuance of a full power license 3 and by routine inspection by Region I. This item cust be completed prior (V to issuance of a full pcwer license.
The purpose of our ATMS review was to determine if interim requirements to mitigate ATVS events have been completed. Our technical review was performed as required by Frank Schrceder's memo of June 9,1980 to you.
Y4de mg
February ll,1982 Robert L. Tedesco p Although the ATWS procedure could not be fully exercised because of V limitations of the simulator, the ATWS procedure is consistent with the guidance provided in the June 23, 1980 memo from Frank Schroeder to you, and is acceptable for issuance of a full power license. The enclosed SER input for Section 15.3 completes our review of the applicant's ATWS procedure.
The review of Section 13.5.2 was perfor:ned by J. W. Clifford, R. J.
Urban and M. J. Goodman of the Procedures and Test Review Branch.
The review of Emergency Operating Procedures including ATWS was perfonned by J. W. Clif ford, R. J. Urban, and M. J. Goodman of the Procedures and Test Review Branch, and M. Morganstern, L. Defferding, R. Shikiar and S. Crowell of Battelle Pacific Northwest Laboratories (PNL).
There are no dissenting opinions within DHFS on the conduct or outcome of this review.
(w' %'m Jbel J. Kramer, Deputy Director (V3 Division of Human Factors Safety
Enclosure:
SER - Operating and Maintenance Procedures and ATWS cc w/ enclosure:
H. Thompson A. Schwencer J. Wilson J. Higgins L. Phillips
~
O
2-SAFETY EVALUATION REPORT INPUT .
SHOREHAM NUCLEAR POWER STATION, UNIT 1
(~T OPERATING AND MAINTENANC" PROCEDURES
\_/
". AND ANTICIPATED TRANSIENTS WITHOUT SCRAM 13.5.2 OPERATING AND MAINTENANCE PROCEDURES A. ' General A review has been conducted of the applicant's plan for development and implementation of operating and maintenance procedures. The review was cor. ducted to determine the adequacy of the applicant's program for assuring that routine operatinge off'-normale and emergency activities are conducted in a safe m a n t. e r . The following description and evaluation are based on
.O) k- information" contained in -the applicant's PEAR and the applicant's response to NRC TMI Action Plan Items (NUREG-0660 and NUREG-0737).
In determining the acceptability of the applicant's programe the Of Mligr&- OS DO, A.,d ed bite Pbg se db g,5* 1
. :- ; critertaAsere used:
10 CFR Part 50dE50.34 ANSI 18.7-1976/ANS 3.2 Regulatory F,uide 1.33, Rev. 2, March 1978 del @,
Standard Review Plan Section 13.5.2 NUREG-0660 as clarified by NUREG-0737 NUREG-0799
/d
<- fThe review consistec of an evaluation of (1) the acclicant's procedure classifi:ation system for orececures that are performed by License: cre aters in the centrol r:0m, a ., d the :tassification 9
2-Os /.
m for other operating and maintenance procedures; (2) the applicant's plan for completion of operating and maintenance
' procedures during the initial plant testing phase to allow for correction prior to fuel leading; (3) the applicant's program for compliance with the guidance contained in Regulatory Guide 1.33, Rev. 2, March 1978 regarding the minimum procedural requirements for safety-related operations; (4) compliance with the guidance contained in ANSI 18.7-1976/
ANS 3.2; and (5) the applicant's program for compliance with Task Action Plan (NUREG-0660) Item I.C.1, " Guidance for the Evaluation and Development of Procedures for Transients and
()*
L Accidents"e for the development of Emergency Operating Procedure Guidelines.
(hB. Operating and Maintenance Procedure Program ,
The applicant has committed in the FSAR to a program in which all activities are to be conducted in accordance with detailed written and approved procedures meeting the requirements of Regulatory Geide 1.33, Rev. 2, March 1978, "puality Assurance Program Requirements (Oceration)", and ANSI 18.7-1976/ANS 3.2.
The applicant uses the following categories of precedures for those coerations cerformed by Licensed operators in the control D room:
[/
s.
s ._ .
l
._ General Operating Procedures System Operating Procedures Emergency Operating Procedures Alarm Response Temporary Procedures
( Other procedures inc~lude the following areas:
Initial Test Maintenance Instrument and' Control Systems Surveillance
(} Emergency Plan Health Physics Chemistry Reactor Engineering Plant Security Radicactive Waste Management Our review disclosed that the applicant's program for use of operating and maintenance precedures meets the relevant recuirements of 10 C FR Part 34e and is consistent with the gui=ance provided in Regulatory Guide 1.33 and ANS 18.7-1976/
ANS 3.2. Thereferer we conclude that the applicant's program
( is ac:e: able. -
l
_4 _
O C. Reanalysis of Transients and Accidents; Development i
of Emergency Operating Procedures In letters of September 13 and 27e October 10 and 30, and November 9, 1979, the office of Nuclear Reactor Regulation required licensees of operating plants, applicants for operating licenses and licensees of. plants under construction to perform analyses of transients and accidentsi prepare emergency procedure guideliness upgrade emergency proceduress and to conduct operator retraining (see also Item I.A.2.1).
Emergency operating procedures are required to be consistent O with the acti.ons necessary to cope with t he transients and accidents analyzed. Analyses of transients and accidents were to be completed in early 1980 and implementation of procedures and retraining were to be completed three months after emergency procedure guidelines were established; howevere some difficulty in completing these requirements has been experienced. Clarification of the scope of the task and appropriate schedule revisions were included in NUREG-0737, Item I.C.1.
/ Pending staff approval of the revised analysis and guidelinese the staff will continue the pilot monitoring of emergency 7s .
\- ccerating procecures cescribed in Task Action Plan Item I.C.! ( N U R E 3 - 0 6 6-0 ) . The adecuacy cf the SWR Owners' Group 3videlines .il, te i:ertifiec 1:r ea:r near terr ::erating ii:erse CNTOL. curing tne emerger:y ::eaa*ir; Or:te:ure review.
' ~
- I In a submittat dated June 30, 1980s the BWR Owners' Group provided a draft of the generic guidelines for Boiling Water Reactors. The guidelines were developed to compty with Task Action Plan Item I . C .1 (3) as clarified by NUREG-0737 and t
incorporated the requirements'for short term reanalysis of small break loss of coolant accidents and inadequate core cooling (Task Action Plan It ems I.C.1(1) and I . C .1 (2) . In a letter dated October 21, 1980, from D. G. Eisenhut to S. T. Rogers, the staff indicated that the generic guidelines prepared by General Electric and the BWR Owners' Group were acceptable for trial implementation at the-Shoreham Nuclear Power Station, Unit 1. Additional information was requested by the staff anc was submitted by the Owners' Group on January 31, 1981. This additional information is stilL under review prior to the staff making a final conclusion on the acceptability of the guidelines for implementation on all Boiling Water Reactors. The guidelines are still considered acceptable for trial implementation at the Shoreham Nuclear
! Power Station, Unit 1.
Based on our review of the emergency operating procedures develooed from the BWR Owners' Grouc Guidelines ano our 7_
observation of the procedures being imolemented on a simulator i
9
Y k- -
and in a walk-through in the control rooms we have concluded that the guidelines have been adequately incorporated into the procedures. This fulfills the requirements of Section I.C.1 of NUREG-0737.
h(Inaccordance with NUREG-0737e Item I.C.7, NSSS vendor review of low power testinge power ascension testing, and emergency operating procedures is necessary to further verify adequacy of the procedures.
fThis requirement must be met before issuance of a full power license.
b p)
( The NSSS f
/e.nd. ore General, Electric Corporation, will review the startup tests and emergency operating proeedures prior to these procedures being implemented. The startup tests encompass the low power testing and the power as:ension testing phases. The applicant has committed to ensuring these reviews are complete prior to fuel load. The staff must review the applicant's resolution of vendor comments to confirm vender review and implementa. tion of vender comments into the procedures. The staff will confirm that this review is completed crier to issuance of a full pcwer license.
! In accordance with NUREG-0737e Item I.C.Si :orrect emergency 0)
\/ aEe necessary based on the NRC audit of selected pro:ecures plant emergency coerating pro:ecures (e.g., small-break LOCAe less of feedwate , estart of engineered sa'ety features
fotLowing a loss of ac power and steam-line break). This action wilL be completed prior to issuance of a full power License.
k The staff and personnel from Battetle Pacific Northwest .
Laboratories reviewed the procedures forwarded by the applicant to the NRC to ensure that the procedures were consistent with the plant's designs the BWR Owners' Group guidelinese and incorporated applicable human factors considerations. The review resulted in tse pages of general' comments and numerous specific detailed comments u
on the procedures. The general comments included human
(~}
(s _ ,
factors consideration on the use of standard Logic formate procedure identificationi interaction with non-emergency procedurese inconsistency between emergency procedures and control room displays and the inadequacy of the graphs that were included in the procedures. The specific comments incluce clarification and the locations of caution statementsi the inclusion of action steps in cautionse the need for the addition of scecific information to reduce coerator judgements such as the preferrec secuence for starting varicus systemse the neec to acc decision coints to aid (O,,) operator actionse anc numerous references to changing words f
l l
') . and using standard logic format to clarify action steps.
A meeting was held with the applicant on September 16, 1981, to discuss the results of the review. During the meeting many of the comments were resolved by incorporating the recommended changes.
<[/OnOctober 16, 1981e a simulator exercise was held at the Limerick Training Center. Operators used the revised emergency operating procedures to respond to simulated transients and accidents. Scenarios were designed to require the concurrent use of procedures and transition
() among procedures. The s_cenarios. varied faom minor transients to accidents involving multiple system failures.
The simulated transients and accidents included:
- 1) Loss of feedwater from leaks or breaks in feed lines, faulty valve operation, and pump failure.
- 2) Various initiating events followed by failure of various injection systems (e.g., RCIC, HPCIe LPCI) when needed for level controle level restoration and containment control
- 3) Turbine trio follcwed by a reactor trip.
f) s- 4) Failure of off-site o wer with suoseocent failure of a diesel generator.
y- - _. .-__ _ _ . _ - - _ . . _ - - . .__ _ _
.- N gg
't
_9_
4 s
k_). 5) stuck open relief valves resulting in toss of 3
,s Reactor Pressure Vessel Water inventory and ,
r emergency conditions in containment. ,
f\Ait of tn; emergency operating procedures were tested in responding to the simulations. The review team observed the exercises and discussed them in detail with the operators. Special emphasis was place'd on the need to use written emergency procedures and evaluating the clarity and usability of the procedures. Several changes were made to the procedures as a result of the exercises and
- subsequent discussions. The changes involved sequencing .
{} ,
of steps, Labeling to help locate specific steps, and .
,' clarifying priorities of actions. ,
[f On October 17e 1981e the team of reviewers that had I
participated in the simulator exercises conducted a
?
2 i~ walk-through of the emergency cperating procedures in the 3l control room. The operaters 'ere
. presented with the l l
- initiating event Can intermediate-size break), with the 1 ,' desired secuence of steps. The ocerators then salked
- l s
y through the scenarice .hile the team of reviewers t
evaluated the ocerators' use of the procedurese the
() interaction of tne oceratcrs .ith the cen;rol panelse anc the interacti:n etween the operators. The entire
! se:ven:e sas discussec in detail .ith t~e c:nte:L reem - ,
0:e-at:rs an: he : tant Oceraticns s t a ',d at' tr* ----'usijn s
3 ,
.,s 1
, 3 '
10 -
C) of the simulated event. The effective manner in which the operators used the emergency operating procedures indicates that they are clears properly sequenced, and compatible with the control room and its equipment.
- 1) some plant
( rDuring the review, it was noted that:
soecific data were not available and noted by a "(Later)",
- 2) the graphs referenced in the procedures need revision to improve their usability, and 3) there are a few additional changes required in the procedures as noted during the simulator exercises. The applicant has committed
() to incorporate the plant. specific data w h en they are available and to make the agreed to changes to the procedures and graphs. The staff wilL verify that the missing data and changes have been included in the procedures n ty issuance of an operating license.
w D>before LL 15.3 ANTICIPATED TRANSIENTS WITHOUT SCRAM 4 Anticipated Transients Without Scram (ATWS) are events in which the scram system (reactor trip system) is postulated to fail to ocerate as required. This subject has been under generic review by the NRC staff for several years.
fin December 1978, Volume 3 of NUREG-0460, " Anticipated
(~1 s_e Transient Withcut Scram for Light Water React:rs" was
- 11 -
((_m, a issued describing the proposed type of plant modifications we believe are necessary to reduce the risk from anticipated transients with failure to scram to an acceptable level. We issued requests for the industry to supply generic analyses to confirm the anticipated transients without scram mitigation capebility described in Volume 3 of NUREG-0460.
Subsequently, we recommended to the Commission that rutemaking be used to determine any future modifications necessary to resolve anticipated transients without scram concerns as well as the required schedule for implementation of such Shoreham Nuclear Power Station, Unit 1 i s
(} modifications.
subject to the Commission's decision in this matter.
' It is our expectation that the necessary plant modifications will be implemented in one to four years following a Commission decision on anticipated transients without scram. As a prudent course, to further reduce the risk from anticipated transient without scram events during che interim period before completing the plant modifications determined by the Commission to be necessary, we recuire that the following stees be taken:
- 1. An emergency operating procedure should be developed event,
) for an anticipated transient without scra 4
-wee,-, .--i*M*
-l-
. including consideration of scram indicators, rod position indicatorse average power range flux monitorse reactor vessel level and pressure indicators, relief valve and isolation valve indicators, and containment temperaturee pressure and radiation indicators. The emergency operating procedures should be sufficientty simple and unambiguous to permit prompt operator recognition of an anticipated transient without scram event.
- 2. The emergency operating procedure should describe actions t.o be taken ,in the event of an- ant ic ipa t ed
(} transient without scram including consideration of manually scramming the reactor by using the manual scram buttonse changing the operation mode switch to the shutdown positione tripping'the feeder breakers on the reactor protection system power distribution buses, scramming individual control rocs from the back of the control room panele tripping breakers from plant auxiliary power sourceffeeding the reactor protection systeme and valving out anc bleeding off inst rument air te scram solenoid valves.
i These actions must be taken immediateLy after detestion of an ATWS event. Actions should also I
e l
l i
o l
- () include prompt initiation of the residual heat
! removal system in the suppression pool cooling a-*- '- :-t mode to reduce the severity of the containment conditions and actuation of the standby Licuid control system if a scram cannot I
be made to occur.
'The Shoreham ATWS procedure was reviewed by members of the NRC staff anc contractor personnel from Battetle Pacific Northwest Laboratories (PNL) and comments were
! discussed with the operations personnel. Based on its i
evaluation, the staff concludes that the Shoreham 1 ATWS
~
procedure provides an acceptabte basis for Licensing and I
interim operation of Shoreham Unit 1 pending the outcome of the procesed rulemaking on ATWS in accordance with I General Design Criteria 10, 15, 26, 27) and 29 of 10 CFR 50 Appendix A. The staff has recommended to the Commission that rutemaking be used to determine any future modifications necessary to resolve ATWS concerns and the required schedute for implementation of such modifications.
O 1
- ~ * * ~ _ -
L.
~ . . .
INSERT - PAGE 10 1.C.1 GUIDANCE FOR THE EVALUATION AND DEVELOPMENT OF O - PROCEDURES FOR TRANSIENTS AND ACCIDENTS The positions discussions and conclusion for this TMI-2 i
l item are contained in Section 13.5.2.
I.C.7 NSSS VENDOR REVIEW OF PROCEDURES .
The positioni discussion, and conclusion for this TMI-2 item are contained in Section 13.5.2.
- I.C.8 PILOT MONITORING 0F SELECTED EMERGENCY PROCEDURES FOR NTOL APPLICANTS l .
l The cositione discussion, and conclusion for this TMI-2 f item are contained in Section 13.5.2.
- O l
(:)
1 - - - - - __ _ _
9250
() 1 MS. LETSCHEs Yes, Judge Brenner, there were.
2 I think you referred earlier this morning to some of the 3 discussion about the attachments to it, and the
{
4 introductory memo I think is very pertinent given Mr.
5 Hodges' discussion of the basis for the staff's review, 6 and the basis for its approval of the ATWS procedure was 7 set forth in this memo I believe is what he said. And 8 he also discussed some of the other contents of the 9 introductory memo.
10 I think since there has been testimony that it 11 does reflect the staff 's basis for its approval and it 12 is a staff-generated document, it is appropriate to have f s. 13 it in evidence.
N- 14 JUDGE BRENNERa I do not have any problem with 15 the cover memo because that was asked about, and it 16 would stand for the truth of the matter that at least in 17 the staff's view the ATWS procedore was not fully 18 exercised, and we got the response f rom LILCO. But as 19 to the attachment, I have not compared it. It is, in 20 effect, draft SER input, and it looks very close to what 21 ended up in the SER, if not exact. But if there is 22 something in here inconsistent with that which is in the 23 SER, this should not be moved into evidence without lh 24 questioning of the witness. I do not know what is in 25 here, and nobody has focused on it, and you did not use ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9251
() 1 it for any such purpose.
2 MS. LETSCHEs Well, I did discuss with Mr.
()%)
3 Hodges the fact that it was the draf t SER material. I 4 suppose you are right that I did not go into great 5 detail about it, and I do not have any particular 6 problems with not having the attachment introduced into 7 evidence.
8 JUDGE BRENNER: I guess the proposal then is 9 to move the covering two-page memorandum, which was part 10 of what was marked as Suffolk County Exhibit 37 for 11 identification, into evidence. And if there are no 12 objections, we could call that Suffolk County Exhibit 13 37A in evidence and mark the attachment, which is in the C.
14 nature of draft, in fact is draft SER input, reading the 15 title of that first page of the attachment, and mark the 16 attachment Suffolk County Exhibit 37B for identification 17 and bind both documents in together.
18 Is that acceptable to the parties?
l 19 MR. REVELEYa No objection.
l 20 (The document marked f
l l 21 Suffolk County Exhibit l
22 No. 37A for 23 identification was
( 24 received. The document 25 marked Suffolk County O
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 55& 2345 i . . _ - - ____ ..
9252 1 Exhibit 37B for 2 identification was 3 rejected.)
4 JUDGE BRENNER4 Suffolk County Exhibit 38 for 5 identification is the IE Bulletin No. 82-17 on the 6 failure of 76-185 control rods to fully insert during a 7 scram at a BWR. That was the Browns Ferry event. The 8 document was used in cross examina tion. I would propose 9 to just bind it in for identification so that the 10 questions asked can be meaningful in context.
11 MS. LETSCHEa I think that would be 12 satisfactory, Judge Brenner.
g 13 JUDGE BRENNER: All right. Let us do that.
k,'
14 (Exhibit 38 follovss) 15 16 17 l 18 l
19 20 21 22 23 24 v
25 ALDERSON REPORTING COMPANY, INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
~
& - ' ENCLOSURE 1
{".
~
SC W 3 Y L n L** 4 SSINS No.: 6820 Accession No.:
8005050076 UNITED STATES O'
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
! ?
6 i
JULY 3, 1980 IE BULLETIN NO. 80-17 FAILURE OF 76 0F 185 CONTROL RODS TO FULLY INSERT DURING A SCRAM AT A BWR Description of Circumstances:
On June 28,1980, 76 of the 185 control rods failed to fully insert during a routine shutdown at TVA's Browns Ferry Unit No. 3 located at Athens, Al ab;.aa. The reactor was manually scrammed from about 30 percent power in accordance with routine shutdown procedures. The shutdown was initiated to repair the feedwater system. The 76 control rods that failed to fully insert were all on the east side of the core.
Following scram discharge volume (SDV) high level bypass and a short drain O verioe of the-50v. e secoae meneel screm wes 4nttietee ene eli vertieliy inserted rods were observed to drive inward, but 59 remained partially withdrawn. A third manual scram was made, again following high level in the 50V and bypassing for another short drain of the SDV, with the result that
- 47 rods remained partially withdrawn. Follosing a longer drain of the 50V, an automatic scram occurred that was initiatec by a scram discharge volume tank high water level signal when the scram reset switch was placed
! in " Normal"; with this scram all remaining rods fully inserted. The total time elapse from the initial scram to the time that all rods were inserted was approximately 15 minutes. Core coolant flow, temperature and pressure
! remained normal for plant conditions. The unit is now shutdown and additional testing indicates that a possible cause of the malfunction was the retention of a significant amount of water in the east bank scram discharge volume. In view of these interim findings and pending results of continued investigation, the following actions are to be taken.
L Actions To Be Taken Ey Licensees:
1 All General Electric Boil,ing Water Reactors with operating licenses which f- are operating at any power on the date of this Bulletin shall perform the
( following steps in the time stated. Those that are presently shutdcwn shall perform the follosing steps prior to operating at poser.
- 1. Within 3 davs from the date of this Bulletir., perform surveillance test s to ve'ri fy that there is no sicnificant amount of water in :ne Scram
' Discharge Voluhe (50V) and associatec ;iping anc that tr.e 50V vent vaives l
are operable anc vent system is free of cbstruction. -
h/N L = w 10 L
y -
- " ^ '
IE Bulletin No. 80-17 July 3, Ic80 -
. Page 2 of 4 h
- 2. Within the next 20 days, perform one manual and one estematic scram in
. that order at normal operating temperature and pressure and with more than 50 percent of the rods fully withdrawn, and obtain the following
- information on each scram
a) All rod insert times and as many indiviltua; rod scram times as practicable.
b) Voltage at the scram solenoid valve 60ses to verify that these ,
solenoids are de energized upon receipt of scram signal.
c) Verify that scram valve air is relieved through the backup valves and that the backup valves are fully open and remain open during the presence of a scram signal.
t Measure fill time of the instrument volume from scram initiation d) to closure of the scram instrument volume high level alarm switch, to closure of the rod withdraw block switch on the instrument volume and to the closure of the scram instrument volume reactor scram switch.
e) Measure vent and drain valves opening and closing times utilizing Thi's7easurement may be made Q the valve stem mounted switches.
independent of the scrams.
i H- f) Measure the delay time from scram initiation to closure of the SDV vent and drain valves utilizing the stem mounted position switches, g) Sample water from the instrument vglume discharge after each scram for pcrticulates.
h) Measure the time to drain the SDV down to a repeatable reference level.
i) Monitor the SDV and associated piping for residual water.
j) Verify that the ten (10) second delay on scram reset is functioning properly to prevent resets of momentary scram signals.
k) Compare the results of the two sets of data taken above with each other and with gny previously obtained data, i 3. At the conclusion of the scram tests and all other scrams, verify tha't l all vent lines on the 50V are functional. Verify that there is no
[
significant amount of water in the SDV and associatec piping.
i
- 4. Within 10 days, complete a review of emergency operating cro:ecures oy the licensee and the N555 vendor to assure that, for scram, operator actions include:
IE Bulletin No. 80-17 July 3,.1980 Page 3 of 4 i
a) Place the reactor mode switch in a position other.than RUN.
L') Determine whether either of the two concitions below exist:
(1) Five (5) or more adjacent rods not inserted below the 06 position.
(2) Thirty (30) or more rods not inse'! teL below the 06 position.
c) If either condition 4;b.(1) or 4.b.(2) exists:
(1) Trip the recirculation pumps.
(2) Insert rods manually. If rods cannot be inserted manually, alternately reset the RPS and scram the reactor until all rods are fully inserted.
(3) Vent the scram air header.
(4) Manually open or bypass the scram instrument volume drain and vent valves, if possible.
d) If, at any time, either condition 4.b.(1) or 4.b.(2) exists and either RPV water level cannot be maintained or suppression pool water temperature cannot be maintained below the suppression pool water temperature scram limit, initiate the SLC5.
4 Review the Browns Ferry occurrence with-all licensed operators and
(} e) train them in the procedures to recognize and mitigate the event.
Verify that preliminary training of operators is completed within 10 days of the date of this Sulletin and that full training is completed within 30 days of the date of this Bulletin.
- 5. Review and develop surveillance procedures such that scram discharge volume j
is monitored daily for residue water for 6 days and, if results are acceptable the interval may be extended to 7 days.
- 6. In order to mitigate the consequences of an ATWS event, enhanced operability-of HPCI, RCIC, SLCS, RPT/RHR/ pool cooling and main steam bypass is essential.
Accordingly, the following actions are requested:
l a) prompt notification (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) of any of the above systems when it is less than fully operable and when it is restored to service.
Operability of both pumps in the SLCS is reouired for full operability.
Surveillance tests and preventive maintenance less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> neec not be reported. ,
' () b)' Operate all the available suporession pool cooling whenever the suppression pool exceeds the normal operating temperature limit.
! c) Perform a 50.59 review to increasa SLCS flow to the maxioum consistent with safety (2 purps, uniess unsafe).
IE Bulletin No. 80-17 July 3, 1980 '
Page 4 of 4
- 7. For plants without ATWS related RPT, perform an analysis of th'e net safety of derating such that, in the event of an ATWS, calcula.ed peak pressures do not exceed the service Level "C" limit (s/1500 psig) by taking into
() consideration the heat removal capability of safety valves, isolation condenser, bypass to the main condenser and other available heat removal systems. T C
- 8. Report in writing within 5 days of the performance of each of the tests results (except for the daily tests) and the results of your review and incluce a list of all devices which respond as discussed above, actions taken or planned to assure adequate equipment control, and a scnedule for implementation of corrective action. Report in writing within 10 days, the analyses specified by Item 7 above. This information is requested under the provisions of 10 CFR 50.54 (f). Accordingly, you are requested te provice within the time periods specified above, written statements cf the above information signed under oath or affirmation. Reports shall be submitted to the Director of the appropriate NRC Regional Office and a copy shall be forwarded to the NRC Office of Inspection and Enforcement, Division of Reactor Operations Inspection, Washington, DC 20555.
For all boiling water power reactor facilities with a construction permit, this Bulletin is for information only and no written response is required, k-} Approved by Gh0', B180225 (R0'072); clearance exp res 7-31-80. Approval was given under a blanket clearance specifically for identified generic problems.
4 l
I i
i -
l
9253 1 JUDGE BRENNER: Thirty-nine, as stated, is t]
2 already in evidence. Forty is just the cover page of 3 the emergency shutdown emergency procedure as previously 4 identified, procedure number 29.010.01.
5 Do you want to move that in evidence? The 6 identification might be sufficient.
7 MS. LETSCHEs I think probably for 8 identifica tion would be suf ficient f or that procedure.
9 JUDGE BRENNER: So we vill bind it in for 10 convenience, even though it is only an exhibit for 11 identification.
12 (Exhibit 40 follovss) 13 14 15 16 17 18 19 l 20 21 22 23 24 l
25 O
ALDERSON REPORTING COMPANY,INC, 400 V;RGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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2 for identification was the RHR procedure, number 3 23.121.01, or the first ten pages, as I recall. What we 4 can do on that is just bind in the cover page and page 5 8, if you can arrange that for the Reporter. The whole 6 exhibit is in for identification, but the only 7 convenience needed is the cover page and page 8.
8 MS. LETSCHEs I think that is true, Judge 9 Brenner.
10 JUDGE BRENNER Okay. Let us do that. And we 11 will bind those two pages in.
12 (The informa tion ref erred to follovsa )
13 14 15 16 17 18 19 20 21 l
i 22 23 lO 24 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON, D C. 20024 (202) 554-2345
, / /
/d ?L fi/ Ul N, /
l Submittp: . 4
,, -v C g .te-Approved:
(P ent Manager) E- -
E t s, f :A -4 U 20
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rm
%,(/
, SP Number 23.121.01 Revision 1 Date Eff. 10/23/80 TPC TPC TPC RESIDUAL HEAT REMOVAL (RHR) SYSTEM
,-~
k 1.0 PURPOSE I
l To provide detailed instructions to the Station Operating Personnel for the operation of the Residual Heat Removal (RHR) System.
1.0 RESPONSIBILITY The Operating Engineer shall be responsible for insuring the proper implementation of this procedure.
PPF1021.200-6.421
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17 5 " .",2
, C04V-0014 If th2 Condcnsata Trcnsfer Systcm ic to ba
. "r us:d in Standby lecv2 th:s2 valvcs open and ensure that the Condensate Transfer System remains in service for CSS and RHRS.
NOTE: This may slowly increase Suppression Pool level if any flow test valves are leaking; find leaking valve (s) and close tightly.
8.1.2.7 Close Cross connect Line fill valve *04V-0011, 0010A, 0010B. ,
8.1.3 . Standby Status 8.1.3.1 Complete Standby Status Checklist SPF23.121.01-2.
8.1.4 Suppression Pool Cooling The Suppression Pool Cooling mode is manually initiated and consists of a closed loop from and to the suppression pool through the RHRS pumps and heat exchangers. Either one, or both loops can be used for this mode.
A LPCI initiation, either auto or manual, will cause the RRRS to automatically revert to the LPCI mode.
This mode of RHRS will be used to maintain suppression pool temperature within limits whenever cooling is required in the absence of a LPCI injection signal, including when RCIC or HPCI is
(~', in uss (testing or otherwise); in the event temperature approaches
(~s' 95oF during power operation; during use in the Steam Condensing mode and in the event of RPV relief valve operation.
This procedure presumes the RHRS to be initially in Standby Status NOTE: The "A" loop is the preferred loop for this function since it can more readily be " lined up" to reject water to Radwaste (*MOV-050 normally closed).
8.1.4.1 Determine which loop is to be operated. This will depend upon plant conditions, pool temperature and any other concurrent RHRS operational modes.
8.1.4.2 Verify RHR Control Room MOV valve lineup is correct per SPF23.121.01-4B for the loop sel-eted.
~
8.1.4.3 Open heat exchanger Service Water outlet valve IP41*MOV-034A(B) and verify flow on *F1-006A(B).
8.1.4.4 Close the LPCI Injection Valve *MOV-036A(B) and Heat Exchanger Bypass valve *MOV-034A(B).
SP23.121.01 Rev. I 10/23/80 Page 8
l 8.1.4.5 Open Suppression Pool Cooling and Spray Shutoff valve
- MOV-040A(B) (Keylock).
l 8.1.4.6 Start selected RHR pump (s) by placing their C.S. to 1 AUTO-AFTER-START. Verify running current <136 amps / pump.
8.1.4.7 Verify minimum flow valve *MOV-045A(B) open af ter 10 seconds.
l CAUTION: Do not exceed 136 amps / pump during continuous operation.
8.1.4.8 Slowly open Suppression Pool Inlet throttle valve
- MOV-042A(B) to establish desired flow rate. Observe flow increase on *FI-001A(B), that pump current increases and that *MOV-045A(B) closes at ,>400 gpm.
8.1.4.9 If desired, throttle open Suppression Pool Spray
- MOV-041A(B) to give 500 gpm spray. This will reduce airborne activity in the Suppression Pool generated during HPCI, RCIC, or Relief Valve Testing / Operation.
8.1.4.10 Start additional pump (s) as necessary to restore or maintain Suppression Pool temperature less than:
120oF during steam condensing mode 950F during reactor power operation 105oF during testing of ECCS or relief valves (during S power operation)
(d 8.1.5 Return to Standby (from Suppression Pool Cooling)
NOTE: 1) When shutting down Suppression Pool Cooling it is desirable, initially, to reduce the total flow in each loop to less than runout capacity of one pump.
- 2) The following methods prevents draining discharge piping I
and forming air pockets.
l 8.1.5.1 If only one pump is running proceed with Step 8.1.5.3.
With two pumps running (in the same loop): throttle inlet to Suppression Pool *MOV-042A(B) to obtain <7000 i gpm loop flow.
l l 8.1.5.2 Stop one pump by placing its Control Switch to l AUTO-AFTER-STOP and verify pump amps decrease to zero.
l 8.1.5.3 With one pump running, throttle Suppression Pool Inlet l Throttle valve *MOV-042A(B) and Suppression Pool Spray lO Valve *MOV-041A(B) to zero flow (*FI-901A(B)).
Lj 8.1.5.4 As loop flow approaches zero, stop the pump by placing its Control Switch to AUTO-AFTER-STOP and verify amps l
1 SP23.121.01 Rev. I 10/23/80 Page 9 l
l 9255 l l
O 1 MS. LETSCHE: I think we probably also need l 2 page 9, though, because I think the informa tion tha t was 3 referenced continues over on to page 9 of the procedure.
4 JUDGE BRENNER: Okay. With that '
5 representation.
6 I think that takes care of the housekeeping on 7 all of the County's exhibits, is that correct?
8 NS. LETSCHE Yes, Judge Brenner, it is.
9 JUDGE BRENNER: Okay. As discussed before the 10 lunch break, at this point I would like to bind in for 11 convenience a section of the SER, Section 15.3 of the 12 basic SER, which consists of pages 15-6, 15-7, and 15-8.
13 Now, what is being bound in are just -- it is i
14 just that section. In other words, the way the staff 15 has prepared it, all that appears are those portions of 16 the pages I read which comprise part of Section 15.3.
17 So that is bound in at this point.
18 (The information referred to follovsa) 19 .
20 21 22 23 f 24 V
25 O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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15.3 Anticipated Transients Without Scram Anticipated transients without scram (ATWS) are events in which the scram system
, (reactor trip syste=) is postulated to fail to operate as required. This subject has been under generic review by the Commission staff for several years.
In December 1978, Volume 3 of NUREG-0460, " Anticipated Transient Without Scram h for Light Water Reactors," was issued describing the proposed type of plant modifications the staff believes are necessary to reduce the risk from anticipated transients with failure to scram to an acceptable level. The staff issued requests for the industry to supply generic analyses to confirm the ATWS mitigation capability described in Volume 3 of NUREG-0460 and subsequently presented its recommendations on plant modifications to the Commission in September 1980. The Commission will determine required modifications to resolve anticipated transient without scram concerns as well as the required schedule 15-6 m
n
- I for imp'lementation of such modifications. Shoreham is subject to the Commission -
decision in this matter.
It is our expectation that the necessary plant modifications will be implemented -
in one to four years following a Commission decision on anticipated transients
, without scram. As a prudent course, in order to further reduce the risk from
) nticipated transient without scram events during the interim period before l completing the plant modifications determined by the Commission to be necessary, we have required that the following steps be taken:
(1) An emergency operating procedure shoeld be developed for an ATWS event, including consideration of scram indicators, rod position indicators, average power range flux monitors (APRM), reactor vessel level and pres-sure indicators, relief valve and isolation valve indicators, and contain-ment temperature, pressure and radiation indicators. The emergency operating procedures should be sufficiently simple and unambiguous to permit prompt operator recognition of an ATWS event.
(2) The emergency operating procedures should describe actions to be taken in the event of an ATWS including consideration of manually scramming the reactor by using the manual scram buttons, changing the operation mode switch to the shutdown position, stripping the feeder breakers on the reactor protection system power distribution buses, scramming individual control rods from the back of the control room panel, tripping breakers from plant auxiliary power source feeding the reactor protection system, and valving out and bleeding off instrument air to scram solenoid valves.
These actions must be taken immediately after detection of an ATWS event.
Actions should also include prompt initiation of the residual heat removal system in the suppression pool cooling mode to reduce the severity of the containment conditions; and actuation of the standby liquid control system if a scram cannot be made to occur.
Early operator action as described above, in conjunction with the recirculation pump trip, would provide significant protection for some ATWS events, namely those which occur: (1) as a result of common mode failure in the electrical portion of the scram system and some portions of the drive system, and (2) at g low power levels where the existing standby liquid control scram capability is h sufficient to limit the pool temperature rise to an acceptable level.
The applicant agreed to develop emergency procedures for ATWS events. As agreed by the applicant, these procedures will be submitted to the staff for review.
The applicant also agreed to train their operators for proper actions for ATWS '
events as part of the formal training program. A reactor recirculation pump trip system also will be implemented at Shoreham prior to fuel loading, which meets the criteria for an acceptable recirculation pump trip design as specified in Appendix C of Volume 3 of NUREG-0460, " Anticipated Transients Without Scram for Light Water, Reactors."
kInadditionwerequiredtheapplicanttoconformtotheconclusionsoftheeneric study- l on sc of the June 28, 1980 incident at Browns Ferry. This issue is discussed further in Section 4.6. '(l l
1 15-7 '
m
I
' We consider the above interia actions as an acceptable basis for licensing and interim operation of Shoreham based on our understanding of the plant response to anticipated transient without scram events.
. _ _ _ _ _ e O
T e
1 l
9256 JUDGE BRENNERs I think that takes care of the
(]) 1 2 housekeeping matters, and we apologize to the witnesses 3 for making them vsit, but if we do not do these sooner,
(
4 ve sometimes forget about them later. We will go to the 5 staff for its questions.
6 MR. BLACKS The staff has no redirect.
7 JUDGE BRENNER: This would also be your 8 opportunity to ask questions of LILCO witnesses.
9 MR. BLACK: Yes. We have no questions.
10 JUDGE BRENNEas Okay. LILCO.
11 Whereupon, 12 MARVIN W. HODGES 13 LEONARD J. CALONE 14 HARRY T. CARTER l 15 EUGENE C. ECKERT 16 HENRY C. PFEFFERLEN 17 JOHN A. RIGERT l
18 WILLIAM P. SULLIVAN 19 resumed the stand and were further examined and 20 testified as follows:
21 CROSS EXAMINATION ON BEHALF OF LILCO 22 BY MR. REVELEY:
23 0 Mr. Calone, have you thought further about
() 24 25 ways to ensure the immediate availability of the standby liquid control system key in the event the key were ever O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON, C.C. 20024 (202) 554,2345 l ---
9257 to be needed?
(]) 1 2 A (WITNESS CALONE) Yes, I have.
l 3 0 What are your conclusions?
4 A (WITNESS CALONE) We have given further S thought to leaving the key in the switch, and we agree 6 tha t that has the possibility of reducing the time for 7 injection by about 15 to 20 seconds, the difference, 8 versus the key being in some kind of locker. And even 9 with that situation we would still agree that standby 10 liquid control would be injected within one minute of 11 the requirement or of the beginning of the scenario.
12 So we considered if there is any difficulty 13 with the key lock itself, and my understanding of the 4 14 key lock and the experience I have had a t the simulator 15 with similar key locks -- and I cannot say they are 16 identical -- usually indicates that the key itself only 17 needs a quarter of a turn to unlock it. And since a key 18 lock switch is there to ensure inadvertent operation, I j 19 had some concerns that we would not be ensured that the 20 key lock is always in the locked position. There is no 21 indication on top of the key lock that says it is locked 22 or open, locked or unlocked I should say.
23 The other thing is that there are multiple key lllh 24 lock switches within the control room, and all of the 25 other control room locks have their keys in the key p
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() 1 locker; so this would be an exception to the standard 2 rule of requesting a key for the key lock.
3 So what I proposed to do was to incorporate
(
4 several suggestions or comments that were made within 5 the hearings here, and that was to install a breakable 6 glass door on the key locker itself and not to have a 7 second key lock or a separate area for the standby 8 liquid control key, because in a transient situation I 9 would not want an operator to have to fumble and 10 remember which key locker he has to go to. So I would 11 propose using the same key locker, putting a breakable 12 door on the front of it with the appropriate means of
- 13 breaking it nearby, to uniquely color the standby liquid 14 control key so it is readily and easily identifiable, 15 and to incorporate in the key control procedures 16 provisions to ensure proper placement of the keys within 17 the key locker itself and to verify them at some time 18 in te r va l .
19 JUDGE BRENNERs M r. Reveley, let me jump in 20 for a minute. I want to make sure Mr. Calone understood 21 one thing beforehand.
22 After we had made our comments that the Board 23 talked about this briefly, I want to make sure you
() 24 understand that we were not requiring you to make a 25 change. I want to make this clear since you came back O
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() 1 so quickly, much more quickly than we thought you would, 2 and that if you had thought about it and come up with
() 3 4
the conclusion that no change should be made, and given us the reesons as to that. That was a very open option 5 to you to do that. I hope you understood that.
6 WITNESS CALONE: Yes, I understood that, and I 7 believe there were some good points made here about 8 getting into the key locker itself; and I think we 9 should consider that, and I think we have.
10 JUDGE BRENNER: Okay. Because we did not out 11 of ignorance -- we are no; thinking of everything that 12 should maybe thought of -- want to make a situation 13 worse for the sake of some momentary optics. And I hope 14 you appreciate that.
15 WITNESS CALONE: I certainly do.
16 MR. REVELEY: I think it is fair to say, too, 17 Judge Brenner, if as the company investigates 18 implementing the breakable glass front and the uniquely l
19 colored key concept problems arise, we will certainly 20 come back to you.
(
21 JUDGE BRENNER: Okay. You are free to do that.
l 22 MR. REVELEY: Based upon a reasonably lengthy i
23 consideration over the lunch break, these steps seemed
!( ) 24 feasible and desirable.
25 BY MR. REVELEY: (Resuming) l O
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9260
() 1 0 Two questions to Messrs. Eckert and 2 Pfefferlen. Are the location and configuration of the 3 standby liquid control system at Shoreham typical of f"\
V 4 those of other boiling water reactors?
5 A (WITNESS PFEFFERLEN) The location and 6 configuration of the standby liquid control system is, 7 to the best of my knowledge, similar to that of all 8 other boiling water reactors, those that I have seen in 9 actuality and those that I have seen layout drawings of.
10 0 Mr. Eckert, do you agree?
11 A (WITNESS ECKERT) Yes.
12 0 Does the standby liquid control system of any 13 other opera ting boiling water reactor have a flow rate w/ 14 greater than 43 gallons per minute, to your knowledge?
15 A (WITNESS ECKERT) There is no plant with a 16 pump of a flow rate greater than 43, to my knowledge.
17 Q Mr. Carter, after boron is injected, will the 18 water level rise in the Shoreham reactor? Will steps be 19 taken to ensure that it rises?
l 20 A ( WITNESS CARTER) Yes. After the boron has 21 been injected, the boron will rise in the vessel or the 22 operator will take steps to raise the water level in the 23 vessel.
llll 24 MR. REVELEYa That is all I have, Judge 25 Brenner.
l /"N l L.)
l ALDERSoN REPORTING COMPANY,INC, i 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9261 1 JUDGE MORRIS 4 Just on that last one, is there
(~)N
\_ ^
2 a procedure, a step that calls for the operator to do g 3 that, or is it intended to have such?
4 WITNESS CARTER: It is intended for him to do 5 that eventually. Once you go into the shutdown 6 condition you more or less try to get water level back 1
7 to the normal operating range.
N 8 , JUDGE MORRIS: I am not sure I got the 9 answer. Is there a procedure now that calls for that 10 action?
11 WITNESS CARTER 4 I think if yoc go down into x $
12 subsequent actions, yes, sir.
13 BOARD EXAMINATION h)
'As 14 BY JUDGE MORRIS 4 ,
s.
15 0 I have just a few questions for the panel.
16 Focusing on the recire pump trip system, is the system
$7 itself safety grade?
'18 A (WITNESS RIGERT) Yes, it is.
19 Q And that includes the sensors, pressure 20 sensors and water level sensors?
21 A (WITNESS RIGERT) Yes. From the sensors is through the logic to the final brq4kei s everything is s
23 safety grade and redundant.
llll t 24 ,Q On page 17 of your testimony you discuss the 25 level monitoring and scram initiation and scram O \
\_/ s ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9262 l
O 1 discharge volume, and you mention that diversity is 2 achieved. Could you explain to me what the diversity is?
3 A (WITNESS BIGERT) The original level 4 instruments on the scram discharge volume were float 5 switches. Six new switches, six new sensors were added 6 to bring the total up to 12. Of those six new sensors 7 four of them.were differential pressure transmitters.
8 They use a different principle of measurement of water, 9 and are, as a result of that different measurement to principle, they are considered to be diverse.
11 12 13 14 15 16 17 l 18 19 20 21 22 t 23 24 25 O
l l
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9263
() 1 0 Fine. That helps me.
2 We have heard a lot about different draf ts of
} 3 4
operating procedures, and we have heard about the owners' group guidance and I would like to get someone 5 on the panel to kind of summarize the life history of a 6 procedure, and maybe the way to get at this is to first 7 of all assume that there is no owners' group. They are 8 not involved in the procedures writing or reviewing or 9 anything, and just explain to me what the life history 10 is of a procedure in the LILCO organization.
11 A (WITNESS CALONE) Well, in general, we sta.c 12 writing procedures based upon the requirement to have a 13 procedure, and that normally starts out with some draft 14 in letter revision. The letter revision implies that it 15 has not been through the review of our operating 16 committee.
17 0 Back up a little. I want to get into the 18 nitty critty. Who prepares this, and what part of the 19 organization?
i 20 A (WITNESS CALONE) The operating manual is 21 divided up into sections based upon the physical 22 sections in th e plan t. There is maintenance section, an 23 admin section, operating section, reactor engineering, l( ) 24 instruments and controls, health physics, 25 radiochemistry, security, and each of those sections are O
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9264
('s 1 required to write their procedures. Those procedures
\_)
2 are draf ted by the individuals within th a t section.
3 They could be engineers, they could be technicians. The 4 original procedures were mostly Written by engineers.
5 Once they have finished preparing a draft, we have the 6 procedures reviewed both at the plant, and if 7 applicable, at the downtown office, and in some cases, 8 Stone and Webster and General Electric have looked at 9 some of our procedures.
10 After we resolve all comments, we submit the 11 procedure, if they are saf ety related, to the Review of 12 Operating Committee, which we call ROC. All of the 13 members of ROC receive the procedure, and that review, b)
Ns 14 and basically accept or reject it. We have ROC meetings 15 to determine the acceptability of procedures. Once they 16 have been accepted, they become the Rev. O, numerically 17 zero.
18 At that point in time the plant manager signs l
l 19 it and the procedure is now in effect, and that l 20 procedure vill stay in effect until some revision is l
21 made to it based upon --
l l
l 22 O let me stop you for a minute. Af ter it goes l
23 through the review committee --
24 (WITNESS CALONE) Yes, the Review of Operating gggg A 25 Committee.
1 1
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9265
(~T 1 0 It goes directly from ROC to the plant
\)
2 manager?
3 A (WITNESS CALONE) Yes. Once the ROC committee 4 has approved, or approved is really not the right word 5 because the plant manager approves. They recommend to 6 the plant manager that approval be made of that 7 procedure. The plant manager then signs it and gives it 8 his approval, but it is the ROC committee that does the 9 recommending of approval.
10 0 And remind me again what organizations and 11 people constitute the ROC?
12 A (WITNESS CALONE) ROC is made up of the plant 13 manager, the two chief engineers at Shoreham, the chief 14 operating engineer and myself, the chief technical 15 engineer, operations, training, security, admin, health 16 physics, radchem, ICC, maintenance and did I say reactor 17 engin, wring? There is nine people, CA, and the plant l 18 tech support group.
19 Those are the members of ROC.
20 0 Is the plant tech support group located at the 21 plant?
22 A (WITNESS CALONE) Yes, it is.
23 0 Are all of these organizations at the plant?
l llll 24 A (WITNESS CALONE) Yes, they are.
25 0 Is there any review of offsite?
O ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE.. S.W . WASHINGTON, D.C. 20024 (202) 554-2345
9266 1 A (WITNESS CALONE) Review offsite is performed ;
2 as part of the draft re vie w . It is not part of the ROC 3 review. During the present stage, we have review of our 3
\/ 4 startup procedures by both Stone and Webster and General 5 Electric. They have become members, temporary members 6 of ROC to approve the startup procedures. But in a 7 normal operation, if we get down to normal operation 8 situation, it is just the ROC members.
9 O And the procedure is finally approved by the 10 plant manager and receives no further review, is that 11 correct?
12 A (WITNESS CALONE) That is correct. The 13 procedure once approved by the plant manager is then put
( m) s 14 into effect, and then we get into subsequent revisions 15 to procedures due to changes in hardware or philosophy 16 or people come up with better me thods of doing things.
l 17 Anyone can propose a change to a given procedure. It is 18 not restricted to the section that initially instituted 19 the procedure. The guidelines a re any individual at the 20 pla nt , or technically, any individual at all can put in 21 proposed change to a revision.
22 0 And does the revision receive exactly the same 23 treatment as the original procedure in each chain of l
24 approval?
g 25 A (WITNESS CALONE) Basically, yes. It depends ALDERSON AEPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
9267 1 upon the extent of the procedure change. If it is s']}
2 nothing more than a set point change due to equipment
('1 3 change or something like tha t, it would be a minimal
)
4 prereview or draft review but would still require the 5 full ROC review.
6 Now, we talk ROC review, we have to talk 7 safety-related procedures.
8 0 Do you have a committee which has a safety 9 review function, including some of f-site non-LILCO to people?
11 A (WITNESS CALONE) We have in place the ISEG, 12 the Independent Safety Engineering Group which is based 13 out of our Hicksville Nuclear Operating and Support
'sN' )
14 Division but reports directly on site, yes. And th ey 15 review safety.
16 0 Do they review the safety-related procedures, 17 routinely or otherwise?
18 A (WITNESS CALONE) They review safety-related 19 procedures as part of their normal function but not as 20 part of ROC. They would do it in some sequence. They 21 would be putting themselves in reviewing systems 3nd 22 procedures and operator action, and event reports from 23 licensees, LERs, that type of stuff. But they are not t
h 24 members of ROC itself. They have a separate chain that 25 they would report through, through the NOSD, and that
(
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9268
() 1 level would normally come back through the plant 2 manager. The NOSD manager and the plant manager all s 3 have equal level of responsibility.
{d 4 Q Does LILCO use any consultants in reviewing 5 the safe operation for Shoreham, or will they?
6 A (WITNESS C1. LONE) I am trying to think of the 7 name. The NRB, the Nuclear Review Board, which is the 8 offsite safety review board for LILCO, is made up of 9 both LILCO technical experts and industry and laboratory 10 technical people to oversee the operation of the 11 Shoreham plants, yes.
12 Q Does that group meet at a stated interval?
13 A (WITNESS CALONE) Yes, they do.
14 0 Do they raise questions on their own 15 ini tia ti ve , or are questions brought to them?
16 A (WITNESS CALONE) I do not think I can answer l
17 for them. I think the intention is for them to bring up 18 issues and not just solely revie w, but I cannot answer 19 that question for them l
20 0 Have they started operation?
21 A (WITNESS CALONE) Yes, they have started 1
22 several months ago, and I know they are meeting, but I 23 do not attend their meetings.
h 24 0 Okay, now, let's go back to square one and 25 assume that the owners' group exists, the boiling water ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
9269
() 1 reactor owners' group.
2 Is this now a standing group that continues 3 its existence and looks at many things?
4 Maybe the GE people could answer that.
5 A (WITNESS CALONE) Well, there are several, I 6 guess, parts of the owners' group, but I guess someone 7 else should answer that.
8 A (WITNESS RIGERT) Maybe I could explain in 9 general the owners' group. It is made up of a genercl 10 membership which does consist of all BWR ovnars, and 11 than there are many committees. Harry Carter is on the 12 EPG committee, I am on the Reg. Guide 1.97 committee.
13 In general, though, there is a charter life to the whole 14 organization, and they have recently extended the 15 charter ano ther year. Theoretically it will expire I 16 think sometime in '83, and they re-evaluate on an 17 ongoing basis the need to continue the owners' group.
18 It is not a certainty that it will be in existence 19 forever.
20 0 It is essentially task oriented committees 21 within the parent organization?
22 A (WITNESS RIGERT) Exactly.
23 Q Is the committee that either has produced what h 24 we refer to as Rev. 2, I guess, still in existence?
25 A (WITNESS CARTER) Yes, the committee is still l
l l
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9270 l l
() 1 in existence. I think, although I missed the last 2 meweting due to these hearings, I think we are going to (x) 3 take a break in the secondary containment. I think that
'ud 4 is the next issue to be taken up.
5 0 Is the work done, then, on the ATHS procedure 6 guidance?
7 A (WITNESS CARTER) Yes, that work has been 8 done. That is in Revision 2, and that has been 9 submitted to the NRC.
10 0 So no further attention will be paid to that 11 at this time?
12 A (WITNESS C ARTER ) Well, based upon NBC 13 response, no. I think there are still a couple of 14 curves that may have to be generated, a couple of 15 calculations, calculational type procedures that must be 16 generated to support Revision 2, but basically Revision 17 2 has been submitted as it is.
18 0 I guess I will have to keep up the tradition, 19 Mr. Hodges, and ask you a question.
20 (General laughter.)
21 BY JUDGE MORRISa (Resuming) 22 0 Coming back to Wonderland, this scenario of 23 worst case that you were discussing yesterday, we h 24 stopped at the point where the suppression pool 25 temperature was exceeding its upper limit, and I guess i
1 h
(~j l x 1
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9271
() 1 it is at the bottom of page 4 of your testimony that you 2 say that overheating and fuel damage could occur.
3 (WITNESS H0DGES)
(-sg A Yes.
V 4 Q I don't know that you have thought about it, 5 but if you have or if you can extemporize what would be 6 the scenario from there on?
7 A (WITNESS HODGES) There are several 8 possibilities, but the problem being that if you lost 9 the injection from your normal systems you are going to 10 be injecting because of the high temperatures, you have 11 to go and supply injection from alternate systems.
12 Now, you can, for example, inject water into 13 the core using the service water system, but now you 14 have to worry about problems of diluting the boron. So 15 I have not really given a lot of thought beyond tha t 16 point as to exactly how it would proceed, and a lot of 17 it depends upon the operator's response and whether some 18 of the systems are still remaining to work at these high 19 tem pe ra ture s , If you assume that nothing works in there 20 because of the high suppression pool temperatures, then 21 you are forced to go to something like the service water 22 system.
23 If you can get a HPSI or a RCSI or even one of h 24 your low pressure systems to operate properly still, 25 then you will probably ride through the transient O
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9272
() 1 satisfactorily. If you have a low pressure system 2 coming off the suppression pool and you have to
~N s 3 (d 4 depressurize to get to it, the depressurization while it is going on in itself will reduce power because it will 5 increase the void if you don't have all of your boron in 6 yet, once you get down, you've got cooler water, and so 7 you have got to worry about a temporary increase in 8 power just because the water is colder until you can get 9 enough boron in there to compensate for it.
10 So it is a very complex issue at this point, 11 and no one has investigated all of the possibilities.
12 0 Well, I recognize we are way out on the 13 probability curve or line, whatever you want to call it, 9 14 but I was trying to get some feeling for a time scale 15 that you would have, f or example, to make a decision on 16 putting raw water in the core.
17 A (WITNESS H0DGES) I think you can cull it out 18 on a time scale. We are talking about a half an hour or 19 so to get up to these high temperatures, and then some l 20 additional time. When I am saying a half an hour, it 21 may be 45 minutes or an hour. These are very rough 22 numbers, but it is definitely not in the 10 minute 23 timeframe. So you have a fairly long time before you gh 24 sta rt getting to the point where there may be a 25 problem. You may actually be out in a period of several
(
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
I 9273 gm l (,) 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before you really realize a problem, and by 2 realize I mean start to get fuel damage, and not l
3 actually recognize but actually start to get the fuel
[~~')N 4 damage. So it is a very drawn out problem, and so there 5 is plenty of time for the operator to take other types 6 of actions.
l 7 0 What did you have in your mind when you used 8 " fuel damage" just now? The onset of clad melt, for 9 example?
10 A (WITNESS H0DGES) Yes.
11 I can imagine in this very, very worst case, 12 that if you uncovered enough, that you would hea t it up 13 some and maybe melted some cladding. At worst you have 14 got it a little bit hot, and you then put the cold 15 water, so there may be some cracking, those types of
- 16 things for this very extreme case. '
17 JUDGE MORRIS: I am so far out on that curve i
18 that I don't know where to go next, so I guess I will 19 stop.
20 That is all I have at this time.
21 BY JUDGE CARPENTER:
22 0 Staying out on the curve where Judge Morris 23 just was, I would like to get a little help with some 24 s pecula tion s that were stimulated by the testimony that l 25 we received some time ago, and it had to do with the 1
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9274
() 1 standby liquid control system, and I was aware that we 2 were going to talk about it again and that there might
~s 3 he a different set of witnesses available for me to ask g
{V 4 questions of, so I delayed asking my questions at that 5 time until you gentlemen appeared.
6 First of all, are there panel members that are 7 quite familiar with the standby liquid control system at 8 Shoreham, quite knowledgeable about the design and the 9 procedures?
10 A (WITNESS CALONE) I think we are quite 11 knowledgeable on the procedures from a plant staff point 12 of view and the general layout of it. If you get into 13 the design you would have to talk to some of the other 14 people on the panel.
15 0 I could have asked to look at a lot of 16 documents and drawings and I chose not to, and I just 17 wanted to be sure that my impression that you are 18 probably the right people to talk to, and remember, I am 19 not allowed to talk to you except on the record, so my 20 exploration here is just in that spirit.
21 In the hearing on June 15, 1982, on page 160 22 of the prefiled testimony which is bound into the 23 transcript for that day, which was the combined h 24 testimony of -- and to be brief, I will use last 25 names -- Burns, Dave, Garibarian, Bianni -- I will just O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9275 O ' ser et 1 - 1 taiax ta t 1= eaousa to iaeatirr it- rt 2 is the testimony with respect to Contention 7B. Would p 3 you confirm for me that the bottom line, the last line V
4 on page 160 reads "The tank solution contents, 5 concentration and temperature are monitored at least 6 once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the Shoreham 7 proposed technical specifications 4.1.5 (see attachment 8 8)."
9 Can you confirm for me that it is planned to 10 monitor? I presume the contents refers to the volume of 11 liquid in the tank , the concentration of the boron salt 12 in the temperature each 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
13 A (WITNESS CALONE) The present NRC submitted O 14 tech specs for Shoreham indicate that at least once per 15 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> tha t the temperature of the sodium pentaborate 16 solution is monitoret or verified. The available volume 17 of sodium pentaborate solution is checked, and the heat 18 tracing circuit is operable as determined by the 19 tem pe ra ture of the pump suction piping to be greater 20 than some level. Those are the three items that we 21 currently have committed in the technical specification 22 for the standby liquid control system.
23 0 So the sentence as written is in error?
f 24 A (WITNESS CALONE) As I recall, it is. I am 25 t rying to locate exactly where it is that we do the O
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l 9276 l l
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() 1 concentration. The concentration check is made once 1
2 every 31 days to determine whether the available weight fy 3 of sodium pentaborate is greater than or equal to 42-46 1 V
4 pounds and the concentration of boron in solution is 5 within the limits of the technical specifications. And 6 so the actual concentration verification is done every 7 31 days.
8 The testimony probably should have said the 9 amount of sodium pentaborate in the tank is verified 10 every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and not the amount of boron or chemical.
11 The tank level is basically verified.
12 0 The volume of liquid and not the co; position?
13 A (WITNESS CALONE) That is correct.
9 14 Q So to come back to my question, you would 15 agree that the statement is in error.
16 I am looking simply for a yes or no.
17 A (WITNESS CALONE) I would say that we do not 18 measure the concentration at that point in time. We 19 measure the content and we take a look at the 20 temperature, but certainly not concentration 21 0 In Attachment 8, which is also in tha t same 22 transcript volume --
23 A (WITNESS CALONE) Do you have a page number?
(O ,) 24 0 It is perhaps three quarters of an inch l
25 farther along. It is very awkward, the pages are.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
9277 1 These are just simply bo6nd in documents, so the pages 2 keep skipping along. If you skip along you will come to 3 a series of attachments, and you are looking for 4 Attachment 8. It is 3/41-20 when you get to it in 5 Attachment 8 but first of all you have to find 6 Attachment 8.
7 A (WITNESS CALONE) We have gotten to Attachment 8 2 so far.
9 0 Well, you are a half an inch along the way.
10 (Pause) 11 A (WITNESS CALONE) If you can give us the 12 reference again, we vill check it.
13 0 3/41-20.
O 14 A (WITNESS CALONE) Okay.
15 16 17 18 19 20 21 22 23 24 25 O
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() 1 0 You see at the top of that page it says at 2 least once per 31 days. Item 3, tha t is, headed Item B,
[V '} 3 at least once per 31 days; and Item 3 is just in 4 conformance with your previous statement.
5 A (WITNESS CALONE) That is correct.
6 0 It is here, but there is an inconsistency in 7 the transcript between the testimony by the GE witness 8 and these tech specs.
9 Now, I would like to explore with you whether 10 it has any possible significance, acknowledging I am nov 11 out on the very, very low probability area, that the 12 tank might get cold. If it got to 40 degrees or 13 something, over two tons of sodium pentaborate in the 14 tank that are soluble at 70 degrees, if the tempera ture 15 dropped to 40, roughly half -- and the precise magnitude 16 of numbers is not important, whether it is 4,434 pounds, 17 it is roughly two tons -- about half of it might come 18 out of solution. I am not familiar with the chemistry 19 of this ma te rial.
20 I do not know what its crystalline form is, t 21 whe ther it tends to grow in very large crystals or a I 22 big, amorphous mass. What I am coming on to is this 23 extreme bounding event now of about a ton of solid
,f e"S t ,/ 24 a ppea rin g in the bottom of th e tank. And the reason I 25 think you are the appropriate people to help me with ALDERSON REPORTING COMPANY. INC.
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l l
() I this, in the procedures are people specifically alerted 2 to that fact?
/~S3 3 I do not have any feel for whether the bubbler )
4 goes to the bottom of the tank. I do not have any feel 5 as to whether the discharge line is sufficiently 6 elevated to be high enough so that you could put a ton 7 of solids and not pull any solids into the pump. So I 8 am letting my imagination, as I say, go way to the tail 9 of the curve; but I wanted to resolve it if I could.
10 A (WITNESS CALONE) Okay. Your first assumption 11 is that the temperature has dropped to 40 degrees.
12 0 Right.
13 A (WITNESS CALONE) The tank itself is monitored 14 for temperature, and there is a control room alarm that 15 would indica te when the temperature got to 70 degrees, 16 so there is some warning or indication to the operator 17 that he has hit 70 degrees. A tank of that volume 18 normally operating above 70, between 70 and 80 degrees, 19 if y'ou cut off the heaters to that tank without making a 20 quick calculation, and if we follow the tech specs that 21 say we have to go up there and walk by it at least once 22 every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, assuming the failure of the alarm to 23 work, I do not think the temperature would get very f ar
/ 24 below and get to the point of being a very low (s) 25 temperature problem, because there is a normal O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
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() 1 inspection anyway every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2 But getting back to the subsequent part of
("Ns 3 your question, the operator is aware.
4 0 Well, let me stop you righ t th e re . What 5 instructions are given to the man with the thermometer?
6 What does he do if he discovers the temperature is below 7 65?
8 A (WITNESS CALONE) That is a tech spec 9 surveillance requirement which means there is paperwork 10 associated with doing that. All our surveillances 11 indicate that if you do not find the appropriate number, 12 size, whatever, you do not satisfactorily complete the 13 surveillance, in this case because of low temperature, 9 14 you are to notify the watch engineer immediately, and 15 the watch engineer is the lead shift supervisor of the 16 operators in the control room, and he would take steps.
17 Q Now we are getting right at my question. Do 18 you feel that individual has been instructed that that 19 condition is a viola tion of the tech spec, that the 20 standby liquid control system shall be operable? Does 21 he understand tha t ? Is it clear in the instructions?
22 A (WITNESS CALONE) He would be aware of the 23 fact that he is in a technical specification position,
() 24 25 and he would have to get that remedied.
limiting condition of operation would apply.
Otherwise, the
(-)N ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9281
() 1 0 That is really what I was getting at.
2 A (WITNESS CALONE) And the other thing I was 3 going to say is that the operators in general are taught
(~N
'v) 4 the characteristics in general of sodium pentaborate and 5 that it does precipitate out at low temperatures, and 6 that is why the tank temperature is maintained at a high 7 level, to avoid crystalline formations within the tank.
8 (Panel of witnesses conferring.)
9 A (WITNESS CALONE) Another point was made tha t 10 the surveillance sheets themselves have the upper and 11 lower allowable limits, so when the individual takes his 12 temperature and sticks it in there, he knows whether he 13 is in within range.
O 14 Q Back in the contention the concern was that 15 things like heaters were not safety grade, and it is not 16 only heaters but it is a question of safety grade 17 procedures, if you will; that the temperature might be 18 60, and that seems a little low, and maybe I will tell 19 somebody tomorrow. And that is the kind of thing I am 20 concerned about, and I did not want to try to dig 21 through all of the documents to try to see where the 22 flags were.
l l 23 And thank you very much.
( 24 JUDGE BRENNER: I do not know if the parties 25 have anything else. I also want to ask how long the O
t ALDERSON REPORTING COMPANY,INC.
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() 1 examination of Mr. Minor would be if we were to start 2 that. It depends also on w!. ether there are any further 3 questions of this panel. Are there?
4 MS. LETSCHE: I have just a couple, Judge 5 Brenner.
6 MR. REVELEYa As to this panel, too, Judge, 7 obviously we would like to answer any questions that it 8 is possible for them to be asked at this time on 9 Revision 2. We do not relish the prospect of bringing 10 all of these people back, and indeed will look closely 11 for good cause should such a request be made.
12 JUDGE BRENNERs We have, as far as the Board 13 is concerned, we have identified no questions we have.
14 In other words, we are not purposely holding any back.
15 We have made a preliminary review and have none in light 16 of what took place.
17 I do not want to preclude the fact that we I
18 might not after further time to look at it, and that is 19 the very same opportunity I am giving the County.
l 20 MR. REVELEYa We did provide the County with l
21 the list of changes last night.
22 JUDGE BRENNERa I know, and I think we vill l 23 hear them if they want to ask further questions. Now, h 24 if it was an area that we have well focused on, the 25 question will arise why did you not ask the question.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9283
(} 1 If it is an area that we have not, I am not going to 2 hold that they had enough time to review it.
('q 3 And the reason I have not nailed it down any N) 4 better than we have is I have seen no reason given the 5 good faith I have seen on the part of all counsel and on 6 all sides, and this shoe has been on various feet 7 throughout the proceeding, and I have no reason to judge 8 their good faith. And it was not an open-ended 9 invitation. We will see what the reasons are. But I am 10 not going to state that you have now had enough time, so 11 I think we all understand the situation.
12 And Ms. Letsche stated on the record that she 13 made an attempt to go into it, and she did ask some 14 questions pertinent to it. There may be other details 15 in that thick document, however, that she will discover, 16 and if she does, she will tell us why she thinks it is 17 important, and we will consider it.
18 You do not have anything in mind now, Ms.
19 Letsche, do you?
20 MS. LETSCHE: No, Judge Brenner, I do not. I 21 have done the ones that I had gotten into my mind, but I 22 would like, as you said, an opportunity to review it 23 carefully.
24 JUDGE BRENNER: Okay. Let us go now to the (a')
25 County's questions of this panel, and we will see if my ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
9284 other request is moot, but think about it.
(]) 1 2 RECROSS EXAMINATION ON BEHALF OF SUFFOLK COUNTY
("A 3 BY MS. LETSCHE 4 0 Mr. Calone, I am not sure -- maybe I missed it 5 --
I am not sure if I heard the answer to a question 6 that Judge Carpenter asked you, and that is how much --
7 I am not sure if'it was his question -- but how much 8 sodium pentaborate would have to come out of solution in 9 the tank before the discharge point would be blocked?
10 A (WITNESS CALONE) From an operating point of 11 view I cannot answer that. What we have is tech specs 12 that monitor and maintain the temperature in the tank so 13 that the solution does not come out of solution. If it 9 14 does come out of solution because of low temperature, l
15 technically standby liquid control becomes inoperable,
- 16 then there are additional tech specs to govern as to how l
17 long we can operate in that situation. But I cannot 18 answer with any technical assuredness as to what you are 19 looking for there.
20 0 Mr. Eckert, in response to one of Mr.
l 21 Reveley's questions, M r. Reveley asked you if the 22 standby liquid control systems of any other operating l 23 BWRs have a flow rate that is greater than 43 gallons h 24 per minute, and I think your answer was no.
25 Are there any plants that are not yet O
l ALDERSON REPORTING COMPANY,INC, l
400 VIRGINIA AVE., S.W.. WASHINGTON. D.C. 20024 (202) 554-2345
9285 operating but are under construction, BWRs, that have a
(]) 1 2 standby liquid control rate greater than 43 gallons per 3 minute?
V 4 A (WITNESS ECKERT) All of the requisition 5 plants that I am working on also use the 43 gpm pump.
6 Those are the ones tnat are under design and 7 construction also.
8 (Counsel for Suffolt County conferring.)
9 JUDGE BRENNER: I do not know how pertinent to this is, but just to shorten it up, it has been 11 suggested in documents not in evidence by the County 12 that the Limerick plant might be a plant that has a 13 greater flow rate. Was that plant included in your S 14 thoughts when you answered?
15 WITNESS ECKERT What they have been 16 considering is putting in a third 43 gpm pump. Now, the 17 studies that have looked at what the staff rule might 18 lead to migh t lead to parallel operation of these pumps 19 rather than just one at a time, but that would be in the 20 potential automated systems or whatever that might come l
! 21 out of the rules.
22 JUDGE BRENNEBs So the potential would be for 23 three 43 gpm pumps pumping at the same time for a total h 24 combined flow rate of triple 43 gpm?
25 WITNESS ECKERT: I do not know if their design l
! (S)
ALDERSON REPORTING COMPANY,INC,
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(} 1 just kept the third one as a backup or activated it with 2 the other two.
3 JUDGE BRENNER: I am confused as to why we got s
4 into the third. Are they planning to have two pumps 5 pumping at the same time?
6 WITNESS ECKERTs The potential design had two, 7 and they uniquely talked about a third pump essentially 8 as a backup. I do not believe it is activated, but it 9 might. They could design to run all three. I am not 10 sure of that detail.
11 JUDGE BRENNER: Let us back up. When you 12 answered Ms. Letsche's question and said -- when you 13 answered questions both as to the flow rate of existing 14 plants and the flow rate of any proposed plants, and 15 there were two different questions, when you said none t 16 greater than 43 were you just thinking single pump rate l
17 as distinguished from total flow rate?
18 WITNESS ECKERT: Yes. And I am also thinking 19 of the design that exists on all of the plants pre l
l 20 resolution of the rule.
l 21 JUDGE BRENNERs So as to those plants, the l
l 22 total flow rate is 43 gpm because the design is only one
, 23 pump pumping at a time?
l h 24 WITNESS ECKERTs To my knowledge that is 25 correct.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
i 9287 !
() 1 JUDGE BRENNER: Now, what about plants not yet 2 in operation?
3 WITNESS ECKERTa To my knowledge that is still (y~\
4 true. They are exploring what the final resolution 5 might mean, and the y are exploring the capability to 6 activate their pumps together.
7 JUDGE BRENNER: There are no plants where the 8 system has been constructed for a total combined flow 9 rate greater than 43 opm?
10 WITNESS ECKERT: That is correct.
11 JUDGE MORRIS: But do you know whether or not 12 any piping changes were made in the SLC system at 13 Lim erick ?
9 14 WITNESS ECKERT I do not believe any changes 15 have yet been made there to the piping.
16 JUDGE MORRIS Thank you.
17 BY MS. LETSCHE: (Resuming) 18 Q Let me just ask you, Mr . Hodges, if you agree 19 with the answers M r. Eckert gave concerning the design 20 or the flow rates for the SLC systems in other plants 21 under construction.
22 A (WITNESS HODGES) I have heard the discussions 23 about the Limerick plant two-pump system so that they
()
rm 24 25 get to 86 gpm in comparison, not just at the hearing here but also outside of the hea ring. It is being O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
i 9288
{) 2 1 reviewed by one of the individuals in my section.
have not discussed this with him yet, and I have not I l s 3 personally looked at that design, so I do not know what 4 changes actually have been made there.
5 There is one other plant that I am aware of 6 tha t is contemplating going to such a change before the 7 rulemaking, but they are very skittish at this point 8 about making any commitments, and they are not talking 9 very much about it.
10 (Counsel for Suffolk County conferring.)
11 JUDGE BRENNER: Is that an operating plant?
12 WITNESS HODGES No, sir. It is a plan t going 13 through OL review.
I 14 JUDGE BRENNER: Just so the record is clear 15 and to state the obvious, Shoreham was not the plant you 16 had in mind, was it?
17 (Laughter.)
18 WITNESS HODGES: No, it was not.
19 BY MS. LETSCHE: (Resuming) l 20 Q Mr. Hodges, just to wrap this up -- and I 21 might have asked this this morning, and I do not mean to 22 repeat it, but if I did, I am not sure -- assuming that 23 both pumps operated at the Shoreham plant without any
T 24 changes to the piping, can you give us an idea of what
\ /'
25 flow rate would be achieved at Shoreham?
)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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\
() 1 A (WITNESS ODGES) I have not tried to do that 2 calculation, but you have got basically a positive 3 displacement pump, so you would still probably be close
{v~N) 4 to 86 opm. I am reminded you have a relief valve 5 problem as far as the pressure, but I do not know the 6 actual flow. I have not made that calculation.
7 A (WITNESS BIGERT) Can I add to that a couple 8 of points that we have considered? We have looked at s
9 that issue, and I think if you were to literally just 10 change the control circuit right now and make both pumps 11 run, you would probably damage the pumps from loss of
? 12 NPSH, the! relief valve definitely would lift, and it 13 would be hard'to predict how much flow would go to the 9 14 reactor and how much would recirculate back to the pump 15 suction. You could overpressurize the piping.
16 The system is just not designed right now for i 17 it. It is not just a matter of reviring the control i
l 18 switch. It would require new suction piping and new 1
l 19 discharge piping and a new injection poin t in to the 20 reactor.
21 0 Why would you need a new injection point into 22 the reactor?
23 A (WITNESS RIGERT) The existing stand pipe has gh 24 a certain flow rostriction to it tha t has been analyzed
\
25 and found to be a limiting point even if we were to O \
l ALDERSON REPORTING COMPANY,INC,
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1
( )) 1 increase the diameter of the piping. And this is along 2 the lines of the analysis I mentioned yesterday, that we
('s 3 would have to go to a new injection point. The point
()
4 would be, basically be 16 points. We would go in 5 through jet pump instrument lines, and it is a fairly 6 complex system. We might have to go to 16 explosive 7 valves, and if you want those to be redundant, maybe 32 8 explosive valves. You get very concerned about 9 instrument line leakage if you do not use explosive 10 valves and you use some other type of valve. If you 11 have leakage, you can make your jet pump in st rum e n ts 12 inaccurate.
13 This is a very complex subject, and we looked O 14 at it, and it was major enough that it was totally 15 beyond the realm of retrofit at this time.
16 0 I would like to ask I guess Mr. Calone or the 17 panel in general one question about the -- I think it is 18 just one question about what we have been referring to 19 as Rev 2, the emergency procedure guidelines, 20 particularly contingency number 7 in that document, 21 which is on page C.7-1, and this is something we 22 discussed earlier, a difference between this provision 23 which uses the "and" requirement, whereas in the 24 Shoreham procedures the word "or" is used with respect 25 to these various parameters.
O v
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() 1 If the conditions that are in this step C.7-1 2 were incorporated into the Shoreham ATWS emergency 3 procedure, when would the operator actuate the standby
(~Ns V 4 liquid control system? And I guess I would like you to 5 answer with respect to the draft you all prepared this 6 morning, Suffolk County Exhibit 39, or compare it to 7 your answers this morning.
8 (Panel of witnesses conferring.)
9 JUDGE BRENNER: Ms. Letsche, this is not even 10 an exhibit for identification. If this is the only.
11 question on it, maybe you can just read the steps. Now, 12 if you have a lot of other questions, we will make it an 13 exhibit, but it is up to you.
14 MS. LETSCH Ea At this point I do not think I 15 am going to have an extensive line of questions on it, 16 Judge Brenner, so I will take your succestion.
17 JUDGE BRENNERs Why do you not read the steps 18 in now then while they are conferring?
19 MS. LETSCHEt The step I am referring to is 20 number C.7-1. "If4 reactor power is above (3 percent 21 (APRM downscale trip)] or cannot be determined, and 22 suppression pool temperature is above [110 degrees 23 Firenheit (boron injection initiation temperature)], and
('
U) 24 either an SRV is open or opens or dry well pressure is 25 above [2.0 psig (high dry well pressure scram set ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
9292
() 1 point)), lower RPV water level by terminating and 2 p re ve n ting all injection into the RPV except from boron 3 injection systems and CRD until eithers reactor power 4 drops belov [3 percent (APRM downscale trip)], or RPV 5 water level reaches [-164 inches (top of active f uel)) ,
6 or all SRVs remain closed and dry well pressure remains 7 belov [2.0 psig (high dry well pressure scram set 8 point)]."
9 WITNESS CALONE: I will not ask you to repeat 10 the question.
11 (Laughter.)
12 WITNESS CALONEs I think basically you want to 13 know under the new guidelines, if they were incorporated 14 into Shoreham, when would we inject standby liquid 15 control.
16 BY MS. LETSCHEs (Resuming) 17 0 That is right.
18 A (WITNESS CALONE) Based upon your scenario and 19 the guidelines, we would be injecting standby liquid 20 con trol at a pproximately one minute. It is at that time 21 that we have reached 110 degrees in the pool, and we 22 have greater than 6 percent power. Under the new 23 guidelines, if they are incorporated, we would use the h 24 new guidelines.
25 (Counsel f or Suf f olk County confe rring. )
(
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9293
([) 1 JUDGE BRENNER: Let us go off the record for a 2 min ute .
3 (Discussion off the record.)
4 MS. LETSCHEa Judge Brenner, I do not think I 5 have any additional questions at this point.
6 JUDGE BRENNEPs Any other questions of this 7 panel?
8 MR. REVELEYa We have none, Judge.
9 JUDGE BRENNERs Staff?
10 MR. BLACKS We have none.
11 (Board conferring.)
12 JUDGE BRENNER: Well, the time has finally 13 come for all of you on this issue. In any event, we 14 thank all of you for your patience.
15 Mr. Sullivan, I want to caution you not to 16 extrapolate the data from this appearance here into a 17 probabilistic conclusion as to the likelihood of persons 18 with ycur expertise being asked ques tions a t this 19 hearing.
20 (Laughter.)
21 Because that has not been the experience in 22 other contexts. But thank you all very much.
23 Mr. Hodges, thank you again, and we will see 24 you again.
25 (The panel of witnesses was excused. )
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() 1 MR. REVELEY Judge, we have Mr. Irwin here 1 2 who would like to say something about SRVs for a moment.
r 3 JUDGE BRENNER All righ t. We have the U)' 4 filing. I do not know if you need say anything else.
5 MR. IRWIN: I just have some scheduling 6 information, Judge.
7 (Pause.)
8 MR. IRWIN: Thank you, Judge.
9 Over the lunch break I gave to the Board, the 10 parties, and the Reporter LILCO's response to Board 11 request of August 3, 1982 for SRV record references. I 12 think that the document speaks for itself, and it simply 13 tries to answer the Board's request for record 14 references as of Tuesday.
15 There were two other pending requests from the 16 Board for further information on SRVs. One was your 17 request, Judge Brenner, for a description of in service 18 maintenance, testing and surveillance procedures which 19 LILCO will use, pa rticularly with respect to cleanliness 20 and other kinds of operability functions of SRVs. We 21 have collected those procedures and expect to prepare a 22 brief narrative relating them to one another, and we 23 propose to file it on or before about August 17th. That h 24 is a week f rom next Tuesday. If possible we will get it 25 in before then. We just have vacation schedules and O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE.. S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9295 ,
1 1
0 cooraiaatioa to orx out-2 JUDGE BRENNER That will be perfectly 3 acceptable. In fact, two out of three Board members v
4 will not be able to act on it before then. But if you 5 can beat that date, fine, but do not knock yourself out 6 doing it.
7 MR. IRWINs Fine. I was thinking particularly 8 of the matter of notice to other parties, and if there 9 are any questions, I would like to try to get them taken 10 care of quite soon after the resumption of the 11 hea rings. Mr. Boseman, who will be involved in that, 12 has apparently a longstanding personal commitment, 13 namely his annual leave, which begins on August 27 from 14 the West Coast, and he would like to be home on August 15 26; therefore, that leaves us August 24 and 25 during 16 which he will be free. This is one of the reasons I am 17 trying to get the filings in early.
18 19 20 21 22 23 A
24 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9296 O 1 JUDGE BRENNER: All right. Thank you.
V 2 Of course, on the assumption that he is not rx 3 going to be gone for two months, we may have options t 't
\_)
4 also.
5 MR. IRWINs That is true. He will be back 6 late in th e week of September 7, so he could appear as 7 early as the week of September 14. I just simply wanted 8 .to try to wrap it up while it is still f resh in 9 everybody's mind if we could.
10 The remaining item is what Dr. Carpenter 11 sel f-de preca tin gly refers to as his castor oil problem.
12 Mr. Boseman is in the process of finishing up the 13 collection of information from his colleagues at GE with 14 respect not only to castor oil but with respect to all 15 other lubricants used on target rock SRVs by GE and 16 their manufacturer. We would propose to submit that 17 information at the same time as the maintenance 18 infor=: tion.
19 JUDGE BRENNER4 I appreciate your using 20 shorthand here. Recall there are two parts to that.
21 That is the first part, as you stated, and in addition, 22 whether or not any of the substances, including castor 23 oil, that may have proved to be a problem were used on 24 the actual valves to be used at Shoreham.
('v 25 MR. IRWIN: That is correct, Judge Brenner.
(J3 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9297 l
l JUDGE CARPENTERS The question is what is the
{])
1 2 evidence with respect to the possible polymerization.
~x 3 From the sounds of your report, he apparently is doing a (Q 4 pretty comprehensive review in this general area of 5 lubricants and qualifying the lubricants for extended 6 service under the kind of conditions that might be 7 experienced with these valves in a reactor, is tha t 8 correct?
9 MR. IRWIN: That is correct. I instructed him 10 to go a little bit further than the actual scope of your 11 question on the theory tha t one thing tends to lead to 12 another.
13 JUDGE CARPENTER: Well, I don't think I 14 necessarily would have pushed you that direction, but 15 you are prepared. Thank you.
16 MR. IRWIN Yes, we will be. I can also state 17 preliminarily th a t this was not caused by Mr. Boseman's 18 having uncovered any alarming information. He simply is 19 a very thorough fellow and likes to present everything 20 all a t one time.
21 I have just one other basically housekeeping 22 note. I distributed also over the lunch break the 23 complete text of the Southwest Research Institute h 24 report, portions of which have been exerpted into 25 Suffolk Coun ty 's testimony on sa f ety relief valves, and ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, O C. 20024 (202) 554-2345 l
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() 1 three pages of which I realized only during my cross 2 examination had not been part of those exerpts. Those 3 pages were 20, 24 and A-9/A-10.
(x e-N_/
i 4
I do not see any need to introduce this entire report into evidence. It might 5 make a useful exhibit.
6 At the very minimum, I would like those three 7 pages to be marked as an exhibit, but I think it might 8 be more useful just for context for the whole report to 9 be marked as an exhibit.
10 JUDGE BRENNER All right, let's do this. We 11 will mark the whole report as an exhibit, but we won't 12 bind it in as an exhibit for identification. That will 13 be LILCO No. 18.
14 (The document referred to 15 was marked LILCO Exhibit 16 No. 'S for 17 identification.)
18 JUDCE BRENNER: For convenience, let's bind 19 those particular pages that you used into the record at 20 this point, knowing they are part of the larger LILCO 21 Exhibit 18 for identification, if that is acceptable.
I 22 MR. IRWINs Fine, that makes sense, and I will 23 provide the reporter with separate copies of those 1
( 24 pages.
25 (The information ref e rred to, three pages of
)
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i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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25 l l l l ALDERSON REPORTING COMPANY,INC, I' I f 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 _ I
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AN ANALYSIS OF THE RELIABILITY OF LIGHT WATER REACTOR POWER-ACTUATED PRESSURE-RELIEVING VALVES AND SAFETY Q (RELIEF) VALVES AND THEIR COMPONENT PARTS USING THE NUCLEAR PLANT RELIABILITY DATA SYSTEM (NPRDS) 1 FINAL REPORT Sandia National Laboratories Contract No. 616634 SwRI Project No.17 6649 Prepared for Sandia National Laboratories C Albuquerque, New Mexico -
l Prepared by Quality Assurance Systems and Engineering Division l
l November 16,1981 O .
l l n / R SOUTHWEST RESEARCH INSTITUTE 3
ff SAN ANTONIO HOUSTON
These categories compose the Electromatic main-stage internals where vibration-induced wear and loosening of assembled parts have caused mechanical binding and integrity loss of the fluid path required to depressurize the main disc pressure chamber following pilot opening. The categories also include second-stage mechanical binding in the intra-stage linkage and solenoid. Similarly, failure to reclose is principally composed of I.A.l.g., II.A.l.c(3), II.B.1.b., ,,
and II.c.2.f.; and premature open is composed of I.A.l.d, II.A.l.d, and III (pressure switch). The functional-element categories relate interfaces of the valve with its power source, the failure detection instrumentation, and the associated reactor operator actions that would be modeled in a comprehensive fault tree in a given event sequence of a Probabilistic Risk Assessment.
4.3 Target Rock Safety / Relief Valve The failure report sample limited to those reactors which have reported engineering and failure data to NPRDS included 44 failure events reported to NPRDS for the Target Rock three-stage valve. LER reports of nonduplicate events were used to augment these NPRDS failure reports to a total of 120 failure events at identifiable valve positions. . Additionally, three failure W reports for the Target Rock two-stage in-line (Modwl 7367F) valve and nine failure reports from reporting reactors on the Target Rock two-stage Model 7567F with pilot axis perpendicular to the main stage were used. Statistical analysis was not performed, but these two-stage valve failure reports are
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tabulated in Table B-k The reporting resecurs included uresden 2 and 3 (two-stage in-line), Hatch 1, Millstone, Monticello, Pilgrim, Brunswick 1 l
and 2, Peach Botton 2 and 3, Fitzpatrick, and Browns Ferry 1, 2, and 3.
i Selected reliability curves for the three-stage Target Rock valve are presented in Figures 6 and 7. Figure 6 shows the valve reliability consid-ering the total of all failure causes and the reliability of the individual l' The figure shows that the main stage and second stage are highly valve stages.
l l reliable relative to the third stage. The main-stage unreliability was esti-mated with reports in the data set, including latent defects revealed in valve l
castings, " wire-drawn" main seats, galled disc stems, and condensation collect-ing behind the main piston. The second stage unreliability was estimated from ,
l 20
r The original incentive to combina passive safety and active depres- ,
sarization valves in the Target Rock was to reduce the total number of valves M required fcr BWR primary system overpressure protection and system depressuri-zation. This advantage was reduced for plants under construction by recent changes in requirements for relief and safety valve capacities. However, the problem of replacing the combination valves with independent function valves in operating plants has led to a continuing effort to develop either a more reli-able combination valve or procedures to reduce usage factors for depressuriza-tion demand.
The reported data since the recent changeover (given in Table B- 6) are insufficient to be conclusive as to reliability improvement. Communication with the first utility to make the changeover indicates that (1) good seat contact is not maintained on the normally seated spring-loaded second-stage pilot, (2) fluttering of the second-stage occurs because of the design of the stabilizer, whose function is to hold the valve open until reseat pressure is reached, (3) second-stage leaks cause a torus temperature rise to the plant's O teca ic 1 9 ciete==1 11-ie . a (4) 1 e9 1 ere i the aisa e direction causing the valve to actuate from 1 percent to 7 percent over name plate ratings.
As in the case of the Electromatic relief valve, the functional-element classification system provides a basis for categorizing reported failure events. Reliability function estimates made from events in appropriately combined classification categories provide the reliability characteristics of the valve with respect to the valve failure mode corresponding to the combined categories.
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,. . Th3 thrc0-ctcg3 Tcrg t Rock vslva (Figura 3) is ths only one of .
these designs with sufficient service years to be used for reliability ,
. analysis. This valve consists of: l V*
(1) Reverse seated main valve seal with a disc [I.A.I.x(x)(x)]
linked [I.B.1.c(1)d(3)] to a spring-loaded operator
[I.C.I.a.(1)b.(1)c.(1)] actuated by pressure difference controlled by main steam flow through the piston orifice and O the inlet of the second stage.
(2) Reverse seated secondary stage seal with a disc
[II.A.1x(x)(x)] linked [II.B.l.c(1)d(3)] to spring-loaded operators [II.C.1.a.(1)b(1)c(1)] and [II.C.1.a.b(1)c(3)]
linked [II.D.2.a.(1)] to a reverse seated pilot valve seal whose disc is [III. A.1x(x)(x)] linked [III.B.l.c(1)d(3)] to a spring-loaded operator [III.C.1.a.b(3)c(1)] actuated by system pressure or an electrical solenoid actuated air valve.
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9300 1 JUDGE BRENNER: In addition, for convenience, 2 since LILCO's response to Board request of August 3, 3 1982 for SRB record references in ef fect collects the 4 record, perhaps we will bind that in for convenience 5 also at this point.
6 (The informatin referred to follovss) 7 8
9 10 11 12 13 14 15 16 17 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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. LILCO, August 5, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O
\d 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) )
LILCO'S RESPONSE TO BOARD REQUEST OF AUGUST 3, 1982 FOR SRV RECORD REFERENCES At the close of the hearing session on Tuesday, August 3, 1982, the Board requested that LILCO provide it with references from prefiled written testimony, attachments and exhibits, and oral testimony already in the record from LILCO or the Regulatory Staff regarding two matters concerning Safety Relief Valves (SRVs).
The first of these dealt with differences between Two-Stage and Three-Stage Target Rock SRVs, as these differences would relate to the different designs' respective resistance to (A) stuck-open relief valve events (SORVs) and (B) spurious openings. (Tr. 8874 line 24 - 8875 line 20.) References in Part I below respond to this request, and also include record references to basic physical and design differences between the
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4- two valve designs which underlie their performance differences.
The Board's second request was for record references from testimony by either LILCO or Regulatory Staff witnesses which would be responsive to a hypothetical scenario posed by Suffolk O County in which a SRV might be closed then rapidly reopened during operation in the alternate shutdown cooling mode, initiating water flow in a SRV discharge line which might be partially or fully filled with water above the level of the suppression pool. (Tr. 8875 line 21 - 8877 line 1.) The fact-that this condition was not specifically tested for by the BWR Owners' Group was the source of the Suffolk County question. Specifically, the Board requested references to assertions by these witnesses relating to the questions whether (a) the loads expected to be experienced by SRVs and piping under such conditions would be
() bounded by those tested for by the BWR Owners' Group tests; and (b) the consequences of failure either of the SRVs to close or of the associated discharge piping would be bounded by the con-sequences of design basis accidents. The references in Part II below respond to the Board's requests with respect to this hypothetical scenario.
I. Differences Between 2-Stage and 3-Stage Target Rock Safety Relief Valves A. Differences Respecting SORV Events
- 1. Prefiled Testimony and Exhibits
- LILCO Direct Testimony on SRV Challenges (following Tr. 7959 (July 27))
(} Q&A 18-20 (pp. 12-14)
Attachment IV, 88 3.2 (pp. 19-20), 4.3-4.3.1 (pp. 23-24) l
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- FSAR Request 212.51 (following Tr. 8448 (July 29))
- 2. Transcript References July 28:
(]) Tr. 8145 line 15 - 8147 line 15 July 29: Tr. 8498 line 14 - 8499 line 23 B. Differences Respecting Spurious Openings
- 1. Profiled Testimony and Exhibits
- LILCO Direct Testimony on SRV Challenges (following Tr. 7959 (July 27))
Attachment IV, 8 3.3 (pp. 20-22)
- Page entitled "SRV Description" in attachment entitled " Generic Review of BWR Experience (s) with the Target Rock 2-Stage Safety Relief Valve Design Model No. 7567F," attached to Board Notification (following Tr. 7968 (July 27))
- 2. Transcript References O(_/ July 29: Tr. 8471 line 14 - 8472 line 8 8498 line 14 - 8499 line 23 8508 line 14 - 8509 line 7 July 30: Tr. 8655 line 14 - 8656 line 1 C. General Physical Differences (Not Already Referenced) 1, Prefiled Testimony and_Exhibi_ts_
- LILCO Testimony on SRV Challenges (following Tr. 7959 (July 27))
Attachments VI, VII
- LILCO Testimony on SRV Testing (following Tr.
7954 (July 27))
Attachment III at Appendix 4, Q&A 1 II.
- Loads and Potential Consequences Associated-With Hypothetical SRV Cycling A. Relationship of BWR Owners' Group test loads to loads on SRVs and associated piping resulting from the Suffolk County scenario July 30: Tr. 8566-8587, especially pages 8568-8569, 8572, 8574-8580, 8384-8587.
B. Relationship of consequences of events not tested to those of design basis accidents, postulating failure (if of a SRV or its associated discharge piping i July 28: Tr. 8214-8244, especially pages 8215-8217, 8220, 8222-8225, 8227-8228, 8231-8232, 8238-8240 i
Respectfully submitted, ,
LONG ISLAND LIGHTING COMPANY a
e DonYld P. Irwin ~
Hunton & Williams Post Office Box 1535
. Richmond, Virginia 23212 I
()- DATED: August 5, 1982 l
_.. . _ _ _ _ _ . . - ~. . . _ . . _ _ _ . . _ . -
In the Matter of LONG ISLAND LIGilTING COMPANY (Shoreham Nuclcar Power Stapion, Unit 1)
Docket No. 50-322 (OL)
$)
I certify that copics of "LILCO's Response to Board
! Request of August 3, 1982 for SRV Record References" were served upon the following by deposit in the U.S. Mail, first-class postage prepaid, or by hand on August 5, 1982, as indicated by an asterisk:
1 Lawrence Brenner, Esq.* Ilerbert II. Brown, Esq.*
Administrative Judge Lawrence Coe Lanpher, Esq.
Atomic Safety and Licensing Karla J. Letsche, Esq.
Board Panel Kirkpatrick, Lockhart, Ilill, U.S. Nuclear Regulatory Christopher t. Phillips ,
Commission 1900 M Street, N.W.
Washington, D.C. 20555 Washington, D.C. 20036 O or- noter ^ " cris*
Administrative Judge seer terv or the c ==i881 "
U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel 1717 !! Street, N.W.
U.S. Nuclear llegulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel Dr. James II. Carpenter
- U.S. Nuclear Regulatory q Administrative Judge Commission Atomic Safety and Licensing 1717 il Street, N.W.
i Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Marc W. Goldsmith Washington, D.C. 20555 Energy Research Group 400-1 Totten Pond Road Bernard M. Bordenick, Esq.* Waltham, Massachusetts 02154 David A. Repka, Esq.
U.S. Nuclear Regulatory David J. Gilmartin, Esq.
Cornmission Attn: Patricia A. Dempsey, Esq.
1717 11 Street, N.W. County Attorney I
Washington, D.C. 20555 Suffolk County Department of Law Veterans Memorial !!ighway 4
Ilauppauge, New York 11787 l
i I.
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MilB Technical Associates Ralph Shapiro, Esq.
1723 Ilamilton Avenue Cammer and Shapiro, P.C.
Suite K 9 East 40th Street San Jose, California 95125 New York, N.Y. 10016 Stephen B. Latham, Esq. Matthew J. Kelly, Esq.
Twomey, Latham & Shea State of New York 33 West Second Street Department of Public Service P. O. Box 398 3 Empire State Plaza Riverhead, New York 11901 Albany, New York 12223 lloward L. Blau, Esq. Mr. Jay Dunkleberger 217 Newbridge Road New York State Energy Office Ilicksville, New York 11801 Agency Building 2 Empire State Plaza Albany, New York 12223 Donald P. Irwin O
!!unton & Williams P. O. Box 1535 Richmond, Virginia 23212 DATED: August 5, 1982 9301 1
JUDGE BRENNER: As we stated, we didn't get !
2 anything from any other parties yet. If any other m 3 parties have any other record references that they want 4 us to look at -- and this is not argument, and in fact, 5 LILCO filed it, as we intended, it is just record. -
6 references -- feel free to do that by August 17.
7 Now, understand if you do that this doesn't 8 preclude any and all record references in the findings.
9 This is just a quick look for us.
10 HR. IRWIN: I thank you for mentioning that.
11 This is not a warranty that there isn't something else 12 in the record that we just.were not able to pick up in 13 the couple of days available to us.
I v 14 JUDGE BRENNER: We understand.
15 I think, given the time, we just won't bother 16 putting the County's testimony in unless nobody has any 17 questions, and I doubt that is the case.
18 MR. EARLEY: That is not the case.
19 JUDGE BRENNER: As I said, I doubt it, but I ,
20 thought I had better ask so we don't come back after two 21 weeks and find out that tha t was the case.
22 Is there anything else we need to do today?
23 I hope the answer is no.
24 (No response.)
25 JUDGE BRENNER: Okay. The Board has something O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D C. 2002J (202) 554 2345
9302
() 1 we want to do on the record. We want to thank our 2 reporter, Mr. Ray Heer, very much. He is not going to 3 be here when we come back. Depending on his schedule in 4 life and our schedule in life, he may be back again 5 before the end of the proceeding. We have been 6 superpleased with all of the reporters we have had on 7 this case. Anybody who has been using the tr ar.s crip t --
8 and that is most of us -- knows just how'securate this 9 tra nscript has been, and we appreciate that very much.
10 And in addition, I personally appreciate Mr.
11 Heer reminding me of what I am supposed to be doing 12 frequently enough to keep the record straight, and we 13 thank him very much.
14 All right, I expect everybody to come back 15 smiling the morning of August 24 in Haughpaugh at 10:30, 16 and we know you will be working hard over the break, and 17 we also hope you get a little relaxation.
l 18 Thank you.
I l 19 (Whereupon, at 2:10 o' clock p.m., the hearing 20 in the above-entitled matter recessed, to reconvene at 21 10:30 o' clock a.m., August 24, 1982.)
22 23 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
NUCLEAR REGULATORY COMMISSION
- Q This is to certify that the attached proceedings befors the ATOMIC SAFETY AND LICENSING BOARD
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in the ::2at t er o f:. LONG ISLAND LIGHTING COMPANY (.SHOREHAM NUCLEAR POWER SYATION)
- Date of Proceeding: August 5, 1982 Docket flu =ber: 50-322-oL Place of Proceeding: Riverhead, New York were held as herein appears, and. that this is the original transcript thereof for the- file of the Com=1ssion. .
Ray Heer Official Reporter (Typed)
OfficiaY eporter (Signature)
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