ML20062D570
| ML20062D570 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/04/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8208060144 | |
| Download: ML20062D570 (254) | |
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NCCIZAR REGULATORY COMMISSICN WD WTh
) h Mdu a ATOMIC SAFETY AND LICENSING BOARD D
In the Mat::gr cf:
LONG ISLAND LIGHTING COMPANY )
} DOCKET NO. 50-322-OL (Shoreham Nuclear Power Station) )
I DATE: August 4, 1982 pAggg: 8893 thru 9133 AT: Riverhead, New York ,
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8893 O 1 uNITro SrATES Or AMERICA I l 2 NUCLEAR R EGUL ATORY COMMISSICN 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 -- - --
- - - - - - - - - - -x 5 In the Matter of :
6 LONG ISLAND LIGHTIhG CO:"PANY Cocket No. 50-322-OL 7 (Shoreham Nuclear Power Station) 8 -- ----
- - - - - - - - - - -x 9
10 Riverhead County Complex 11 Legislative Hearing Room 12 Riverhead, N.Y. 13 0 14 Tuesday, August 3, 1982 The hearing in the above-entitled matter 15 convened, pursuant to notice, a t 9:05 a.m. 16 BEFORE: 17 LAWRENCE BREXNER, Chairman 18 Administrative Judge 19 20 JAMES CAR""NTER, Member 21 Administrative Judge 22 23 PETER A. MORRIS, Member 24 Administrative Judge 25 O ALDERSON REPORTING COMPANY. INC, 400 VIRGINTA AVE., S W., WASHIM
8094 O ' Artz^8^sces. 2 On behalf of Applicants 3 W. TAYLOR REVELEY III, Esq. 4 ANTHONY F. EARLEY, Esq. , j 5 Hunton & Williams 6 707 East Main Street 7 Richmond, Va. 23212 8 9 On behalf of the Regulatory Staffa ! 10 RICHARD BLACT, Esq. I 11 DAVID A. REPKA, Esq. 12 'Jashin gt on , D.C. l 13 l 14 On behalf cf Suffolk County
'15 KARLA J. LETSCHE, Esq.
16 Kirkpatrick, Lockhart, Hill, , 17 Christopher & Phillips i 18 1900
- Stteet, N.W.
19 Washington, D.C. 20036 20 - 21 22 i {
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23 24 25 O ALDERSON REPORTING COMPANY,INC, l 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8894-A 1 I
; j 1 CONTENTS 2 WITNESSES DIRECT CROSS PEDIRECT RECROSS BOARD William P. Sullivan, 4 John A. Rigert, Leonard J. Calone, 5 Harry T. Carter, Eugene C. Eckert, 6 Henry C. Pfefferlen, Marvin W. Hodges 7
By Mr.- Feveley 8906 8 By Mr. Black 8909 By Ms. Letsche 8911 g By Mr. Peveley 8943 By Ms. Letsche 8964 10 (AFTERNOON SESSION P. 9007) 11 William P. Sullivan, 12 John A. Rigert, 13 Leonard J. Calone, ('} Harry T. Carter, 14 Eugene C. Eckert, Henry C. Pfefferlen, 15 Marvin W. Hodges By Ms. Letsche 9012 17 EXHIBITS 18 Number Identified Received 19 Suffolk County #36 9012 Suffolk County #37 9015 20 Suffolk County #38 9054 21 l MATERIAL BOUND IN TRANSCRIPT PAGE 22 Letter from Mr. Bordenick dated August 2nd, and the ....... 8895 23 County and LILCO reports each dated August 3rd (^\ ( ,/ 24 Suffolk County Exhibit number 36 .......................... 9042 25 RECESSES: Morning - 8959 Noon - 9006 Afternoon - 9082 l r8 l U 1 t l l ALDERSON REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8895 1 P,_ R _0_. C _ E _ E D _ I _ _N_G_E (Vl 2 JUDGE BFENNER: We have a few matters '.e want 3 to take up prior to launching into the County's cross 4 examination of the staff and LILCO witnesses on the next 5 contention, which is ATWS SC 16. 6 The first matter is the status of negotiation 7 on the security issues. We have received and appreciate 8 the three reports filed separately by LILCO, staff, and 9 the County, the staff's report in the form of a letter 10 from Mr. Bordenick dated August 2nd, and the County and 11 LILCO reports each dated August 3rd. I would like to 12 bind those three sta tus reports into the transcript at 13 this point. O 14 [The material referred to follows.) 15 16 17 18 i 19 i ! 20 21 l 22 l 23 A \ 1 l 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345
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- UNITED STATES 8 a NUCLEAR REGULATORY COMMISSION
$ '- t WASHINGTON, D. C. 20555
***** August 2, 1982 0 Lawrence Brenner Esq. Dr. James L. Carpenter Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D.C. 20555
' In the Matter of Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1) ,
Docket No. 50-322 (OL) O
Dear Administrative Judges:
Pursuant to the Board's request (Prehearing Conference Order dated July 27, 1982, at pp. 25-26), the Staff submits this status report concerning the security contentions settlement negotiations. AstheBoardmayknow,representativesofApplicant,SuffolkCounty(SC) and the Staff met at Yaphank, New York on July 28, 1982. It is my understanding, based on telephone conversations, that a listing of attendees.. and general subject areas discussed at the meeting will be set forth in the l respective status reports being filed with the Board by Applicant and SC. As a result of the meeting held last week which was generally broad in scope and not overly lengthy, I am optimistic that there are many issues that can and should be resolved between the Applicant and SC without resorting to j litigation. It is, however, too early in the negotiation process to know i whether all issues can be resolved between the parties. It is diff'icult for Staff at this time to quantify the time frame which O' may be required to conclude the negotiation process. However, I believe
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,~ . r that within the next few weeks the parties should be in a position to provide the Board with a more definitive status report.
Sincerely, ' b% Bernard M. Bordenick N Counsel for NRC Staff cc: Michael S. Miller, Esq. Anthony F. Earley, Jr. , Esq. # O 9 i T O 1 l l l l
LILCO, August 3, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
/)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY Docket No. 50-322 (OL) (Shoreham Nuclear Power Station, ) Unit 1) ) SECURITY STATUS REPORT This report on the status of settlement negotiations en the security contentions is submitted pursuant to the Board's Order of July 27, 1982. Though not a joint report, counsel for () LILCO has discussed the contents of this report with counsel for the County and the Staff. The parties filed their direct testimony on the security contentions on July 20, 1982. Thereafter, on July 28, 1982, a meeting was held at Suffolk County Police Headquarters to dis-i cuss possible settlement of the security contentions. Suffolk County Police Commissioner Donald J. Dilworth, Suffolk County
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Police Inspector Richard Roberts and Michael Miller, Esq. were present on behalf of Suffolk County; Bernard Bordenick, Esq., staff counsel, was present on behalf of the NRC Staff; and James Rivello, Plant Manager, Shoreham Nuclear Power Station, Robert t Reen, Security Director, Shoreham Nuclear Power Station, Brian R. McCaffrey, LILCO's Regulatory Supervisor, Anthony F. Earley, l l ._ _ _ __ _ _ _ . _ . ~ _
Jr. and T. S. Ellis, III were present on behalf of LILCO. The meeting, which lasted over two hours, was very productive. The parties' discussion covered the full range of issues raised by the security contentions and demonstrated, in LILCO's counsel's opinion, broad areas of general agreement on which a comprehen-sive resolution of the security contentions can be based. In particular, issues relating to weapons, communications, joint training and procedures and alarm response procedures may be susceptible to early resolution. Other issues are equally susceptible to resolution, but may require more time. In any event, counsel for LILCO believe a comprehensive settlement must be the goal of all parties because the various security conten-tions are strongly interrelated and constitute, in a real () sense, a seamless web. Consistent with all parties' desire to achieve a compre-hensive resolution of the security contentions, additional meetings and contacts have been arranged and scheduled. Inspector Roberts of the Suffolk County Police and Mr. Reen of LILCO are responsible for ensuring that the appropriate contacts are made. Mr. Bordenick indicated that the Staff security re-viewer would be available to participate in the discussions. Tentatively scheduled meetings include those involving Mr. Reen and the County's police communications specialists and further meetings of the parties during the week of August 9, 1982. O As a result of the July 28, 1982 meeting, counsel for LILCO believe settlement of all the security contentions is a l
l reasonable prospect. While it is doubtful that this can be accomplished by the August 17 reporting date, we believe that very substantial progress on a full settlement can be made and reported to the Board by that date. Respectfully submitted, LONG ISLAND LIGHTING COMPANY
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T . , III Anthor . Earley, Jr. Hunton & Williams Post Office Box 1535 Richmond, Virginia 23212 DATED: August 3, 1982 O O l
s' l t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: Lawrence Brenner, Chairman Dr. James H. Carpenter Dr. Peter A. Morris
)
In the Matter of )
) Docket No. 50-322 0.L.
LONG ISLAND LIGHTING COMPANY )
) (Security Proceeding)
(Shoreham Nuclear Power Station, ) Unit 1) ) August 3, 1982
)
STATUS REPORT OF COUNSEL FOR SUFFOLK COUNTY () This Status Report is submitted by Suffolk County pursuant to the Board's Order of July 27, 1982. While it is not jointly submitted with the NRC Staff and LILCO, the County has discussed this Report with these parties. Representatives of Suffolk County, LILCO and the Staff-met in Yaphank, Long Island, at Suffolk County Police Headquarters, on Wednesday, July 28, 1982 to consider resolution of Suffolk County's security concerns. The County and LILCO had both experts / consultants and counsel present; only counsel was present I for the Staff because its security reviewer had a commitment with fT r' regard to other Commission business. n The July 28th meeting was productive in setting forth . the parties' positions. The parties reviewed and discussed in varying degrees of detail each of the contentions filed by Suffolk 9
County, particularly as these contentions were addressed in the testimony filed on July 20, 1982, with respect to certain matters, such as weapons, communications, screening and selection !~) hs/ procedures and alarn. response procedures, there appears to be a real possibi3ity that LILCO will take specific actions requested by the County which will satisfy the County's concerns. Further meetings are planned at which tine the parties will continue d scussions. There remain certain contentions as to which the parties are in disagreement. The chief contention in this regard is Contention I concerning the number of armed responders. As indicated in the County's testimony on thic matter, the County has very definite views regarding the number of armed responders which are required for LILCO to comply with 10 C.F.R., Section {} 73.55(h) (3) . The County, thus far, has not been presented with any data which, in its view, wou3d lead to a change in that position. There also remains a dispute between LILCO and the County on Contention 7 concerning the location of the SAS. The county emphasizes that, in its view, Contention 1 is integrally related to contention 3 concerning LILCO's failure to prepare adeguately for the design basis threat. Moreover, Contentions 1 and 3 are necessarily related to Contentions 2 and 4 concerning LLEA assistance and guard training. Accordingly, it appears to the County that progress in resolvinc these interrelated ; contentions will be likely only if the parties can first reach agreement on Contentions 1 and 3. Assuming such agreement can be reached, there would then have to be agreement by the parties to training programs in Contentions 2 and 4 that track the content of Contentions 1 and 3. a' Further meetings are planned, and at these meetings the parties will continue discussions on these areas of disagreement. g In the County's view, no prediction can be made at this time regarding the likelihood that these issues can be resolved prior to trial. The Board has requested a further status report by August 17, " setting forth in detail any unresolved issues which remain." While the parties will schedule meetings in order to meet the August 17th deadline to the fullest extent possible, in the County's view that deadline may prove unrealistic in light of the nature of some of the issues to be discussed and considered. I'} Respectfully submitted, Herbert H. Brown Lawrence Coe Lanpher Michael S. Miller KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W. Washington, D.C. 20036 (202) 452-7000 Attorneys for Suffolk County Dated: August 3, 1982 0 m -
{ In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) Docket No. 50-322 (OL) I certify that copies of Status Report of Counsel for Suffolk County were served upon the following by hand, unless otherwise indicated, on August 3 , 1982: Lawrence Brenner, Esq. *Ber na rd M . Bordenick, Esq. Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Anthony F. Earley, Jr., Esq. Hunton & Williams P.O. Box 1535 Dr. Peter A. Morris Richmond, Virginia 23212
,es Administrative Judge
(,) Atomic Safety and Licensing
- Chief, Records Service Branch
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Board Panel U.S. Nuclear Regulatory Division of Technical Information Commission and Document Control Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jam.3 H. Carpenter Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 [' by Michael S. Miller Kirkpatrick, Lockhart, Hill, Christopher & Phillips
"? 1900 M Street, N.w. -
Washington, D.C. 20036 Dated: Aug us t di , 1982 By rail. l
i l l 8896 l l I 1 JUDGE BRENNER: The Board thinks it is fair to (/ *%) 2 characterize the reports as being on the optimistic side 3 in terms of a substantial narrowing, at least, of the 4 issues, although the degree of optimism varies somewha t, 5 and in fact is perhaps less than the party that counts 6 the most when we are assessing the optimism, that is, 7 the intervonor, the County in this case. However, even 8 the County is hopeful of further progress in its report. 9 Based dpon that, we will wait until the next 10 report on August 17. 'de are disturbed a little as to 11 the predictions tha t we may not get much more as soon as 12 August 17. We emphasize to the parties how important 13 this time frame is for us, and while we are not saying t (3
\J unless every single thing is buttoned up by the 17th, we l 14 15 will have to make a decision as to who should hear it, 1
l
- 16 we certainly need to see very tangibly what is lef t in
[ 17 the report on the 17th. l 18 So, we hope that efforts are going to be quite 19 intensive, bearing in mind our time f rame considerations l 20 and not just the time frame for the overall case. It 21 would be most usef ul, in f act, we are going to request, 22 that the August 17 report be a joint one. The three 23 reports were very helpful. We are no t criticizing () 24 them. But we won't have the benefit over that week in which August 17 cccurs of being able to discuss any 25 l
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1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8897 (m) 1 matters with the parties, so the procese of ha ving to 2 file one report, we think, will require the parties to 3 be jointly thorough and careful in the language used, ro 4 we will truly get a focusing on what is left. 5 The type of information contained in the 6 County's report was most useful. That is, an 7 ascertainment of what it is that is left in the 8 dispute. To the extent the kind of detail th a t the 9 parties think would be most helpful to us on August 17 10 in order for us to decide what, if anything, is left 11 will be safeguards information. It might be better, if 12 possible, to somehow divide the report int.o a portion 13 that can be filed in the case and an attachment that , s
- 4 would be safeguards information which can be referenced I
15 in the cover heet. We are not requiring that format. 16 We'are just suggesting that as a possible way to give us l 17 as much detail as you want, and we will take a look at I 18 it on the 17th, and perhaps decide before we have an 19 opportunity to talk with the parties again, perhaps not, 20 but that is why you want to try to tell us everything 21 you think would be helpful to us. 22 Obviously, the narrower the dispute has l l 23 become, the more likely it is that we could defer and give the parties some mora time. It might be helpful, [)/ x-24 25 although we won't require it, that if you de get th ro ugh 1 o ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345
8898 () 1 a very tangible narrow area of that which remains in 2 dispute, if we could get a time estimate on how long it 3 would take to litigate, because we don't want to go back 4 through the testimony on ou r own and try to figure out 5 wha t te stimony might remain appropriate, and we are not 6 asking you to do that precisely, either, but some time 7 estimate, if we are talking about a week, or we are 8 talking about two weeks, that type of thing, and be 9 realistic. The purpose is to help us make a decision, 10 and not to lull us into thinking we can handle it in X 11 amount of time. 12 JUDGE CAPPENTER: Mr. Repka, I would like to 13 add a comment that is perhaps personal, but certainly [D s' 14 not in disagreement with the other members of the 15 Board. I know, first of all, Mr. Bordenick is not here 16 this morning. I would like to express my concern that 17 these meetings speak to a certain extent, in a very 18 limited way, but to a certain extent to the merits of 19 contentions, and as a Board member, I a m ve ry frustrated 20 that the staff expert on security matters has not been 21 available to participate in these meetings. 22 I note in Line 10 in the status report by 23 Suffolk County that the security reviewer had a 24 commitment with regard to other Commission business. I (O) 25 really hope that other business was quite important,
)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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8899 () 1 because as far as I am concerned, personally concerned, 2 it certainly detracted from the effectiveness of this 3 attempt to understand those issues that must be
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4 litigated and those issues which perhaps ca n be 5 resolved. 6 I would also note in the LILCO status report 7 on Page 2, Line 20 reads, "Mr. Bordenick indicated that 8 the staff security reviewer would be available to 9 participate in the discussions." I don't know whether 10 the choice of that verb was deliberate. It seems a 11 little weak to me, " indicated" ra ther than "said." I am 12 trying to make it very clear that in the context of the 13 points that Judge Brenner was just making in terms of 14 trying to resolve what the dimensions of this litigation 15 might be, we feel, and certainly I feel very personally 16 tha t the staff security expert would be very useful to 17 all the parties, and I would hope that the staff would i 18 agree with me that some priority should be given this. l 19 Thank you. 20 JUDGE-BRENNER: Well, it is not personal to 21 Judge Carpen ter. Why wasn 't he there? Do you know? 22 MR. EEPKA: He had a Commission meeting that l 23 day. He was going to be there, but the security [) 24 negotiation conference was up in the air, and the final v 25 day that was finally resolved on just happened to A () ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C 20024 (202) 554 2345
8900 coincide with the expert's Commission meeting. (m_) 1 2 JUDGE BRENNER: All right. Well, tetween now 3 and the 17th, we expect that at least one and probably 4 more meetings are going to have to take place, telephone 5 conferences, whatever. If this isn't a priority for the 6 staff's experts, it better be. 7 MR. REPKA: It certainly is a priority, and he 8 will be there in the future.
.9 JUDGE BRENNER: I don't know who he is, nor do 10 I care at this point. Whatever people need be involved 11 should be, and it migh t be more than one person. I 12 guass the theme is very consistent with what we 13 expressed in the emergency planning context. There is
\ N') 14 an auto parts company that had a rather interesting ad 15 campaign to the gist of, you can pay me now or you can 16 pay me later. The staff experts can spend time in the 17 seetings now or they can spend time at the hearing 18 later, and those are the tradeoffs. I am sure staff 19 counsel knows that, and I am not saying it for your 20 benefit. I am saying it so that you can be reinforced 21 in your message to your experts. 22 MR. REPKA: The experts have that messa ge, and 23 I don't really think it is a problem. It is a one time (O ss) 24 only thing. 25 (Whereupon, the Board conferred.)
/'N N.Y ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8901 s s JUDGE BR ENNER4 All righ t. We would like to, (~-)
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1 1 2 I duess, rule on the County's objections dated August 3 2nd to the prehearing conference order and r.otion for 4 reconsideration or, in the alternativa, for 5 certification to the Commission. This relates to the 6 emergency planning matters ruled upon in our prehearing 7 conference order of Julyf27th, 1982. 8 In part, the Co nty oSjects to and moves us to 9 reconsider our rulings with respect to the Board's to separation of Phase I an'd Phases II issues and its 11 deferral of certain contentions until Phase II of this
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12 proceeding, and also the Board's ruling that discovery 13 is proper on Suffolk County's emergency plan, which has
,73 , *l 14 not,been completed, is not a matter in controversy, and -
l . 15 indeed is not the subject of any 'proferred or admitted s . % 16 contentions. Th'at is the' County's description at Page 2 17 of its motion.
. s 18 And as I say, tha t is only part of its 19 motion. A; 'to those two parts, the request for 20 reconsideration is denied. We have extensively 21 considered the County's arguments at previous 22 conferences and in our previous rulings. The County's s s-23 in s tan t request makes no additional points or arguments, 24 and for that reason, the request is denied.
(a) 25 In addition, the Co t'ryty makes the bare request
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ALDERSoN REPORTING COMPANY,INC, s
~g 400 VIRGINI A AVE., S.W,. WASHINGTON. D.C. 2 % 24 (202) 554-2345
8902 () I that we certify the issues to the Commission. The 2 sta ndards f or certification are no t add ressed by the 3 County. In any event, it is spparent to us that the 4 sta ndards f or certifica tion would not have been mot here 5 in this instance. So, that request is also denied. 6 The County in addition has asked that we 7 reconsider our ruling that EP1 is not admissible at 8 sil. That ruling, you will recall, did not permit an 9 opportunity f or f urther specification of EP 1. We did 10 permit that opportunity with respect to other 11 contentions. In our prehearing conference order of July x 12 27th, we found EP1 to lack pa rticula riza tio n , to be 13 overly brosd, and slso to be, a t least in part, g-N- 14 apparently redundant to the extent we could discern the 15 subject of EP1 with other contentions. 16 We did, incidentally, thoroughly consider the 17 responses, written responses cf the County and the 18 argument of counsel, contrary to the suggestion in the 19 motion f or reconsidera tion that we did not consider 20 those. We did not cite tnem directly, but we certainly 21 did consider them. On reconsideration, we stand by our 22 ruling as to EP1 as it was then pleaded, but we will 23 give the County in essence the other relief it requests, that is, an opportunity as part of the next filing and ('a m) 24 s 25 also as part of the discussions that we have required rN L) ALDERSON REPORTING COMPANY,INC, 400 VIR3lNIA AVE., S W., WASHINGTON. D.C. 20024 (202) 554-2345
8903 () 1 take place among the parties before the next filing an 2 opportunity to respecif y EP1 similar to the opportunity I'N 3 we have permitted further contentions. U 4 The County has begun to specify EF1, 5 particularly at Psges 16 and 17 of its motion for 6 reconsideration. We are not ruling now on whether that 7 is sufficient specificity. In fact, as the parties 8 know, we are insisting tha t contentions demonstrate 9 satisfaction of the requirements of the bases and 10 specificity requirements of the regulation in this area 11 of emergency planning, and I guess I will provide the 12 hint and a little more in a moment that more specificity 13 could still be had with respect to that con tention. 14 In addition, the County and, of course, the 15 other parties should consider whether EP1 as it has 16 begun to be specified and as it may finally be specified 17 by August 20th is redundant to other contentions already 18 pleaded and ruled upon, and whether, consistent with our 19 rulings on other contentions, whether the specified 20 subsections of EP1 are Phase I or Phase II issues. In 21 fact, it is clear to us that at least many of the parts 22 of EP1 are Phase II issues. 23 In the context of specificity, even in the () 24 County's motion for reconsideration, no attempt is made 25 to allege the connection between local conditions, O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASH!NGTON. D.C. 20024 (202) 554-2345
8904 ' () 1 assuming such conditions are adequately specified, which 2 is just that, an assumption. No attempt is made to 3 allege the connection between such local conditions and
)
4 the failure of specific parts of LILCO's plan to meet 5 specific provisions of the emergency planning , 6 regulations. 7 All rioht. That is our ruling on the motion 8 for reconsideration. Judge Carpenter has some comments 9 also. 10 JUDGE CARPENTER: Ms. Letsche, as Judge 11 Brennec indicated yesterday, the Board did not f eel a 12 need for County counsel that was particularly cognizant 13 of these matters to be present today, and I ay not O'. 14 asking for a response to the comments I am about to make 15 today, and I would hope that at least in the week ) i 16 following the break, the County could indicate what sort 17 of response it might like to make. 18 I would like to take particular note of Page 3 l 19 of the objections to the prehearing conference order, 20 and draw attention particularly to the point raised in 21 the last sen tence of the first full paragraph -- I am 22 sorry, the second paragraph, which reads, "The 23 intervening parties noted especially the language of () 24 NUREG-0654, which states at 23, 'An integrated approach 25 to the development,'" and I underline " development" -- O l \_/ l i ALDERSON REPORTING COMPANY,INC, 400 V!RGINI A AVE, S.W, WASHINGTON. D C. 20024 (202) 554 2345
8905 () I that is my emphasis added - "'of the response plans to 2 radiological hazards is most likely to provide the best 3 protection of the health and safety of the public.'" 4 I would like to ask that the Board be informed 5 of the mechanisms that are presently being used to 6 assure that there is an integrated approach to the 7 development. In particular, I am interested to know 8 whether there is a LILCO representative at the meetings 9 in which the County plan is being de veloped , or some 10 other such mechanism. 11 The Board is sitting here in the dark, if you
~12 will, as to what is going on, and so I am taking this 13 just in the spirit as put forth by the County that as 14 outlined in NUPEG-0654, an integrated approach at the 15 development stage is very important, and I just leave 16 that for after the break, and also, to the extent that 17 they are involved at the present time, I would like 18 identification of the FEMA and staff representatives 19 that are contributing to the integrated approach of the 20 development of the plan which represents the best 21 efforts of all parties. That is the way I read the word 22 " integrated."
23 (Whereupon, the Board conferred.) () 24 JUDGE CARPENIER: Judge Brenner suggests perhaps August 20th would be a good time to submit that 25 O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8906 O 1 long with the other filings that are due on that date. 2 MS. LETSCHE: Judge Carpenter, I will pass 3 your comments on to people in */ashincton who are workino 4 on this matter, snd I am sure they will respond. j 5 JUDGE CARPENTER: Thank you. 6 JUDGE BRENNER: All right. Unless there are 7 any further preliminary matters, we can launch ri.cht 8 into the swearin7 of the panel and the cross examina tion 9 by the County. 10 MR. REVELEY: The ATWS witnecses will come 11 forward. 12 (Pause.) 13 Whereupon, 14 WILLIAM P. SULLIVAN, 15 JOHN A. RIGERT, 16 LEONARD J. CALONE, 17 HARRY T. CARTER, i 18 EUGENE C. ECKERT, ! 19 HENRY C. PFEFFERLEN, 20 and MARVIN W. HODGES 21 were called as witnesses, and having been first duly 1 22 sworn, took the stand and were examined and testified as l 23 follows: 24 DIRECT EXAMINATION 05 BEHALF OF LILCO 25 BY MR. 3FVELEY: O ALDERSON REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W., WASHINGTON. O C. 20024 (202) 554-2345
8907 () 1 Q Gentlemen, your prefiled written testimony wa s 2 admitted into evidence yesterday by stipulation. It was 3 admitted with the ccrrections and additions with which 4 you are faniliar. With those corrections and additions, 5 is your prefiled ATWS testimony true and correct so far 6 as you know? 7 A (WITNESS PFEFFERLEN) Yes, it is. 8 A (WITNESS ECKERT) Yes, it is. 9 A ( WITNESS C APTER) Yes, it is. 10 A (WITNESS CALChE) Yes, it is. 11 A (WITNESS RIGERT) Yes, it is. 12 A (WITNESS SULLIVAN) Yes, it is. 13 Q Mr. Calone, do you have a crisp summary of (' N.
\- 14 that testimony?
15 A ( WITiiESS CALONE) Yes, I do. 16 Q Would you give it, please? 17 A (WITNESS CALONE) Our testimony on ATWS, our 18 testimony on anticipated transient without scram 19 demonstratas that Shorensa is well protected against 20 ATWS events pendino the implementation of the NRC's ATWS 21 rulemaking. The Cosimission has already said that it is 22 unlikely that an ATWS would occur in this interim 23 period. .The low probability of an ATWS coupled with the 1 () f~\ 24 interim ATWS messares of EFT emergency operating 25 procedures a nd operator training led the NRC to conclude 1
.n ? h 'r. ./
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON. O C. 20024 (202) 554-2345
8908 () 1 that nuclear power plants can be safely licensed and 2 oparated prior to completion of the rulemaking. 3 In our testimony, we show tha t LILCO has 4 installed the recirculation pump trip feature at 5 Shoreham. RET is a highly reliable means of tripping 6 the recirculation pumps in the event of an ATWS to 7 reduce reactor power rapidly and to control primary 8 system pressure. 9 LILCO has also developed an emergency 10 operating procedure fo r AT'4S. This procedure was 11 developed based upon guidance provided by General 12 Electric. In addition, LILCO has committed to j 13 incorporate future guidance into its operating procedure (~\, NJ 14 when such 7uidance is approved by the PWR owners and th e l l 15 NRC. 1 16 LILCO's training program ensures that licensed 17 operators will promptly and correctly follow the ATWS 18 emergency operating procedure. We believe, however, 19 that prior to learning specific procedures, the operator 20 must have a thorough knowledge and understanding of the 21 design and operation of the systems he will use. In the 22 course of LILCO's extensive training program, operators 23 have received classroom instructions as well as plant es (s j) 24 walkthroughs on ATWS-related subjects. Only after the 25 operators have a thorough knowledge of plant systems are p
\u/
ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
8909 ( ,) I they given training on the ATWS emergency o pe ra ting 2 procedure itself. This training is enhanced further by 3 plant walkthroughs of that procedure. 4 Finally, operstors have been tested on their 5 ability to handle an ATWS in simulator training. In 6 addition to tho interim ATWS measures slied upon by the 7 Commission, LIlCO has taken steps to reduce further the 8 possibility that an electrical or mechanical failure 9 will cause an ATWS. These steps are the installation of 10 alternate rod insertion and improvements to the scram 11 discha rge volume. 12 With the changes just described, we agree with 13 the Commission tha t it is very unlikely tha t an ATWS f' )
14 would occur in the interim period, but if it did, we are 15 confident that Shoreham operators are trained and 16 capable of responding in a rapid and correc t f ashion.
17 That ends my statement. 18 MR. REVELEY: Thank you, Mr. Calone. 19 Judge Brenner, LILCO's ATWS panel is available 20 for cross examination. 21 JUDGE BRENNER: All right. The staff. 22 DIRECT EXAMINATION ON BEHALF OF THE STAFF 23 BY MR. BLACK: s () m 24 0 Mr. Hodges, your testimony has been previously 25 incorporated into the record as if read on August 3rd,
/~x ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W.. WASHINGTON. D C. 20024 (202) 554-2345
8910 () 1 in the transcript of August 3rd, 1982. Do you adopt 2 that as your testimony in this proceeding? 3 A (WITNESS HODGEF) Yes, I do. 4 MR. PLACK: Mr. Chairman, as a preliminary 5 note, I would like to indicate that as the Board is well 6 aware, the staff testimony on ATVS issues took an 7 approach that was different from how evidently the Board 8 viewed the testimony or the contention. We took a very 9 sim plistic a pproarh with respect to the testimony, which 10 basically was that a stand-by liquid control system 11 needed to be added to give reasonable assurance of 12 mitigation of A.TWS events. We are awa re of the Board's 13 comments. (s'D
' 14 JUDGE BRENNER: You mean an automatic standby?
15 MR. BLACKS Excuse me. Automa tic initia ted 16 standby liquid control system. We are aware of the 17 Boa rd 's comments with respect to procedures and 18 training, and we took those to heart, and went back to 19 Bethesda and discussed that, and through those 20 discussions with appropriate staff personnel, we have , 21 determined that Mr. Hodges was indeed the right witness i 22 to address procedures and training that would be 23 applicable for ATWS condition and ev en t s . 24 And with that preliminary remark, I just wish ( 25 to say that Mr. Hodges can be examined on procedures and
/
N_ ALDERSoN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8911 () 1 training, and we think that he will fully respond to the 2 staff position with respect to those items, and with 3 tha t preliminary remark, I submit that r. Hodges is 4 available f or cross exa mina tion as well. 5 JUDGE BRENNEE: Okay. Well, we certainly 6 appreciate that effort, and the parties have heard your 7 comment, and the Board will be guided accordingly also. 8 Thank you. 9 All right. The testimony now, after the fact 10 of it being bound in, has been sworn to, and as I 11 mentioned over the break, I hope the pa rtie s come up 12 with a procedure whereby we can just stipulate 13 everything in, and there are a few ways to do it, and I 14 am sure the parties will come up with something to shave 15 a few minutes off the day. 16 They are all yours, Ms. Letsche. 17 CROSS EXAMINATION ON BEHALF OF SUFFOLK COUNTY 18 BY MS. LETSCHE: 19 0 Mr. Calone, let me begin with you. You 20 indicate in your statement of professional 21 qualifications on Page 24 of your testimony that you 22 have obtained an SRO certification. Have you ever had 23 any actual operating experience? () 24 A (WITNESS C ALONE) During my training 25 assignments at Brown's Ferry, on Page 25 of my resume, O s ALDERSON REPORTING COMPANY,INC, 400 VIRGIMA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
0912 Item F talks about a 30-week field assignment to TVA's (]} 1 2 Brown 's Ferry nucles r plant. At tha t plant I wa s 3 qualified as a nuclear engineer on shift for TVA, and 4 during those 30 weeks I did work in the con trol room 5 with the operators operating at Brown's Ferry 3. i
! 6 Q When was that assignment of yours?
7 A (WITNESS CALONE) It began in June, 1976, and 8 was completed in January, 1977. 9 0 You also indicate in Item H of that listing on 10 Page 25 participation in Brown's Ferry refueling 11 outage. 'ihen was that? 12 A (WITNESS CALONE) That was last summer, during 13 the refueling outaga for Brown's Ferry, Unit 2. 14 Q And what did you do? What was your 15 participation in that? 16 A (WITNESS CALONE) I worked with the outage 17 coordinator in doing the repairs to the plant. I 18 0 Had you participated at all in the preparation 19 of LILCO procedure SP 29.02.01, which is a ttached to 20 your testimony? 21 A (WITNESS CALONE) I am a member of the review 22 committee that would have reviewed that procedure, yes. 23 0 Did you participate in that review?
~T (WITNESS CALONE) Yes, I did.
[Y 24 A , l 25 Q Do you have any involvenent in operator C:) ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
8913 () 1 t ra ining f or the Shoreham opera tors? 2 A ( WITNESS CALONE) Indirectly. I as the chief 3 technical engineer, which is equivalent to assistant 4 plant manager, and therefore I do have management 5 responsibility in training. 6 0 Can you be a little more specific? What is 7 your management responsibility with respect to 8 training? 9 A (WITNESS CALONE) Training associated with 10 technicians under my area of control has -- as a senior 11 management person selected to obtain an SB license, I am 12 in the training program itself. So if you ask from a 13 training aspect at Shoreham, training incorporates more 14 than just operator training. It is involved with the 15 training and organization from a technician point of 16 view. I am involved with the training program itself as 17 a licensed operator. 18 0 Maybe " involvement" was a bad choice of words 19 on my part. Let's talk first about what you do in the 20 operator training program. 21 A (WITNESS CALONE) I am a participant in the 22 operator training program. 23 0- That means you are trained in it? l () 24 A (WITNESS CALONE) Yes. 25 0 You don't do the training of other people? O v ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8914 I [) 1 A (WITNESS CALONE) I did do training for the 2 training organization when I was the reactor engineer. 3 I gave training in reactor engineering subjects to 4 operators. 5 0 When was that? 6 A (WITNESS CALGNE) 1976, 1977. 7 0 But you a re not actively involved in the 8 gifin; c training to opetaccc5 noni 16 that ristt? 9 A (WITNESS CALCNE) That is correct. 10 0 Did you participate at all in demonstration of 11 emergency operstor procedures for the NRC that is 12 referenced in your testimony? 13 A (W IT N ESS CALONE) No, I was not p re sen t then.
,a t i A/ 14 0 Other than training that you yourself 15 received, do you participate at all in simulator 16 training received by LILCO operators, Shoreham 17 operators?
18 A (WITNESS CALONE) As a participant in the l training program, I have received simula tor training 19 20 along with the operators. 21 0 Mr. Carter, have you had any BWR operating i 22 experience other than the simulator experience that is l 23 referenced in your professional qualifications? I r's ( ) 24 A (WITNESS CARTER) No, I have a certified, and l \J 25 I have just had the experience, but no other BWP Q ,i l ! ALDERSON REPORTING COMPANY,INC, 1 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345 l
8915 () 1 e::p erien ce . 2 0 When did you receive your 3WR simulator 3 training? 4 A (WITSESS CARTER) The simulator training was 5 in 1980, and also I have spent some time down at the 6 Limerick simulator over the past two years on various 7 things. , 8 0 Lat ma enme back to that in a minute. Where 9 did you receive your simulator training? 10 A (WITNESS CARTER) At Dresden, Illinois. 11 Q Coming back to the time you spent at the 12 Limerick simulator recently, what was it that you were 13 doing thera? 14 A (WITNESS CARTER) Well, in liay of 1981 I was 15 down at the simulator with three opera tors, and we 16 checked out the emergency operating procedures that 17 included the generic operating procedures and the ATWS 18 procedure. We spent five days down there. In October 19 of 1981, I went down there with the operators again, and 20 we did the demonstration for the NRC. 21 0 You say with the operators. Other Shoreham l 22 operators? 23 A (WITNESS CARTER) Yes, they were. () 24 0 Do you participate at all in the operator i 25 training, in the giving of opera tor trainin g to Shoreham ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 ,
I l l 8916 ! l () 1 operators? 2 A (WITNESS CARTER) Yes, I have. I taught the 3 emergency operatina procedures to the operators. 4 0 You have done that in the past? That was the 5 past tense there? 6 A (WITNESS CARTER) Well, what do you mean by 7 past tense? 8 0 Well, I was just trying to understand, is tha t 9 something you are going to be doing or something that is 10 being done? 11 A (WITNESS CARTER) That is something I have 12 done. 13 Q You have? 14 A (WITNESS CARTER) Yes. 15 0 Do you have any involvement in the preparation i 16 of the lesson plans or training courses that are used in i 17 the operator training? 18 A (WITNESS CARTER) Well, there was no lesson 19 plan. I taught the operators the procedures. I did 20 that based upon previous knowledge. I am a member of 21 the BWR owners ' group, and I worked on emergency 22 procedure guidelines and a lesson plan at this point in 23 time. A lot of the procedures are still in a state of () 24 flux, and a lesson plan micht not have been beneficial to write. I taught them based upon informa tion that I 25 t l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 i
mam -a. a me. . __. -u - - wm_-_ W . - - . . + a_. - -2._ . .m_m.. ., a aim , - a r- -a_ _ _ _m___. (-_. 2-.___m. 8917 O neve tr== the ova *r= =coor-2 3 j i 4 5 , ll 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 l 20 l l 21 l l 22
- 23 .
I 24 25 I O ( ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON. D.C. 20024 (202) 554-2345
8916 fl 1 0 Is there a lesson plan in existence now? v 2 A (WITNESS C ARTER ) No, there isn't. What I 3 did, I took flimsies of th e procedures and ta ugh t the 4 operators line by line. 5 JUDGE BRENNER: Let me make sure. Are we 6 talking about the same procedure, the identical 7 procedure to that which is attached to your testimony? 8 WITNESS CARTER: No. I'm really lumping that 9 all together with the generic BWR procedures and the 10 ATWS procedure. 11 JUDGE BRENNER: " ell, do your answers apply to 12 that procedure also? 13 WITNESS CARTER: Yes. (~ kJ 14 BY MS. LETSCHE (Resuming) 15 Q M r. Carter, the procedures that you used in 16 training the Shoreham operators, were those the generic 17 GE or the owners group procedures, or were they 18 Shoreham-specific procedures? 19 A (WITNESS CARTER) No, it was Shoreham-specific 20 procedures. I think it is the procedure that is 21 attached to the testimony, and those procedures that you 22 have. 23 0 Mr. rckert -- r\ i ( / 24 JUDGE CARPENTER: Ms. Letsche, night I ask one l
*s 25 last question?
Iv ') ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8919 ( ') 1 .ir. Carter, you said that you went to the 2 Limerick cimulator and checked out the Shcreham 3 procedures. Could you help me a little bit? I don't 4 quite understand wha t you mean by that. You tested the 5 procedures or you tested the operators with the 6 preceduras? 7 WITNESS CARTER 4 No, the procedures 8 themselves. After I had written the procedures from the 9 BWR owners group generic ouidelines and the ATWS 10 procedure, I went down in Pay of 1981 and I spent five 11 days at the simulator running through various scenarios 12 on the simulator that I had developed myself and to 13 demonstrate to myself that the procedures were k/ 14 adequate. 15 JUDGE CARPENTER: Thank you for the 18 cla rifica tio n. 17 BY MS. LEISCHE: (Resuming) 18 0 Mr. Eckert, have you had any operating 19 experience with a nuclear reactor? 20 A (WITNESS ECKERT) I have been to operating 21 reactors, but I am not an operator myself. 22 0 Have you performed any of the work of the type 23 You've described in your professional qualifications [ml 24 that relates specifically to Shoreham, or are the things 25 described in your prof essional qualifica tions limited to ,- \
.Y ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASH!NGTON, D.C. 20024 (202) 554-2345
8920 1 () 1 generic type studies? 2 A (WITNESS ECKERT) My group does the specific 3 Sho reham licensing trsnsient analysis and design 4 specification work in the ATWS area. It is mainly the 5 generic work for BWR-4's, that are very similar to the 6 Shoreham plant. 7 0 In the early part of your answer you said "My 8 group does" the plant specific analysis. Have you done 9 any Shoreham-specific analysis yourself ? 10 A (WITNESS ECKERT) I approve and review and 11 check the work as done by the people working for me. I 12 don't run the computer cases personally. l 13 0 Is the Shoreham-specific analysis that you s/ 14 have reviewed reflected in some documentation 15 somewhere? Is tha t in the FSAR? 16 A (WITNESS ECKERT) In chapter 15 of the FSAR 17 mainly, some in chapter 5. i 18 0 Have you had any -- have you reviewed any 19 Shoreham operator procedures with respect to the l 20 mitigation of ATWS events? 21 A (WITNESS ECKERT) Yec, I have. 22 0 Have you reviewed any other than the one that 23 is attsched to the LILCO testimony? () 24 A (WITNESS ECKERT) For Shoreham, you mean? 25 0 Yes, for Shoreham. I l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345
6921 (WITNESS ECKERT) No, just what is attached (]) 1 A 2 here. 3 0 How about training? Have you reviewed any 4 information concerning the Shoreham operator training 5 with respect to the mitigation of an ATWS event? 6 A (WITNESS ECKERT) Well, I pa rticipa ted in and 7 supported the EWR owners group, simila r to Mr. Carter, 8 and was a part of that development of the training that 9 he referenced. I was not directly involved in the 10 Shoreham training. 11 0 I guess I'm not quite clear what statements of 12 Mr. Carter you were referring to. Can you tell us what 13 your participation was with the owners group effort? 14 A (WITNESS ECKERT) Well, we supported them in 15 the development of the steps that are included in the 16 current guidelines for emergency procedures. And, as he 17 mentioned, he tau-ht, for example, line by line from the 18 generic guideline as it had been developed there. And l 19 so I was a part of developing those actions. 20 0 Developing the guidelines? 21 A (WITNESS ECKERT) Yes. 22 0 Your participation in the development of the 23 guidelines, was it limited to areas of design and [~D 24 analysis, or did you actually get in to the human factors s_/ 25 elements of training and procedures? O ALDERSON REPORTING COMPANY,INC, 400 VIRGINtA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
8922 ('~) 1 A (WITNESS ECEERT) Primarily the design and a 2 anslysis. We vsnted to make sure what we asked an 3 operator to do vac a reasonable step, that he had the 4 signals or things he needed to sense that situation. S C Mr. Pfefferlen, you mention in your 6 professional qualifica tions at page 33 that you obtained 7 a license to oparnte the Vallecitos boiling water 8 reactor? 9 A (WITNESS PFEFFERLEN) That is correct. 10 0 When did you obtain the license? 11 A (WITNESS PFEFFERLEN) That was in early 1960, 12 1952, I believe. 13 0 How big is that reactor?
,m
( ) k/ 14 A (WITNESS PFEFFERLEN) It's a very small 15 breeder-type reactor, about 50 megawatts, I believe. 16 0 Did it have a standby liquid control system? 17 A (WITNESS PFEFFERLEN) No, it did not. 18 0 What was the purpose of the reactor? It was 19 an experimental? 20 A (WITNESS PFEFFERLEN) It was a prototype and 21 it was generating power. It was really an experimental 22 prototype that SE was running. 23 0 I notice you mentioned in your professional (q ) . 24 qualifications that you have responsibility for all 25 licensing aspects of the ATWS issue within General l'D V ALDERSON REPORTING COMPANY. INC, 400 VIRGINTA AVE., S W., WASHINGTCN, D.C. 20024 (202) 554-2345
_= _ - . . _ . 8923 4 1 Electric. Have you performed any Shoreham-specific 2 licensing compliance work? 3 A (WIThESS FFEFFERLEN) We reviewed the Shoreham 4 work. I am involved with the generic ATWS licensing, 5 and as such we input to Shoreham and review the work 6 tha t comes out. My group does that. , 7 Q You say " review the work that cores out." Do 8 you mean review things that Shoreham sends to you? 9 A (WITNESS PFEFFERLEN) Yes, before they send to them out. We are involved in the process of the review 11 of the GE input to the Shoreham submittals. 12 0 What kind of input is it that you review? Do 13 you review procedures, for instance, operating 14 procedures? 15 A (WITNESS PFEFFERLEN) Yes. i 16 0 Do you review training programs? 17 A (WITNESS PFEFFERLEN) Not the training 18 program, no. 19 0 Have you reviewed Shoreham-specific procedures 20 other than the ones that are attached to your , 21 tes timon y? 22 A (WITNESS PFEFFERLEN) I have looked at those. 23 I was involved in the review of the emergency procedure 24 guidelines that served as input to this. As Jean Eckert 25 was, we were involved in that review. , O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
._. _= . - - . - - _ .. .--
8924 () 1 Q With respect to the Shoreham procedures now, 2 setting aside the generic guidelines that you centioned,
' 3 you said you have reviewed some other than what is 4 sttached to your testimony?
5 A (WITNESS PFEFFERLEN) No. I have looked at 6 these. I was not in the official review procecs for 7 these. I have seen these. But I'm not sure that I 8 fully understand your question, have I looked at other 9 than Shoreham's and the EPG's? 10 Q Let's start again. There is a Shoreham 11 procedure that is attached to your testimon y? . 12 A (WITNESS PFEFFERLEN) Yes. 13 0 You've looked at that? i O 14 A (WITNESS PEEFFERLEN) I've seen that, yes. I
, 15 0 Have you looked at any of the Shorehan 16 emergency operating procedures?
17 A (WITNES$ PFEFFERLEN) No, I have not. 18 0 And all of the "these's" that you referencinq 19 in your last snswer, the record isn't going to reflect l 20 whst it is that you were talking about that you said you 21 reviewed. 22 A (WITNESS PFEFFERLEN) The Shoreham procedures 23 that you had indicated as being attached to the () 24 testimony. That is what you have reviewed? 25 0 O l ALDERSON REPORTING COMPANY. INC, 400 VIRG;NIA AVE, S.W., WASHINGTON. D.C. 20024(202) 554 2345
8925 (WITNESS PFEFFEPLEN) Yes. (]) 1 A 2 0 All right. 3 JUDGE EPENNER: It is one procedure, right, 4 singular? 5 WITNESS PFEFFERLENs One procedure, yes, sir. 6 (Counsel f or Suf folk County confe rring. ) 7 BY F.S. LETSCHEs (Resuming) 8 O Mr. Eigert, have you had any reac tor system 9 design experience? 10 A (WITNESS RIGERT) Well, in my job function I 11 perform reviews, assessments, of design modifications. 12 I have been involved in the design evolution of Shoreham 13 since the early stages. 14 0 You say you've been involved in the design. 15 I'm not sure what that means. Can you be more 16 specific? 17 A (WITNESS RIGERT) Well, as an engineer for a 18 company like LILCO, I would be responsible for the 19 review and technical approval of design work being 20 produced by Stone C Webster or General Electric. And in 21 some cases I would produce my own conceptual designs or 4 22 recommendations that would be sent back to Stone E 23 Webster or GE. () 24 We don't do highly detailed analytical work, We are also very much involved 25 as would be done a t GE. O ALDERSoN REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W., WASHINGTON O C. 20024 (202) 554-2345
8926 in the hardware aspects, the specifying and procuring of (]) 1 2 equipment, either through GF or through Stone E 3 Webster. 4 0 Have you had any operating experience. 5 A (WITNESS BIGERT) I was involved in a somewha t i 6 unrelated area. I started out in the gas production 7 department of Long Island Lighting. I was involved in 8 the startup of our liquified natural gas plant in 1971, 9 and I got varied operating experience at that time in 10 mechanical, einctrical, instrument and control 11 equipment, and a lot of process system operation. 12 I was a startup engineer at Shoreham for two 13 years, from '76 to '78, and I have had soma simulator 14 t ra ining , Westinghouse and GE, short courses; nothing 15 comparable to what the operators get, though. 16 0 When did you receive your GF simulator 17 training? 18 A (WITNESS RIGERT) I think that was in February 19 of '77. 20 0 '777 i 21 A (WITNESS RIGERT) Right. 22 O Where did you receive that? 23 A (WITNESS RISERT) That was at Morris, at the 24 Dresden simulator. ( 25 0 Have you had any design experience or l l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54 2345
8927 1 performed any work relating to the standby liquid
/^')
(- 2 con trol system a t the Shoreham plant? 3 A (WITNESS EIGERT) That system's design has 4 been fairly well fixed through the years. I was the 5 test engineer on that system when I was at startup. But 6 since then, the only changes of any significance have 7 been -- I wouldn't even call them of significa nce -- 8 have been the incorporation of a couple of SIL's into 9 the system, GE service information letters making 10 certain improvements in circuits. 11 Like I saf, other than that that system is 12 pretty much -- has pretty much been unchanged through l l 13 the years. 14 0 Did you participate in the incorporation of I 15 these GE service information letters, those changes, l l 16 into the SLC system? l 17 A (WITNESS RIGERT) I have reviewed and approved l l 18 the change for incorporation or recommended that t! c 19 change be made. It wa s made. I am not involved in the 20 actual construction and implementation of the work. 21 O In your position, do you have any
- 22 responsibilities relating to emergency operating l
l 23 procedures?
/m 24 A (WITNESS FIGERT) No official responsibility.
A'J) 25 We review them. Me and the people in my group, we try ('N O
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8928 7 () 1 to be as operationally knowledgeable as we can to do 2 systees' design. But no, we have no formal involvement.
'N 3 0 I assume the answer is the same with respect 4 to the training program?
5 A (WITNESS RIGERT) Right. 6 (Counsel for Suffolk County conferring.) 7 0 Mr. Sullivan, you indicate in your 8 professional qualifications that you have participated 9 as a reviewer in several PVR PRA's. Have you 10 participated in a review of the Shoreham PEA? 11 A (WITNESS SULLIVAS) No. i 12 0 How about the Limerick PPA ? l 13 A (WITNESS SULLIVAN) Yes, I have been a r)
/ 14 participant in the review of the Limerick, and I have 15 had inputs into the Limerick PRA.
l 16 0 'Did your inputs into the Limerick PRA include 17 any information applicable to analysis of the standby 18 liquid control system at that plant? 19 A (WITNESS SULLIVAN) Yes. i, 20 0 Can you describe what, in a little more 21 ' detail, what it was that you did relative to that?s 22, MR. REVELEY: I'm going to object to the 23 question. I don't think we're here to litigate the () 24 Limerick standby liquid control system. l 25 JUDGE BRENNER: 'J ell , we haven't gone that far O ALDERSON REPORTING COMPN,Y,INC, ! 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
[Q t
- s. I.
N s
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6929 s% o yet, so I'm going to overrule the objection. He is part (~') 1 s.
'2 of the panel and I could see where we are still on'his 3 qualifications snl his qualification in this area could V(~) 4 become pertinent to how the system at Shoreham would 25 operate in terms of efficscy of interin measures and 6 timing *and such things.
- 7. So we will overrule the objection, but not
'2 8_-necessarily disagreeink with your cornents. We just
^
, I -
9 don't think the question fallsjwithin the comment. t 10 WITNESS SULLIVAN: My primary function was 11 ' p ri ma ril y in the review of the standby' liquid control 12 fault trees tha t we re genera ted as part of th e ' L{ de rick 13 PRA. s
?
14 JUDGE BRENNEf I'm sorry, Mr. Sullivan. For 15 some reason I didn't hear you,;' <
"s . s WITNESS SULLIVA5':s As part of the Limerick
-16
\
17 PRA, my function was a r view of the standby liquid 18 control fault tree. i 19 JUDGE MORRIS: If Ms. Letsche doesn't ask you, l 20 I will. Could you describe f urther - what that involved? 21 I mean, was this a six-month job, a three-day job, and l 22 what did you actually do? WITN ES$ ; SU LLIVi'! : Y uns in te rms of 23 () 24 probably over a week 's jeb. Other people had prepared My primary function was in the 25 these fault trees. h ([) -' 1 ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE g S.W., WASHINGTON. D.C. 20024 (202) 554-2345 1
1 8930 () 1 review of these. 2 JUDGE M0ERIS: In that review, did you ask I 3 yourself questions like, is the logic correct? 4 WITNESS SULLIVAN: Eight. 5 JUDGE MORRIS: Did you look at interactions? 6 Did you look at the probabilities at branch points? 7 Just what did you do? 8 WITNESS SULLIVAN: Well, the f a ul t tree s, of 9 course, were supposed to -- were to identify the failure to modes, including the interfaces. And my function was, 11 as part of the review functions, to review the fault 12 trees f or technical adequacy, that they truly reflected 13 the design and probability values associated with that 14 assessment. 15 BY MS. LETSCHE: (Resuming) 16 0 Mr. Sullivan, was this, the f ault trees that U you were reviewin7 for Limerick, did that relate to an 18 automated or manual standby liquid control system? 19 A (WITNESS SULLIVAN) That was related to an 20 automated standby liquid control. 21 0 Did you have any review f unction or other 22 responsibility related to the human reliability 23 inf orma tion included in the Limerick PRA? (WITNESS SULLIVAN) What part of human ( 24 A 25 reliability? That's a very broad subject. r (~') l \_/ l L ALDERSON REPORTING COMPANY, INC, i 400 VIRGINTA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345 l __ _ _ _
8931 1 0 You're right, it is. Wi th respect to your (~ } 2 review of the standby liquid control fault trees. 3 A (WITNESS SULLIVAN) Yes, that would be 4 included ss part of that review. 5 (Counsel for Suffolk County conferring.) 6 Q Mr. Fullivan, would an evalua tion of fault 7 tree for a standby liquid control system at the Shoreham 8 pla nt involve the same failure modes success criteria 9 that were involved in the Limarick fault trees that you 10 reviewed? 11 MR. REVELEYa Judge, I object again. It seems 12 to me, despite the fact that we are on a credentials 13 inquiry, that we are preparing the way to go into 14 forbidden areas. 15 (Board conferring.) 16 JUDGE BRENNER: We are going to overrule the 17 objection. Obviously, she is not limited to l l 18 qualifications. That wasn't the thrust of your 19 objection. Going to the thrust of it, she is asking 20 about the applicability to Shoreham in this instance. 21 We will see if there is a bridge or not. 22 WITNESS SULLIVAN4 Could you repeat your f f 23 question again? I'm sorry. i 24 MS. LETSCHE: I'm not sure, maybe the reporter 25 could read it back. ( ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W , WASHINGTON, D C. 20024 (202) 554 2345
8932 (The reporter read the record as requested.) (]) 1 2 WITNESS SULLIVAN: Ihere would be some (~ 3 differences just due to the design configuration. That b} 4 would be the primary differences. 5 BY MS. LETSCHE: (Resuming) 6 Q Would there be differences with respect to the 7 human reliability data ? 8 A (WITNESS SULLIVAN) In reference to what? 9 Q Comparing the fault trees that would be 10 con struc te d for the two plants.
~
11 A (WITNESS SULLIV AN ) In terms of human 12 reliability, they should be essentially -- and I have 13 not gone through a complete review of a Shoreham-type 14 fault tree. But in my review of the limerick, I would 15 say yes, they would snd should be very similar. 16 Q Mr. Sullivan , wha t was the data base for the 17 human reliability information in the limerick f ault 18 trees we have been discussing? 19 A (WITNESS SULLIVAN) This is prima rily standard 20 NRC failure rates used in PRA analysis. 21 JUDGE BRENNER: Ms. Letsche, could I hear your 22 last question again? 23 MS. LEISCHE: I asked them what the data base () 24 was for the human reliability information in the 25 Limerick fault trees. O ALDERSON REPORTING COMPANY, fNC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
0933 BY MS. LETSCHE (Resuming) (]) 1 2 0 Mr. Sullivan, does your experience include 3 work in analyzing operator reliability or reviewing 4 operator procaiores from that point of view? 5 A (WITNESS SULLIVAN) Yes, I have been involved 6 in several assessments where we have reviewed operating 7 procedures in relation to operator response. 8 0 Have you donc that with respect to the 9 Shoreham operating procedures? 10 A (WITNESS SULLIVA.V) Which operating 11 procedures? 12 0 Let me be more specific. Have you reviewed 13 any Shoreham operating procedures relating to the 14 mitiga tion of an ATWS event as part of an analysis of 15 operator reliability? 16 A (WITNESS SULLIV AN ) I have reviewed the 17 operating procedures attached as part of the testimony. 18 I have not performed a reliability analysis specific to 19 Shoreham or reviewed a reliability analysis specific to l 20 Shoreham relating to the operating procedures. 1 21 0 And I take it tha t you haven 't reviewed 22 operating procedures for Shoreham other than the one 23 that is attached to your testimony? 24 A (WITNESS SULLIVAN) I don' t understand what 25 you mean by "others." O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D C. 20024 (202) 554 2345
f 8934 Well, there is one procedure attached to your (') 1 O 2 testimony, one Shoreham procedure? (WITSESS SULLIVAii) 8 3 4 A 0 Yes. Hsve you reviewed any other Shoreham 5 procedures? 6 A (WITNESS SULLIVAN) No. 7 0 You said you haven't performed a reliability 8 analysis. To your knowledge, has one been performed 9 relating to the Shoreham procedure that you have 10 reviewed? 11 A (WITNESS SULLIVAN) It's my understanding that 12 there is a probabilistic risk assessment that is being 13 conducted for Shoreham. k/ 14 O A side f rom that, though, are you aware of any 15 other reliability analysis rela ting to the Shoreham 16 emergency operatino procedures or any other procedures 17 relating to the mitiga tion of an ATWS event? 18 A (WITNESS SULLIVAN) Specific to what is 19 attached to the testimony? 20 0 Well, to tha t procedure or anything else, but 21 specific to Shoreham, a mitigation of an ATWS event. 22 A (WITNESS SULLIVAN) Not specific to Shoreham. 23 JUDGE BRENNER: Ms. Letsche, let me offer the
,m (v ) 24 general comment tha t some of your questions are very 25 broad, and it raquires the witness to come back and say, f'~'\ '\. l ALDERSON REPORTING COMPANY, INC, 400 VIRGINI A AVE . S.W.. WASHINGTON. D.C. 20024 (202) 554 2345
1 8935 () 1 do you mean this, do you mean that. I don't want to 2 talk about all procedures in general, nor do I want you [^ 3 to limit it necessarily to this one procedure. However, V} 4 within those two extremes you can include words in your 5 question that will focus on the procedures to deal with 6 an ATWS. 7 MS. LETSCHE: Judge Brenner, I intend to do 8 that. I intended this to be broad, since we were in the 9 qualifications area, and I will certainly get more 10 specific. 11 BY S. LETSCHE (Resuming) . 12 0 Let me ask the GE witnesses -- 13 JUDGE BRENNER: Excuse me. Are you finished 14 with Mr. Sullivan's qualifications? I 15 MS. LETSCHE Yes, I am. 16 JUDGE BRENNER: Mr. Sullivan, although I 17 recall your indicsting many years of experience in 18 reliability engineering, I don't recall any listing of 19 your education in the qualifica tions. If you listed it, l 20 I 'm sorry, I don't recall. 21 Could you tell us what it is, please' 22 WITNESS SULLIVAN: Yes. I am a bachelor of 23 science in mathematics.
/~ 24 JUDGE BRENNER: Thank you. I wanted to find
()D l 25 out if they were giving degrees in PBA work. l () l ALDERSON REPORTING COMPANY,INC, l 4C0 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8936 1 (Laughter.) ( 2 BY HS. LETSCHE: (Resuming) 3 Q Let me ask the GE witnesses sort of in general [~} k/ 4 this questions Did any of you participate in the 5 preparation of responses to the NRC regarding the ATWS 6 issues, such as an analysis of NUREG-0460 responses? 7 A (WITNESS FEFFERLIN) Yes, we have. I think 8 all three of us have participated in putting together 9 our responses and submitting them to the NRC. 10 0 Who do you mean by "our responses"? 11 A (WITNESS FEFFERLIN) The GE responses. 12 (Coursel f or Suf folk County conferring. ) 13 0 The responses tha t you have participated in, 14 are those generic responses or Shoreham-specific 15 responses? 16 A (WITNESS FEFFERLIN) They are generic 17 responses. 18 0 Mr. Hodges -- 19 JUDGE BRENNER: Ms. Letsche, I guess I would 20 like to ask the LILCO witnesses a preliminary matter, so 21 ve don't possibly go too far off in the wrong direction 22 once we get into the substance. I guess I should ask 23 Mr. Calone, but anybody clse can answer too if they () 24 think it is appropriate. Is the procedure attached to the testimony the 25 O O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554 2345
8937 1 one that is going to be in place? Is that the procedure (} 2 ve should focus on if we sre going to judge the efficacy 3 of prccedures? Because I thought I heard something -- 4 we know that there is a transition period fCr developing l 5 new procedures, and I don't want to waste a lot of time 6 on one procedure and then find out a month from now that 7 that is not the procedure. 8 WITNESS CALONE: The procedure that is 9 attached to the testimony is the procedure that is 10 currently in existence and the operators are training to 11 at Shoreham. We understand there are some revisions 12 down the road a bit. Our commitment is to incorporate 13 new revisions af ter they are approved by the appropriate 14 entities, basically the BWR owners and the NRC. 15 At the present time, all we have to deal with 16 is the procedura tna t is a ttached, which has been 17 reviewed by the N9C and we are now using. 18 ' JUDGE BRENNER: That's not good enough. Do 19 h ou know what the changes are going to be? Are you 20 prepared today to tell us what they are likely to be, 21 even though you kind of state certainly tha t all of the 22 changes will be made? 23 WITNESS CALONE: Yes, I believe that we could 24 discuss the changes that would have to be made. ( 25 JUDGE BRENNEP: Maybe it would be appropriate ( r ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
0938 (~') I to get that up front. Mr. Reveley, what do you think? x_/ 2 (Counsel for LILCO conferring.) 3 MR. REVELEY: Mr. Calone, why don 't you state, 4 with all appropriate qualifications, your understanding 5 of the current situation as to the evolution of the 6 procedure, where it is going? And Mr. Carter can help 7 you as necessary. 8 WITNESS CALONE: I think Mr. Carter would have 9 a more detailed answer for that. 10 WITNESS CARTER: At the present time, the 11 present ATWS procedure is based upon GE guidance that r 12 came out in July of 1980. Right now our generic GE l l 13 quidelines are based on Revision 1.B, which was -- well, r^N
\- 14 that came out around March of 1981.
l 15 Right now currently, Revision 2 is -- that is 16 submitted by the BWR owners group to the NRC and is 17 waiting for approval for use. Revision 2 incorporates 18 the ATWS or reactivity control guideline into the 19 generic BWR owners group guidelines, and once we write 20 Revision 2 the ATWS will be incorporated into the 21 generic guidelines. And that is what we're waiting for 22 now. 23 The Revision 1.E I wrote somewhere around 24 March of 1981, and the ATWS procedure is based upon the [/ x._
)
25 GE quidelines about the same time. n U ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASH!NGTON, D.C. 20024 (202) 554-2345
8939 3 1 JUDGE 9RENNER: I cuess I wasn't very clear. (~/ t 2 I want to know what the new procedures are likely to be, 3 wha t changes there are, and is there a draft precedure 9 4 out, what the status of uncertainty is. That is, does 5 LILCO and GE know what they want and is it just a matter 6 of Staf f ap pro val, or is GE and LILCC -- do they still 7 have a lot of uncertainty as to what they want to do 8 with respect to the procedure? 9 WITNESS CARTER No, Revision 2 has been 10 submitted to the NRC. It is incorporating the 11 reactivity control guideline which is the ATWS guideline 12 into the procedures. We are just waiting for approval, i 13 and then we will incorporate or write our procedures to \ (~)
'x s 14 Revision 2, when we have all of the informa tion. I l
l 15 think there are still a couple more drafts that need to 16 be generated. 17 WITNESS HODGES: May I make a comment? I am i 18 the principal reviewer for those guidelines, and because 19 of this hearing there has been somewhat of a hiatus in 20 the review. My schedule had called for completing that 21 review in August. It will definitely not be completed 22 before September now. It may be slightly later, but I'm 23 going to attempt to try to get it completed some time in () 24 September. 25 The ATWS procedures as they are outlined in l (
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8940 TN 1 the guideline are very similar to the Shoreham V 2 procedures as they now exist. There are dij#.erences 3 which I feel should be incorporated, and I don't know, 8 4 at this point or later on in the discussion, if you want 5 to get into the reasons for those. But there are not 6 large differences. There are a few steps to be added, 7 basically, from the procedures that now exist. 8 Once they are approved by the NEC, there would 9 probably be some suggested changes to this Revision 2 10 that he discussed. So the owners group would have to go 11 back and incorporate that. I would estimate that it 12 would probably take approximately a year's time to get 13 all of the changes incorporated, procedures changed at i
/^g l \) - 14 various plan ts, and the training implemented that would j 15 be needed before the new revised procedures would be 16 implemented. That is just a rough estimate based upon 17 not jerking the operators around too much by changing l
I 18 their training in the procedures every few months. 1 19 JUDGE BRENNER: Well, as we said way back in 1 20 the order admittinc this contention, the efficacy of 21 interim measures are going to turn very heavily upon 22 procedures and trsining. So I'm open to suggestions as 23 to how we make sure we are on the right track and not (n)
%J 24 focusing on things that micht importantly change.
l 25 WITNESS CALONE: If I may add, Judge Brenner, l')
%._)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554-2345
8941 (~
'uj) 1 I want it understood that LILCO does not consider the 2 current procedure inadequate, and that we do understand that future revicions are in the right direction to 8
3 4 improve the situation of an ATVS mitigation. And the 5 revision also incorporates ATWS into the other emergency 6 procedures which deal with containment and reactivity 1 7 control. 8 Right now they stand as two separate entities 9 a nd Rev. 2 puts them all together. So there is a bunch 10 of revision that has to be done with Rev. 2, but as it 11 stands right now we did not con templat e tha t the current 12 situa tion is, shall we say, unsafe. l l 13 JUDGE BRENNERs Well, I understand that, and (3 () 14 tha t is fine. But I think counsel knows what the 15 Board's concern is. I don't want to litigste something 16 and then find out the actual procedure -- and I'm not 17 talking about unimportant details. Somehow we need to 18 get a feel for what the changes might be, even if they 19 are not finally in place. 20 MR. REVELEY: I think that is right, Judge. 21 And I think this group is prepared to discuss what the 22 changes might be, though, as Mr. Hodges pointed out and 23 as Mr. Calone pointed out, the present situation is not ('/i xs 24 thought to be inadequate, nor is it likely tha t wha tever 25 revisions come to pass will be implemented inmediately. g) N ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554-2345
8942 So that I think the appropriate approach to ('/) s 1 2 take is the one on which we are enbarked. People should 3 ask this panel how they expect the procedure to evolve 8 4 and they should ask this panel why in its judgment the 5 present situation is acceptable. 6 But we do not confront the possibility, so far 7 as I understand the situation, that we are going to 8 litigate a particular procedure here this week and 9 perhaps later in August, and then discover in a month 10 that that procedure has changed and that Shoreham is 11 proceeding with a new one. 12 This is part of the discouraging ambiculty 13 that we confront all of the time in this prccess, and we l f~'s) ( i A/ 14 are doing our best to cope with it. But we live in l l l 15 flux. I 16 JUDGE BRENNER: k' ell , flux per se doesn't l 17 disturb is. It is getting a handle on the possible 1 18 extent of that flux, as you know. 19 MR. REVELEY: I think this panel is prepared 20 to help develop a record that defines the bounds of the 21 flux. 22 JUDGE BRENNER Well, my suggestien is, isn't 23 it inefficient to extract it question by question?
/m 24 Let's get a draft written procedure available. I (v) 25 thought -- I guess I am not very articulate today. I f')
LJ ALDERSoN REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
8943 1 tried to ask one of those questions earlier, that is (' } 2 tell us where it's coing to change. 3 MR. REVELEY: Well, I thought I acked tha t 4 same question, too. 5 JUDGE BRENNER: I didn't hear the answer. 6 MR. REVELEY: Neither of us got the answer. I 7 will ask it again. 8 JUDGE BRENNER: I want to first hear from 9 LILCO how their proposal varies the procedu re a ttached 10 to the testimony, and then I want to hear from Mr. 11 Hodges whether he agrees with that and what, in addition 12 to the propocal, he envisions happening without any 13 commitment that you are going to require these other D. k._) 14 changes or that you might not think of others, but to l l 15 the best of your ability tell us what your thinking is 16 at this time without being locked into it as your final 17 review. 18 BY ME. REVELEY: (Resuming) l 19 0 Mr. Carter, can you indicate, with whatever 20 additional comments other panel members micht have, your 21 understanding of the way in which the procedures are 22 likely to evolve, to change, if and when Revision 2 23 becomes a reality? () V 24 (Panel of witnesses conferring.) 25 JUDGE BRENNEE: Incidentally, I'm certainly O
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8944 l) V 1 not hung up on what the witness answers, and maybe I wa s 2 misled by something I read in the qualifica tions, but I 3 thought I saw in Mr. Eigert's qualifications that he is 4 the one who developed the procedure. And that is why 5 I'm a little confused with respect to what he does on 6 the precedures as compared to what Mr. Carter does on 7 the procedures. 8 I was going to ask that at some point. Maybe 9 as part of this answer I chn hear that, too. 10 WITNESS CARTER: Well, as far as the ATWS 11 procede'e is concerned, I wrote it. 12 JUDGE BRENNER: So if I read words in Mr. 13 Rigert's qualifications f rom which I inferred that he
\/ 14 Wro te it, that was a wrong inference?
15 WITNESS CARTER: Yes, I would say so. 16 I guess, to respond to the other question, 17 essentially now we have essentially two separate l l procedures 18 the procedures based upon the generic BWR 19 owners group and then the ATWS procedure. Revision 2, 20 will incorporate the ATWS procedure into the generic 21 procedures, and when that happens that will then delete 22 the ATWS procedure as it exists today. 23 JUDGE BRENNER. I 'm sorry, I lost you. You f~) w/ 24 say the ATWS procedure. That is the procedure attached 25 to your testimony? (~))
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I
)
l l 8945 I l l 1
/~'T 1 WITNESS CARTER: Yes, the procedure attached l %J l 2 to the testimony as it exists today will be deleted when !
3 Revision 2 is implemented. We will implement the 8 4 Revision 2 as soon as possible when we get the okay to I 5 implement it. 6 There are some differences between the two 7 procedures. Essentially, Revision 2 will have a step in i 8 there which will control reactor power by lowering
)
9 reactor wa ter level, and essentially will lower reactor 10 water level down to about the top of the reactor fuel, l l 11 And until we inject the boron into the core, and then it 12 will raise the water level to cause a shutdown of the 13 core. l (M.\ i \ N._/ 14 The present ATk'S procedure as it is now does i l 15 not have tha t step in there. There are some other 16 differences. Essentially, the Revision 2 will also , l 17 integrate ATWS into the other procedures, and therefore 18 you will have -- since ATWS also has to be sort of 1 l 19 integrated with the containment control procedures, that 20 is probsbly more beneficial to have the procedures 21 integrated, and therefore essentially we will 22 incorporate Revision 2 when available. 23 JUDGE BRENNER: M r. Hodges , do you want to l 24 give us your views also? [v) 25 WITNESS HODGES: For the most part, I acree
/7 C
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8946 I with what Mr. Carter says. There are a couple of -- (~s') s 2 JUDGE BEENNER: That also means you understand 3 what he says? 4 WITNESS liODGES: Yes, I understand what he 5 says. 6 JUDGE BRENNER: Don't be afraid to repeat it 7 in your own words. 8 WITNESS HODGES: Because I have followed both 9 the generic guidelines and the Shoreham procedures, I am 10 familiar with what is going on. A couple of points. 11 First of all, the organization of the 12 guidelines in Eevision 2 is considerably dif f erent f rom 13 the organization of the guidelines in the revision upon 14 which the Shoreham procedures are based. This does not 15 mean that the steps that are taken are that different, 16 but just how the logic, the procedures, take the 17 operator through in order to get to those steps is 18 different. 19 And so any revision to the procedures based 20 upon this Revision 2 of the guidelines I would expect to 21 incorporate this organizational difference. 22 Secondly, I think Mr. Carter said that the 23 current Shoreham procedures do not include lowering the 24 vater levels to the top of th e reactor fuel. The () 25 revision that I have, which I think is Revision 0, does 'T
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J ALDERSON REPC 4 TING COMPANY,INC, 400 VIRG:NIA AVE., S.W . WASHINGTON, D C. 20024 (202) 554 2345
8947 (N v; 1 include that step. What is not included is the raising 2 the water level f o l'. o w i n g that to back to the normal 3 level. 4 The reason for lowering the water level is, 5 following tripping of the recirculation pumps you are 6 still genera ting on the order of 30 percent power. 7 Because this is a la ge heat load on the suppression 8 pool if the heat is going to the pool rather than to the 9 condenser, the desire is to get the power level down 10 even further. 11 You can do this by reducing the natural 12 circulation flow rate, which has a very close link with 13 the power because of the void. And once you've tripped
/~m j f i 'V 14 the pumps, the only thing you can do to further reduce l
15 that is to lower the water level and thus reduce the 16 driving head that is causing the natural circulation 17 flow rate. l l 18 For that reason, the procedures do call for a 19 lowering of the water level as indicated on the 20 instruments to the top of the reactor fuel. This does 21 not mean that the actual water level in the core would 22 be at the top of the reactor fuel. It would mean that 23 basically the solid level in the down region would be at ( ; 24 a level equivalent to the top of the reactor fuel and 25 you would have sota two-phase mixture higher than that On v ALDERSON REPORTING COMPANY, INC, 400 VIRGINTA AVE., S.W.. WASHINGTON. D C. 20024 (202) 554-2345
8948 () 1 within the core. U 2 This grea tly reduces the d riving head for 3 natural circulation. It would reduce the power level in 4 the range of ten percent, and essentially buys time to 5 get sufficient boron injected with the standby liquid 6 control system. 7 JUDGE BRENNER Okay. In terms of whether the 8 step to lower the water level is included now, Mr. 9 Hodges, I think whst r. Ca rter mean t is that tha t step 10 is not presently included in the procedure attached to 11 the testimony. Is that correct in your view, "r. 12 Hodges? 13 WITNEFS HODGES: No, it is in the procedure (~'l '
\- / 14 attached to the testimony. What is not included is 15 increasing the water level later in the event.
16 JUDGE BRENNER: Mr. Carter? 17 WITNESS CARTER: I probably misstated it a 18 little bit. The entire power level control guideline is 19 not in there. We do trip the feedwater pumps, which 20 would have the effect of lo we ring the water level. But [ 21 the entire step is not in there. 22 JUDGE BRENNER: With respect to the entire i 23 step, what does the operator have to do to lower the l (~) x.s 24 water level besides tripping the pumps? 25 WITNESS CARTER: Well, the guidelines -- well, U ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8949
', 1 just from trying to remember them now, they are I'_.J 2 essentially, you secure feedwater flow into the vessel 3 and you lower water level until you hit some 4 p re de te rmine d power level. Then once all of the boron 5 has been injected, then you raise the level back up.
6 That specific step is not in the procedures as it is 7 written now. 8 WITNESS HODGES: I think the biggest 9 difference is that in the guideline Revision 2 you stop 10 all injection to the vessel except with the standby 11 liquid control system and the control rod drive system. 12 In the Shoreham procedures that now exist, you 13 still have HFCI and RCIC operating, so that the level (3
\-) 14 would be lowered more slowly and it might not get as lov 15 with the HPCI and the RCIC operating. So it might not 16 get to the top of the reactor fuel. In fact, it 17 probably would not get all of the way down to the top of 1
18 the reactor fuel unless he throttled those systems to i 19 get it down to that point. l i 20 Now, if I recall -- and we could check the 21 step -- there is a step tha t says, lower to the top of I 22 the reactor fuel, in the procedures. But it would 23 require some throttling of those systems to do that. JUDGE BRENNEF: This is still in the limited [v) 24 25 preliminary context, and we're going to have the parties (~'\ L.) ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, O C. 20024 (202) 554-2345
8950 I have at that first. But Mr. Hodges, I'm trying to get a (~') us 2 handle on what the Staff as part of your review might I don't want to pin you down into a review that you 8 3 4 do. have not completed yet, and you've given us the time 5 frame. 6 But is that a direction the Staff agrees 7 with? That is, throttling back of these systems so as 8 to increasa the rite of lowering the level? 9 WITNESS HODGES: I think that, given the 10 system design as it exists today, which is the 43 gpm 11 manually-actuated standby liquid control system, that 12 tha t is the best that you can do. You have got to lovar 13 the water level rapidly, and the more rapidly in this f} x/ 14 case the better because you are trying to get the power 15 down and that is the means of doing it. 16 There may be problems associated with doing 17 that, and just exactly wha t those problems are are not 18 subject to analysis. The computer codes that exist are 19 not capable of doing the calcula tions, and there are 20 only limited experiments available to describe what goes 21 on. And so some of what might occur is speculation. 22 But I do have concerns personally about 23 oscillations snd such that might occur as the water I ') 24 level is lowered and now that might affect the core, I Ns 25 think. But if you're looking st the tradeoffs as
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0951 I~ opposed to what you buy with these procedures, as V) 1 2 oppose'l to what happans if you don't do that, tha t these 3 are the best procedures that you can get wi th the system 4 as it exists today. 5 MR. BLACK: Judge Brenner, if I may point out 6 something that may be of help to the Board just in 7 further explanation. If you will look at attachment 1, 8 which is the current procedures, attachment 1 to the 9 LILCO tastimony, page 3 of that procedure, there is a 10 procedure number 3.6.1.2 at the top of the page there 11 that says, " Terminate all injection into the RPV with 12 the exception of CRD and RCIC or HPCI, to maintain 13 reactor vessel water level above the top of the active ( i
\s' 14 fuel."
15 Now, that is currently in there. I think what c. 16 Mr. Hodges just said is that the thrust of wh a t the 17 Staff wants to do is to get the water level down as 18 quickly as possible, to get your water level down, to l l 19 get natural circulation slowed down. And to do so you l 20 would nave to throttle the RCIC or the HPCI. 21 And in the provision as now in 3.6.1.2 it says 22 you do not throttle RCIC or HPCI, and that provision 23 will be added in Revision 2, I guess. ([ ) 24 MS. LETSCHE: Judge Brenner, I have not said 25 anything during all of this beca use I have assumed the l (~)
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8952 ()Lj 1 Board was trying to find out where we stood with respect 2 to this issue. But I really have to say something, 3 first of all with regird to the counsel testifying over 4 here. But more importantly -- 5 JUDGE BRENNER4 I don 't think tha t was in the 6 realm of testifying. That is, he drew our attention to 7 part of the procedure that we can then regin to relate 8 the witness' testimony, and that is the context we will 9 accept. 10 But co on to where you really want to go. 11 MS. LETSCHE: More importantly, I just have to 12 object to what is going on here. I mean, we have again 13 found out that there is some other procedure that is in t G 4 N> - 14 existence that this panel is f amiliar with. Mr. Reveley 15 has said this panel is prepared to talk about it. The 16 important point is that the County isn't. 17 We haven't heard anything about it and have 18 not had any notice of the existence of these documents. 19 It sounds like there are goina to be, or at least there 20 are some considerations being made of, some substantial 21 changes, not only in the procedure that has been 22 attached to the LILCO prefiled testimony, but also 23 apparently in other procedures that thus far have not I been relied upon by LILCO in mitigating an ATWS event \s) 24 25 during this interim period. ('hi s ALDERSON REPORTING COMPANY, INC. 400 VIRGINIA AVE., S W. WASHINGTON D C. 20024 (202) 554-2345
e-8953 () 1 And I just have to reiterate the objection we v 2 have made on other occasions when it has como up that 3 I 'm not sure what we are doing here, when there is this 8 4 new information coming out that the County has never 5 been notified of. And we certainly are not -- we did l 6 not know that we were going to be litigating tha t this l l 7 morning, this additional information. 8 MR. REVELEY: Judge, if I may, I think that it 9 is not the case that the County is unsware that these 10 guidelines, th ese procedures, are in the process of 11 revision. Mr. Earley indicates to me that that point 12 was made during the 7.F testimony. Mr. Earley thinks 13 that in a meeting wi th the Staff and with LILCO people, (~h '
'A > 14 with County people present, it was mentioned. That is l
l l 15 A. 16 B, again, procedures stay in flux, guidelines 17 sta y in flux , regula tions stay in flux. That is a fact 18 of life. I think this panel is prepared, if people wish 19 to know in what directions these guidelines and 1 l 20 procedures are going, to discuss that direction. They l l 21 are also prepared to discuss the adequacy of the l l l 22 existing regime. 23 I don't think Ms. Letsche's objection, f) 24 complaint or whatever it was, is well taken. 1
%j l
25 JUDGE BRENNER: In your comments, Mr. Reveley, I in l l ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S W., WASHINGTON, D C. 20024 (202) 554 2345
1 l 8954 l f 1 did you mean to imply that the specific changes in this (v) 2 procedure were discussed in meetings? We know about the l 3 general flux, bat we're not talking about that. 4 MR. REVELEY: Let Er. Earley speak to that. 5 JUDGE BRENNER: Well, let me make a point to 6 you, and then we're going to take a break. We asked you 7 last week, the Board did, in the particular context of 8 this contention -- we made the observation, which is in 9 accordance with the observation you just must, that 10 these procedures are in flux, a nd we want to make sure 11 and hea r tha t the procedure attached is the one that is 12 going to be used. If there are any changer being
- 13 considered, we want to know about them.
\ t w/ 14 And we got resounding silence back from LILCO 15 since that comment. And because -- of course we are 16 awa re of the general flux situation. And we reiterated 17 the point, and it shouldn't have been necessary for us 18 to reiterate i t. The parties should be alert to 19 apprising us of that kind of thing, and at a minimum we 20 should have had an identification of the contemplated 21' possible changes, the material ones, not every little 22 itty-bitty thing and whether or not the procedure in 23 terms of organization is going to be incorporated within <~s ( ; 24 a larcer procedure in terms of the symptomatic approach, 25 of which we ha ve a lso heard much, as distinguished from f% Y ALDERSoN REPORT 4NG COMPANY,INC, 400 V RGINIA AVE., S W., WASHINGTON. O C. 20024 (202) 554-2345
8955 (') v 1 a separa te proced u re . 2 I'm not interested in that, and I guess the 3 witnesses misunderstood my interest before. But as to 4 the saterial changes, we want a very good chart of what 5 the operator is going to have to do from the moment he 6 starts entering in ATWS event. And this change being 7 contemplated sounds important to that, and that should 8 have been identified before this morning, particularly 9 given the reminder we gave last week. 10 But we are going to take a break. 11 MR. REVELEY: I think your point is well 12 taken. On the latter score, as to whether this
,- 13 particular change, if it is approved by the Staff and if
\
'# 14 it is implemented, will be in effect when this plant 15 goes on line, if this plant is approved by this Board, 16 that is another question, and I don't believe it will 17 be, As I understand the situa tion accordingly.
18 JUDGE BRENNEF: I understand that possibility, 19 and it is certainly pertinent. But the point is to 20 identify what might happen, and then we can more 21 intelligently discuss when it might happen, whetNer the 22 timing is important. We could assass the present 23 procedure in light of what might happen. (fn ) 24 It still might be an interim period in the 25 sense of interim prior to the rulemaking, even if there [)
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8956 (J i 1 are changes ov9r the interim period. So certainly all 2 of that would have been pertinent to understand and get 3 at. But it is not in derogation of the fact that we 4 need the basic information in order to start focusing on 5 the more sophisticated aspects of it than you just 6 indicated. 7 It is very hard for us, when we hear this for 8 tha first time, even if you told the County everything 9 in a meeting last week, which is not the case. 10 MR. LANPHER: Judge Prenner, let me just 11 correct one thing. I certainly did not mean to say tha t 12 the County did not know. We obviously read in the 13 testimony and know that the emergency procedure t i 14 guidelines a re under review. 15 What we did not know is that there has been a 16 revision of particular relevance to this contention that 17 has been submitted to the Staff, tha t is ou t there, tha t l l 18 everybody is looking at. That is what I meant in terms 19 of new material. 20 WITNESS HODGES: ay I make a comment or is 21 this just fo r the lawyers? l l l 22 (Laughter.) i 23 JUDGE BPENNER: I was going to say, you may be
,m '( ) 24 a ray of sunshine in all of this. Go ahead.
l 25 (Laughter.) l l ALDERSoN REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W. WASHINGTON. D C. 20024 (202) 554 2345
~ _
8957 s J]') 1 '4ITNESS HCDGES: In my opinion, the most V ~ 2 cionificant change in the Revisiort 2 as far as the.AT'4S 3 procedures is already incorpora ted in the LILCC 4 procedures and is actually attached to the prefiled 5 testimony by these witnesses;- There is an unusual 6 situation that LIICO has here in that Mr. Carter is a i 7 'sember of the subg-oup that is workinc on these generic 8 guidelines, and what he has incorporated in to the 9 Shoreham-specific procedures is in advance of the 10 earlier version of the guidelines. 11 And so, although it does not go quite to what 12 the guideliner now recommend, it goes most of the way j 13 and has what I think is one of the more essential points 1 i l V 14 in the revised guidelines. So in that sense I do not i 15 consider what we were discussing a major increment over l 16 what they had in their prefiled testimony. 17 s JUDGE BRENNER: All right, that is helpful. 18 Let me understand one other thing also, Mr. Hodges. 19 Although your review is not completed of the proposals 20 that go beyond the procedure attached to the LILCO 21 testimony, I understand you are prepared to give your 22 opinion as to tihe state of 1ffairs if we operate on the 23 assumption that the procedure in place at the time of w . (v ) 24 possible operation of Shoreham would be the procedure as 25 presently sttsched?
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1\ i ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8958 ( ; 1 WITSESS HCDGES: Yes, I can talk about that, xJ 2 or I can talk about what the ;eneric guidelines will do, 3 either way or both. 4 JUDGE EFENNER: But your review is not still 5 open on the procedures that presently exist, is it? 6 WITNESS H0DGES: The procedores as they 7 currently exist have been approved for implementation. 8 JUDGE BRENNER: I take it, depending upon what 9 you find as you review the proposals, you might find 10 something that you would want to see implemented before 11 startup. Is that possible?
' 12 WITNESS HCDGES: The proble: I have with 13 saying, yes, we would do it before the startup, is ,~,
t t) 14 something I alluded to a little earlier, in that the 15 oerators have already been trained on these other 16 procedures, on the set of procedures, and to, say, every 17 six months or fairly frequently change the proced ure s 18 that they are trying to operate with and hence have to 19 go back and retrain the operators may be more 20 detrimental than waiting a little bit longer and 21 incorporating them with a bigger change. 22 So I can't give you a definitive answer on 23 that. 24 JUDGE BRENNER: I infer -- and these are my ( ) 25 words, not yours -- that you would have to find that v ALDERSoN REPORTING COMPANY,INC, 420 ylRCINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 {
l 8959 O =c'etniao reettr =toatitceat e= overtooxe4 ta the 2 existing procedura before you would rasch the type of l 3 determination that it was important to take the changes 4 before any com;ta rcia 1 opera tion ? I 5 WITNESS HODGES: Yes. 6 JUDGE BRENNER: Okay, let's take a break, 7 partly because it's atout that time or past that tine, 8 anyway. And we will think about this and be back a t 9 11:00 o' clock. 10 (Whereupon, a t 10:50 a.m., the hearing was , i 11 recessed, to reconvene at 11:00 a.m. the sa ne day. ) i 12 13 14 15 16 17 18 i 19 20 21 22 . 23 24 25 l O ALDERSON REPORTING COMPANY, INC, 400 VIRGINI A AVE., S W., WP4RNGTON, D C. 20024 (202) 554 2345
8960 () 1 JUDGE BRENNEPs Let's go back on the record. 2 I think that we agreed, "r. Reveley, that the 3 things are not abcolutely fixed, and we recognize that, 4 and everybody, including the Board and the parties and 5 the witnesses, whose task we shouldn 't overlook either, 6 try hard to adapt and do the best we all can consistent 7 with the time frames in th e real world and the time 8 frames of the untaal worli thst is this litigation. 9 Consistent with that 20-20 hindsight, this was 10 not the best way for LILCO to handle this particula r 11 matter. We should have heard sone more about the 12 contemplated changes, recognizing that with all of the 13 necessary caveats, they are just proposed and not I i
\/ 14 approved. They are contemplated. The time f rame in 15 which they might be implemented is open and subject to 16 inquiry.
17 With all of that, it would have been helpful. 18 The problem is, we heard some thincs for the first time 19 today. The County heard some particulars for the first 20 time today. We all understand tha t in general things 21 are in flux with respect to procedures, and in addition 22 it is appropriate to point out, and I hesitate to 23 reiterate that procedures are particularly important in this context ar we focused the ATWS contention, given (_) 24 25 the Commission's rulemaking, and as you know, on the
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554 2345
8961 (3 1 basis of our rulings on the motion to strike, on LILCO's L,/ 2 motion to strike the County's testimony, and the reasoning we endesvored to set forth at the time we 8 3 4 admitted th e con ten tion , that the procedure and training 5 sre the primary focus. 6 So, we need a good awareness of what changes 7 might take place, because if we are write things are 8 okay cr not okay on the basis of this procedure, and 9 limit our writinc focused that way, there could be big 10 problems for =ither party, either LILCO or the County or 11 even the staff, in terms of what might happen in the 12 future after our decision. That is just another 13 practical reason as to why we need what is going on when . 1
,~
i ( ; i> 14 parties decide whether the material bases for a finding 1 15 by the Ecard is now being changed on a contested issue 16 after the Board's decision,.and airo as we said, the 17 interin period that we are considering is not the period l l 18 between now and licensing, possible licensing l l 19 exclusively, but the period between now and possible 1 1 20 implementation of the final rule. 21 Having said all of that, we are going to do 22 our best to go ahead wi th the information as is, but we i 23 are sympathetic in this particular instance, Ms. n
/ ) 24 Letsche, to the aspect of your ability to follow up with </
25 thoughtful cross examination on matters you have heard
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8962 fLJ') I for the first time when those matters are not just 2 additional detail in response to things we contemplated, 3 but some new things. So, wo will proceed a s best we 4 can. We ask you to do your best to adjust and to follow 5 up now. However, if you after the break vant to follow 6 up with respect to the new matter, and make a 7 demonstration as to what you want to ask and what it 8 relates to so we can make our own assessment as to 9 whether it relates to the possible changes in the 10 procedures that we have heard about, as distinguished 11 from things you should have been able to ask about, we 12 will give you that opportunity. 13 In terms of rebuttal, you always have that i t > l \/ 14 righ t , even if the right to request rebuttal once you 15 tie that to the n?w matter also, and we just ask that it 16 be done timely. I don't frankly think we are going to 17 finish the ATWS contention this week. We are hopeful, 1 l l 18 very much hopeful of finishing the LILCO and staff panel 19 this week, but I don't expect that we will finish the l l 20 County's testimony if we even start it. So, perhaps we 21 can handle requests, these possible requests by the 22 County prior to the time that we might get back to this 23 contention through the County's testimony, so we could n (, j 24 make whatever rulings that are necessary in advance, and 25 have the followup all in one place as we continue the n
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
0963 ( ,) 1 contention at some point after the break, and the 2 parties chould be talking with each other about these 3 possibilities also, but for now we will proceed. 4 MS. LETSCHEa I would like to request that 5 LILCO or the staff or someone provide the County with a 6 copy of whatever the revisions are that the gentlemen 7 have been referring to, and the other relevant 8 procedures that might be affected or changed as a result 9 of these ravisions so that we have the pertinent to material to look at over the break. 11 JUDGE BRENNER: In fact, if possible, perhaps . 12 by the end of the day that could be done.
, 13 MR. REVELEY: Yes, I think it can be done.
( \
\l 14 What we are talking about are guidelines, not draft 15 procedures, guidelines. There are no draft procedures 16 proposed. We will certainly make the guidelines 17 available, and indeed at my request we are going to 18 investigate how the guidelines have not been previously 19 in the County's hands, given our understanding of the 20 history, but we will certainly make them available af ter 21 lunch.
22 JUDGE BRENNER: I guess I thought the 23 guidelines being reviewed by Mr. Ho?.ges were guidelines
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() 24 for the possible futuro draftino of procedures, and as 25 such, I envisioned that they would be pretty specific as
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON. D C. 20024 (202) 554 2345
8964 1 to the type of things that would be done, even though (Vl 2 they might not be written in procedure format as you 3 would present them. 8 4 MR. REVFLEY: I think that is correct, but the 5 procedures implementing them don't exist in draft, nor 6 would I imagine they will exist in draft un til the 7 guidelines are approved in some form, if they are 8 approved. 9 JUDGE BRENNER: Okay, but we are not just to talking about vague goal-oriented cuidelines. We will 11 know them when we ree them, I guess. 12 MR. REVELEY: We vill get it to you right 13 after lunch. r (
'u) 14 JUDGE BRENNERs Okay.
15 MS. LETSCHE: Had the Boa rd finished asking 16 questions? I was getting ready to move to Mr. Hodges' 17 qualifications. 18 JUDGE BRENNER: res. 19 BY MS. LETSCHE: (Resuming) 20 0 Mr. Hodges, have you participated in the 21 preparation of NUREG-0640? 22 A (WITNESS HODGES) No. 23 0 Have you had any participation in the ATWS
,s I / %j) 24 rulemakina?
25 A (WITNESS HCDGES) I had no participation in n ( ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE S.W., WASHINGTON, D C. 20024 (202) 554-2345
8965 (i 1 the writing of the proposed rules that went out for c) 2 comment. As far as reviewing the comments that come in, and the drafting of a Commission paper to propose a new 9 3 4 variation of the rule, if you may characterize it as 5 such, based upon the proposed rules and the comments, 6 there is -- a task force his been established to do 7 that, and one of the members of the task force is under 8 my supervision, and as part of my job and supervising in 9 this work, I am obviously discussing it with this 10 individual. I am also reading the comments that have 11 been received on the propoced rule. 12 0 Does your responsibility include any staff i 13 review of generic interim responses to deal wi th the g
\wi 14 AIWS event?
I 15 A (WIT. NESS HCDGES) Not specifically. i 16 JUDGE MORRIS: I am sorry, Ms. Letsche. I 17 don 't know what generic interim responses a re. 1 18 BY MS. LETSCHE (Resuming) 19 0 What I was asking, Judge Y. orris, was whether 20 or not Mr. Hodges reviews generic submissions or utility 21 submissions in response to the staff's requirement of 22 interim ATWS measures. I mean, interim in the period 23 prior to the conclusion of the rulemaking. Is that what [ 24 you understood my question to be? v 25 A (WITNESS HODGES) I think I understood your
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L.) ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8966 [^') 1 question then. Maybe I was trying to state your
's.J 2 question myself as you were going through it, and I may 3 have misstated it to myself. I did not review, for 4 example, the Shoreham specific submittals that came in 5 for the interim requirements. I have lookad at the P " generic" requirements, and the guidelines, emergency 7 procedure guidelines which a re offered as part of that 8 requirement. I say I have the primary responsibility 9 for reviewing the technical basis.
10 I should emphasize that there are two parts of 11 that review. One is the human factors review, and one 12 is looking at the technical basis, and another 13 individual is doing the human factors portion, but we do c
\ \ \/ 14 work very closely, and I am only looking at the 15 technical basis for those guidelines.
16 0 Have you reviewed an interim or a submittal 17 with respect to in te rim ATWS measures from any other 18 plants? 1 ! 19 A (WITNESS HODGES) Yes. 20 0 Which ones? 21 A (WITNESS HODGES) LaSalle, Fermi. Those for 1 l 22 sure. There may be one or two others. l l 23 0 How about Limerick? c.,
!s j 24 A (WITNESS HODGES) No.
25 C You said that you haven't reviewed the
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8967 Shoreham specific submittal about the interim (( ) 1 2 requirements. Is the staf f 's review of that submittal, 3 however, complete? 4 A (WITNESS H0DGES) When I say I haven't 5 reviewed, I did not review in the sense of writing the 6 evaluation. I have reviewed myself to my personal 7 satisfaction the Shoreham submittal. The evaluation, 8 for example, of the procedures that were written was 9 done in th e Prccedures and Test Review Branch. 10 0 Have you reviewei the training that Shoreham 11 proposes to provide to its operators with rerpect to the 12 mitigation of an ATWS event? _ 13 A (WITNESS HODGES) No, I have not. (s)
Have you reviewed any submittal f rom Shoreham l 14 0 15 pertaining to the recire pump trip system?
16 A (WITNESS HGDGES) What I saw was not very 17 descriptive. I believe we have got a question out 18 asking for more detail. Basically, what I have seen 19 merely said tha t they were installing such. 20 0 Is that something that is within the scope of 21 your responsibility? l 22 A (WITNESS HODGES) It is a join t responsibility 23 between my branch and the Instrument Control Systems g (_,! 24 Branch. 25 0 And is that review still open of the RPT p, 1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 G02) 554 2345
- 6968
(~1 1 system? V' 2 A (WITNESS HOCGEE) We are trying to get the I haven't seen the details of the syctem. 8 3 details. 4 0 So it is still open? 5 A (WITNESS HODGES) Well, in the sense that they 6 haven't described fully what they are using, yes. 7 0 You asid you haven't reviewed the training. 8 Do you know if the staf f 's review of the proposed 9 training is complete? 10 A (WITNESS HODGES) The staff reviews, not the 11 details of the training, but reviews basically, the 12 manpower commitment to training, how nuch effort goes 13 into the training. f)
\m) 1-4 JUDGE BRENNER4 r.r. Hodges, do you intend tha t 15 just as a generalization, I take it?
l No, I am not -- I had fairly 16 WITNESS HODGES: 17 substan tial discussions with the people who are l 18 responsible for looking at the training, and they do 19 review what I might call as a quantitative effort that 20 goes into the training from the standpoint of manpower 21 and dollars, but not the details of the training 22 program. What they do do is, they rely upon the testing 23 of the operator on procedures to verify that the () v 24 training has been done satisfactorily. 25 JUDGE MORRIS: Is the general syllabus looked (3 N,) ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE S.W., WASHINGTON. O C. 20024 (202) 554-2345
8969 [) 1 st, and the subject matter, come outline of what is t 2 included in training? 3 WITNESS HCDGES4 I am not really sure how much 4 they go into the detaile there. I know they don't go 5 into any details of the training. They may look at the 6 syllabus. I am just not certain. 7 JUDGE BRENNEF: I suggest to you, and you 8 don't have to answer unless you have covered this point 9 with the training people, that we have in at least one 10 instance and perhaps more that when there are contested 11 issues in a proceeding in which the particular training 12 for a pa rticula r thing was focused on, that the staff 13 may vary its general review and f ocus on th e details g, I e
\ -) 14 contained in -- down to the lesson plan, and so on.
15 WITNESS HODGES. That was discussed with the 16 people who had that responsibility, and they are in the 17 process of trying to upgrade what they do. They have 18 recently hired a number of people with background in 19 training, and it is their intent to get into additional 20 detail, but at this point they just have not done it. l 21 JUDGE BBENNER I think they have done it at 22 least once. I think what you described is their general I 23 approach, and it shouldn't be taken ar necessarily
,a
() 24 deemed sufficient by the staff, even dopending upon 25 where the focus on a particula r issue goes. l :/"'b,
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400 VIRGINIA AVE., S.W., WASHINGTON, O C. 20024 (202) 554-2345
8970 1 WITNESS HODGES: This is the approach that has ( 2 been taken on Shoreham, whether or not it is just a j 3 general approach, and also the approach that has been 8 4 taken on the ATWS, the training for the ATES procedures , l 5 in general. 6 JUDGE BPENNER: Okay. 'Ae will see if that l l 7 provides us with enough basis to support th e staff's ! l 8 conclusion. 9 BY MS. LETSCHE (Eesuming) 10 0 Mr. Hodges, have you reviewed the alternate 11 rod insertion system that LILCO indicates in their 12 testimony they intend to install at Shcreham? 13 A (WITNESS HODGES) No, I have not. (3 I
\_) 14 0 Have you reviewed any information from LILCO 15 concerning the modifications to the SDY system that they 16 have mentioned in their testimony?
17 A (WITNESS HODGES) I read over what they ! 18 described as having been done, and I am familiar with 19 the type of changes th a t they a re ref erring to. 20 0 You say you have read it over. You mean the 21 testimony? 22 A (WITNESS HODGES) Well, I think it was -- I l 1 23 believe it was also described in FSAR or one of the submittals to questions. I have read a description, I (v^') 24 25 believe, oatside of the testimony. I am just not -- I
,. \ \vl ALDERSON REPORTING COMPANY,INO, 400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554-2345
8971 () 1 just don't recall where I have seen it. v 2 (Whareupon, counsel for Suffolk County 8 3 4 conferred.) 0 Mr. Hodges, you indicated that you have not 5 reviewed the ARI system that LILCO proposes to put in. 6 Has anyone on the staff reviewed that? 7 A (WITNESS HODGES) That would be the review 8 responsibility of the Instrument and Control Systems 9 Branch. I presume they have looked at it, but I have 10 not verified that. 11 0 You said before that you didn't write the 12 evaluation, and I assume you are referring to the SER 13 evaluation of the ATWS mitigation measures planned by
\J-14 LILCO, but that you have reviewed some information, and 15 I can't remember your exact words, but sort of 16 familiarized yourself wi th wha t they are doing. On what 17 do you base your conclusion in the testimony, in your 18 prefiled testimony that the interim measures that are 19 being proposed at Shoreham satisfy the staff?
20 A ( WIT.N'ESS H0DGES ) Well, there are two things. 21 First off, there is a letter from Frank Schroeder to 22 Darryl Eisenhut which outlines the criteria against 23 which the ATWS procedures should be reviewed. I ( ) 24 Basically, this letter calls for such things as manually
- v l
25 inserting the rods, openin7 vents and drains on the s ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554-2345
8972 (v ')
^
1 scram discharge volume, resetting the scrams, a number 2 of items of this nature. The ATWS procedures were 3 reviewed against the criteria in tha t particular letter, 4 and satisfied all of those criteria. 5 On the basis of that com pa rison, the ATWS 6 procedures for Shoreham were deemed acceptable. 7 0 But you haven't reviewed the training, and you 8 haven't reviewed the RPT, and you don't know whether the 9 ARI has been reviewed, and I am not sure of the extent to of your review on the SDY. Is your review limited to 11 what you just explained about the procedures? 12 A (WITSELS HODGES) Now, when you say my review, 13 tha t is a little dif ferent. What I described was the
/^T 4 \>
4 14 review that was behind the SER for the ATWS proce'dures. 15 My review has gone considerably beyond that, because I 16 am reviewing them as part of the emergency procedure 17 guidelines, and looking into the details of the 18 technical adequacy, not just at whether or not it 19 satisfies the criteria in that letter. 20 0 The SER sections tha t your counsel had 21 admitted into evidence yesterday, those-are the ones l 22 tha t deal with LILCO 's mitigation of ATWS event? Is l 23 that right? l 24 A (WITNESS HODGES) Well, there is one, I think, (V~) 25 at 15.3 thst addresses the ATwS in particular. The l ?> l / ALDERSO'1 REPORTING COMPANY,INC, 400 VIRGINTA AVE., S W., WASHINGTON. D C. 20024 (202) 554-2345
8973 (i 1 other section talks in general about the review of
%)
2 procedures, and that review encompassed the ATWS 3 procedures, although I don't think it says ATWS 4 procedures explicitly in that particular writeup. Or 1.' 5 it does, it is only briefly. As an example, that 6 description talks about the testing of proredures on the 7 Limerick simulator, and although the ATWS procedures 8 were one of the procedures that were gone into to some 9 extent on that simulator, they were not culled out in 10 the list tha t is in tha t SER. 11 (Pause.) 12 JUDGE MORRIS: Hr. Hodges, takinc a quick look 13 at the Schroeder memorandum, it spems to be addressed to 1 i ('N k : i
\s/ 14 the emergency operating procedures for ATUS. Is there a 15 similar document tha t addresses training?
16 WITNESS HODGES: I am not aware of such. 17 JUDGE MORRIS: Is there any guidance in 18 writing to whatever part of the staff does this review l 19 on training as to what they should do? 20 WITNESS HODGES: I don't know of any. l 21 JUDGE MOPRIS: It is not included in the 22 s ta nd a rd review plan anywhere? 23 WITNESS HODGES: I do not normally review (~) V 24 against those rections of the standa rd review plan, so 25 you are beyond what I have really looked at now. j
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6974 ("'3 1 JUDGE MOEPIS: Thank you.
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2 BY MS. LETSCHE: (Resuming) 8 3 4 0 1:r . hodges, I assume you would ag ree with me ths t even based upon the analysis in 0460, that ATWS S events, some ATWE events can have very severe 6 consequences. Is that right? 7 A (WITNESS HODGES) Yes. 8 Q You state on Page 2 of your prefiled testimony 9 that it can be irgued that an ATWS mitigation system 10 need not be single failure proof. You use an 11 interesting phrase there, "that it can be argued that." 12 Is that year opinion? i 13 A (WITNESS HODGES) I don't think I have a 1 ,e \ i l ,(j 14 strong opinion ye t at this point that it would have to i l 15 be single failure proof or did not have to be single 16 failure proof. I would prefer that it be single failure 17 proof. 18 0 Would your preference for a single failure 19 proof system get stronger if we were talking about an l 20 event where you are isolated from the condenser? 21 A (WITNESS HODGES) When I make my statement, I
, 22 am referring to just the general design of the system, 23 and taking into consideration all possible ATWS type
(. events. (
) 24 25 0 And would you agree with me that reliance upon
(_) ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASH NGTON, D.C. 20024 (202) 554-2345
8975 ( w. 1 operator actions or proced"res to citigate an ATWS event \_) 2 rather thsn on hardware would give rise to more 3 potential for failures in the form of human errer? 4 A (WITNESS HCDGES) That is a pretty broad and 5 general question, but I think the answer is generally 6 yes. 7 MS. LETSCHE: Judge Brenner, if I could have 8 just a moment, please. 9 ( Whereu pon, counsel for Su f f olk County 10 conferred.) 11 BY MS. LETSCHE (Fesuming) 12 Q Mr. Hodges, directing your attention to Page 3 13 of your prefiled testimony, you state in the first e-(_)3 14 paragraph there that your conclusion or the staff's 15 conclusion that Shoreham can operate prior to the final 16 resolution of the ATWS issue is based on engineering 17 judgment and three factors. Your first factor is the 18 estimated re vi val ra te of anticipated transients with 19 potentially severe consequencer in the event of scram 20 failure. What do you mean by that? 21 A (WITNESS HODGES) I mean first off that I 22 think that the likelihood of ad .ATUS of rny type to 23 occur is f airly low. I think in NUREG-0460 it was
-u
() v 24 estimated a t about 2 x 10 probability per reactor 25 year. I don't have any baris to challenge that number, Ej ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
0976 Q U 1 so I am accepting that nu:ber as rr ssonably correct. 2 But in addition, there are a number of things that can happen that will tend to mitigat e the AT'4S. 8 3 4 One is that you don't always operate at full power, so 5 that if it o :urred, you wouldn't alvsys be at full 6 power. Many transients, you have the condenser 7 available as a heat sink, and a number of ATh'S events, 8 even though the rods did not go in on a scram signal, 9 the operator can be very effective in inserting either 10 all the rois or sufficient rois to terminste the event. 11 12 13 V' 14 15 16 17 18 19 20 21 22 23 ( I 24 wJ 25 (~\ N.] ALDERSON REPORTING COMPANY, INC, 400 VIRGIN!A AVE., S W., WASHINGTON. D C. 20024 (202) 554-2345
8977
) 1 0 With respect to the last aspect of your (R-'J 2 answer, that assumes that there aron't failures in other 3 equipment that the operator would be relying on, is that 4 right?
5 A (WITNESS HODGES) What do you mean? 6 Q Well, you said that the operator would have a 7 chance to take certain,actionc to mitigate the event, B but doesn't that assume that you don't have a failure 9 of, say, the RPT or the safety relief valves or other 10 hardware that the operator is going to have to rely on? 11 A ( WIThESS HCDGES) You still stated a very 12 broad question and I'm not sure how to answer your 13 question, because you have to assume some failures to (,,,) 14 get to what we 're talking about in the first place, and 15 then we're still talking about the operator takinc 16 ' actions with failures. So if you could be more specific 17 it would help. 18 (Counsel for Suffolk County conferring.) 19 0 Let's see if we can do it this way, Mr. 20 Hodges. In your last answer with respect to opera tor 21 actions, what equipment are you assuming that the 22 operator is going to be using? 23 A (WITNESS HODGES) I'm assuming the operator is (': V 24 going to be trying multiple things. One is that he's 25 going to try to reset his scram signal to see if he can
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8978 fm 1 -- if he tries to trip again, if it can be effective. (
\ _s) 2 He's going to start trying to manually insert rods one 3 at a time with his control system. He is going to open l
8 4 vents and trains on the scram discharge volume. Ha is 5 going to bleed air off the headers to get the scrar 6 valve open. 7 He ic going to go to the motor generator and 8 take the power of f there in order to try to get the rods 9 to go in. There are a number of steps of this type that 10 the operator will take in order to insert rods, either 11 through a scram signal or by means of the control 12 system. And not all the rods have to be inserted in 13 order to shut the reactor down.
,\
JUDGE BRENNEP: Mr. Hodges, I want to get (_) 14 l l 15 through my non-technical mind the alternate rod 16 insertion, ARI, context with what you just said. That 17 is something other than the manual insertion that you 18 are talking about, correct? 19 '41TNESS HODGES: Yes. I think at this point 20 we are talking about both the regular scram system 21 having failed and the API having failed, which would 22 take some combination of failures to get there. So I am 23 assuming at this point that both of those are failing l (~3 24 and now we're tal(ing about what the operator does.
\-)
l 25 Obviously, if the API works that is going to
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s/ ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554-2345
8979 1 come in in 15 or 20 seconds after the normal trip signal (~') us 2 and insert the rois, and there is no need to do all of 3 thase other steps. 4 JUDJE BRENNFR I 'm sure we will get to this 5 more with LILCD's witnesses, but Mr. Podges, do you know 6 how API is initiated? Is that an automa tic signal or 7 does the operator have to demand it? 8 WITNESS HODGES: I don 't think he has to 9 demand it. It is a signal that would follow with the 10 delay of the regular trip signal. 11 JUDGE BRENNER: I assume that -- well, I don't 12 know. Is there sharing of essential equipment of the 13 normal scram system and the API, such that a common mode ('h \,_) 14 failure could well occur? 15 WITNESS HODGES You are sharing the same 16 control rod drives and the same rods, but I think 17 electrically they are separate. 18 JUDGE BRENNEP: Okay. I'm sure we will, as I 19 say, get more on this la ter. I just wanted to get it 20 into context since you mentioned the manual insertion 21 step taken by the operator. 22 (Counsel for Suffolk County conferring.) 23 BY MS. LETSCHE: (Resuming) Mr. Hod 7es, de you know where the sensors are ( 'l 24 0 25 located for the RPT system at Shoreham? s '\s' ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
8980 r^'T 1 A (WITNESS HODGES) You have s high pressure
'O 2 signal which provides one of the trips, and I believe r 3 that would come off of the same taps that would be the l
l 4 taps for the reference leg on the level 5 instrumen ta tion . The other signal which would give you 6 sn PPT is low wster level, and I believe that is at 7 level two, so it is a water level signal. 8 0 But you haven't reviewed any Shoreham diagrams 9 or submittals to confirm that your assumptions are right 10 with respect to Shoreham, have you? 11 A ('4 IT N ES S HODGES) I have not reviewed the 12 specific Shoreham desien for that. I have information 13 from Shoreham that they use those signals and tha t is (a
\_) 14 normally what is used.
15 0 Do you know what pressure will trip the pump? 16 A (WITNESS HODGES) I believe it is 1120. 17 That is psig. 18 0 In the LILCO testimony they state that - and 19 let me direct your attention to page 11 of LILCO's 20 testimony. In the last paragraph of the answer before 21 question number 15 on that page, LILCO states that -- 22 the LILCO witnesses state that: "RPT assures that 23 reactor pressure is maintained well below acceptable f ') 24 limits." i 25 Do you agree with th a t statement, Mr. Hodges? L./ ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
8981 (~ ; 1 A (WITNESS HODGES) Well, for the analyses that U 2 I have seen, which are generic analyses with RPT, the 3 pressure remains lest than 1300 pounds even for the most 4 severe pressure transients. 5 JUDGE PRENNER: Mr. Hodges, just so I have 6 plucked your statement right now into context, that is 7 supportive of your view thst the concern isn't breach of 8 the pressure vessel, rather it is loss of the cooling, 9 the heat sink inventory over time? 10 WITNESS HODGES: Yes. 11 (Counsel for Suffolk County conferring.) 12 BY MS. LETSCHE: (Pesumina) 13 0 Mr. Hodges, in your opinion does the reduction m 1 l l
\_)' 14 in power that may be achieved by the RPT assure an 15 acceptable water level?
16 A (WITNESS HODGES) What do you mesn by an 17 acceptable water level? 18 0 That the water level is well below acceptable 19 limits, just to use -- above the top of the active 20 fuel. 21 A (WITNESS HODGES) Ini tiall y tripping the pumps 22 will reduce the power to the 30 to 40 percent range, and l 23 as the water level decreases from the normal control i i (^) R.; 24 range downward the power level would decrease. In the 25 current Shoreham procedures for ATWS, they are told to ( N)J ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345
8982 "1 1 have either HPCI or ECIC going. (G 2 They may have -- with those particular situations you could maintain, let's say 8 3 -- I think HPCI 4 will handle on the order of 12 to 15 percen t power. I 5 don ' t ha ve the actual number, but that is a good range. j 6 I have calculated the number for another plant, but not l l 7 specifically for Shoreham. 8 And co that if you say that you had the HPCI 9 system in operation, the water level would drop dcun 10 until the na tural circulation flow rate would support a 11 power level of that magnitude, and then you would tend 12 to reach a steady state level. If you drop all the way 13 down to the top of the active f uel, power is going to be 1 ( ') l \J 14 in the 8 to 10 percent range based upon calculations 15 that I've seen. So just operating of the HPCI system 16 Would definitely keep it above the top of the active 17 f uel, and you migh t need to throttle slightly to bring 18 the level down. l 19 (Counsel for Suffolk County conferring.) l 20 0 3r. Hodges, would the reduction in power that 21 may be achieved by the RPT ascume -- or assure that the 1 22 suppression pool temperature would remain below 110? 23 A (WITNESS H0DGES) No, the temperature will ( ) 24 still exceed the 110 degrees Fahrenheit, and in the 25 procedures that is the poin t at which the operator is [Q'l ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W WASHINGTON, D C. 20024 (202) 554 2345
8983 1 instructed to initiate the standby liquid control ( }) 2 system. 3 0 Mr. Fodges, on page 3 of your testimony, in 4 the second answer on that page you talk about ATWS 5 procedures developed by LILCO and say that they have 6 been reviewed and accepted by the NRC. Is the procedure 7 that, or the procedures that, you are referring to in 8 your testinony limited to the one that is a ttached to 9 the LILCO testimony on this contention? 10 A (WITNESS HCDGES) Well, I think the actual 11 approval may have been of sn earlier revision of the 12 same proced u re . But basically, the procedure that is 13 given in the LILCO attachment, it is procedure
\-) 14 29.02u.01.
15 0 And tha t is the procedure that -- just so I 16 can keep straight what it is that you've done, you have 17 reviewed that procedure, right? 18 A (WITNESS HODGES) Yes, I have. 19 0 Have you reviewed any Shoreham procedures 20 relating to maintenance of equipment that may be used to 21 mitigate an ATWS event? 22 A .(WITNESS HODGES) No. l 23 0 How aboat procedures relating to surveillance (3 / 24 or testing of tha t equipment? 25 A (WITNESS HOLGES) Vo. < ,o l NI l l ALDERSoN REPORTING COMPANY,INC, 400 VIRG!NI A AVE., S.W., WASHINCTCN. O C. 20024 (202) 554 2345
8904 (- 1 Q How about those relating to normal operating
't 2 procedures relating to that equipment?
3 A (WITNESS HODGES) Caly for the RHP system. 4 JUDGE BPENNER: Es. Letsche, the "you" in the i 5 question was Mr. Hodges? 6 MS. LETSCHE: Yes. 7 JUDGE BRENNER: And tha t is the way you 8 understood it, Mr. Hodges? e WITNESS HODGES: That in the way I understood 10 it, yes. 11 BY MS. LETSCHE4 (Resuming) 12 0 You indicated in discussing with the Board 13 earlier some possible changes or revisions to the (3
\._ ) 14 emergency procedure guidelines that are being reviewed 15 by you or by the Staff now, and I believe you said -- I 16 don't want to chstacterize your testimony, but something 17 about having a consideration of ATWS conditions and 18 other procedures, something to that effect?
19 A (WITNESS HODGES) I think what I referred to 20 there was a reorganiza tion of the guidelines, which 21 would then probably be reflected in a reorganization of 22 the emergency proced ures. Basically, the emergency 23 procedures or at least the emergency proced ure n ! (j 24 guidelines start out with a list of symptoms that would 25 indicate when you were -- f or e xam ple, a wa ter level L.) I ALDERSoN REPORTING COMPANY,INC, I 400 VIRGINTA AVE., S W., WASHINGTON, D.C. 20024 (202) 554-2345
\
8985 (m) x.s 1 indicative of a reactor trip or a high drywell pressure, 2 some signal of ti a t. type to signal to you to get into i 3 theemergency,fhoedures, as o; posed to your normal 4 cperating procedures. 5 . Once you were in these emergency procedures, 6 then you had t be keyed to the ATYS procedures or 7 wha tever, and the organize. tion ac to how you get there 8 vill be change'd'scomewhat. But, the: actual steps to be 9 taken to mitigate the ATWS should be very close to the 10 same. There a re so'me changes. 11 O Let me just make sure I understand what you 12 " e da n b y the logic changing. The particular instructions 13 } t o the operator with respect to how he gets to each of ( \ ; l l L' 14 the steps that he's going to take in t he prbcedure, is 1 / 15 tha t logic likely to change? ' i S s 16 A (WITNESS HODGET) As an eiacrile, for the ATWS
* ' /
x ' 17 procedures there is n5w what'EG calle'd --- h old on one
$ 2 y +
\
13 , secoqd. ,' s-19 (Pause.) l q is ,',. 20 A s (WITNESS HO GES) Okay. *Easically, you have
> . \
21 wha t's f ailed a reactor, control procedure, which is '
- 1 !
.(
22 broken down into subco'eponents. .One would be the 23 control of level, one wh>uld be control of power, one (o
~
! 24 would be control of reactor pressure, and one would be l
25 control of -- what have I said thus far? l \ > j ? \ l} e e i , bERSON REPORTING COMPANY,INC, [ 400 VIRGINIA AVE j 2.W., WASHINGTON, D C. 20024 (202) 554-2345
;[ .s -
8986 (~') 1 A (WITNESS CALONE) You've said all three. v 2 A (WITNESS HODGES) Okay. So basically you're 3 looking at those components, and dependina upon the 4 symptoms, whether y ou 've got , for example, a high 5 neutron flux still existing or a high pressure in the 6 reactor vessel or a low water level, then it will key 7 you to various subparts of the procedures. 8 And as far as the guidelines, the ATWS is 9 under what is known as a contingency. It's contingency 10 number 7, and it handles the part of the ATWS procedures 11 which affects the lowering of the water level. The part 12 of the ATWS procedures, though, which refer to trying to 13 insert the rods and the manual resetting of the scrams, E s# 14 inserting each individual rod manually, things of that 15 nature, are actually covered in the main proced u re , the 16 reactor control procedure. 17 Now, the current Shoreham procedures are not 18 organized quite in that fashion, but the steps are very 19 much the sa me. 20 (Counsel for Suffolk County conferring.) at Q Mr. Hodges, I think Mr. Carter mentioned, in 22 describing this revision, that another difference would 23 be that there would be an integration of ATWS into other 24 procedures. Do you know what other procedures ATWS ic 7-[] ( 25 going to be integrated into? (
.)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON D C. 20024 (202) 554 2345
8987 {) 1 A (WITNESS HODGES) Wall, I think I mentioned 2 this reactor control procedure, which is one of the main 3 procedures. Basically, the guidelines for the 4 procedures, the Revision 2 of the guidelines har two 5 main procedures. One is a reactor control procedure and 6 the other one is a containment control procedure. And 7 the bulk of the ATWS procedures would be contained in 8 this reactor control procedure. 9 The contingency which says, go and reduce the 10 water level to get the power level down, is in 11 contingency number 7 in the guidelines. And whether 12 tha t would be the exact structure of the Shoreham 13 procedures, I'm not certain. Put there would probably
'v) '
14 be at least a similar logic. 15 16 17 18 19 20 21 22 23 (v ) 24 25 ("')'S ALDERSON REPORTING COMPANY. INC. 400 VIRGINI A AVE., S W., WASHINGTON. D.C. 20024 (202) 554 2345
0988 1 0 The only procedures then tha t ATWS would be 2 incorporated into would be the reactor control 3 procedures and the containment control procedures? O, 4 A (WITNESS HODGES) Would you state that again? 5 Q I was trying to see if I understood what you 6 had said. Is it that the only procedures, emergency 7 operating procedures in which ATWS would be incorporated 8 would be what you have referred to as the reactor 9 control procedures and the containment control 10 procedures? 11 A (WITNESS HODGES) I don't think the ATWS 12 procedures are culled from the control procedures. The 13 ATWS procedures, if you want to call them that -- I () 14 think in the new guidelines they are called reactivity 15 control contingency or something of that nature -- they 16 are culled from the main reactor control procedure, not 17 from the containment control procedure. 18 (Whereupon, counsel for Suffolk County 19 conferred.) 20 MS. LETSCHEs Judge Brenner, although I would 21 very much like to follow up on this, I am afraid I can't l 22 do it until I'see some sort of material to be provided 23 by LILCO. 24 BY MS. LETSCHE: (Peruming) 25 0 Mr. Hodges, did you attend the demonstration l O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8989 (~'t 1 at the Limerick simulator which is referenced in the V 2 LILCO testimony, the demonstration of the ATWS procedure? 3 A (UITNESS HODGES) No, that was attended by 4 members of the Procedures and Test Review E ranch. 5 0 Well, do you know whether or not that 6 procedure or that demonstration, excuse me, utilized a 7 generic procedure or if it utilized th e Shoreham 8 specific procedure? 9 A (WITNESS H0DGES) It is my understanding it 10 was Shorehsm specific, but maybe the LILCO people could 11 elaborato. 12 A (WITNESS CARTER) That was a Shoreham crecific 13 procedure. p(-! 14 0 Er. Hodces, did the staff make any 15 recommendations for chances or additions to be made in 16 the procedure that was used at the Limerick 17 demonstration as a result of the demonstration? 18 A (WITNESS HODGES) It is my recollection there 19 were recommendations for some changes in the huran 20 factors area. 21 0 Do you know wh' ether or not those changes were 22 made? 23 A (WITNESS HODGES) I am not certain. Maybe the i (.m) RJ 24 LILCO people could answer that. 25 0 Well, let me just stay with you for a few (~') L. J ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8990 () 1 minutes. I certainly intend to ask the LILCO witnesses 2 some questions about this, too. 3 Do you know whether or not the staff po si tion 4 at tha t demonstration or af ter that demonstration was 5 that the procedures were complete at that time? 6 A (WITNESS HODGES) There were statements that 7 there were figures yet to be provided in the Shoreham 8 procedures, and that those should be provided. 9 Q Do you know if they were? 10 A (WITNESS HODGES) I don't think they all have 11 yet. But that didn't just refer to the ATWS 12 procedures. This was procedures in general that those 13 statements referred to. O 14 0 Well, I am asking you about the ATWS 15 procedure. Do you know if the ATWS procedure was 16 considered complete by the staff? 17 A (WITNESS HODGES) There are no specific 18 figures in the ATWS procedures, so those comments would 19 not have applied to the ATWS procedures. 20 0 When you are talking about the staf f 's 21 comments, are you referrino to the information that is 22 contained in Supplement 2 of the SER, Section 13.5.2.c? 23 A (WITNESS HODGES) I am talking about the ! 24 comments that were made relative to the figures 25 missing. There are other comments in that same writeup, O V ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
8991 l O 1 some of which will apply to the ATWS procedures. t V 2 0 Okay. 'i e l l , do you have a copy of that up 3 there with you, tha t portion of the second supplement of 4 the SER7 5 A (WITNESS HODGES) Yes, I do. 6 0 Okay. Directing your attention to Page 13-4, 7 was the ATWS procedure one of those that wa s reviewed in 8 the October 17, 1981, simulator exercise that is 9 referenced on that page? 10 A (WITNESS CARTER) Yes, the ATWS procedure was 11 reviewed during that time period. 12 MS. LETSCHE: Judge Brenner, I would like to 13 direct these questions to Mr. Hodges and get the staff's Ch
\j 14 position.
15 JUDGE bilENNER: Well, Ms. Letsene, you are 16 entilted to do that within reason, but one reason for 17 havino a combined panel is to get it all in one place, 18 and it struck me along the way this morning that there 19 were many instances when it migh t have been helpf ul to 20 get the view of the LILCO witness right there when we 21 were on the same subject. For example, and this is just 22 an example, at one point Mr. Hodges gave a figure at 23 which he believed -- that is a paraphrase of his words T 24 -- that RPT would trip with pressure, and it would have ('~'J L 25 been helpful to get -- precumably, if that was wrong, a p v ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
8992 1 LILCO witness wouldn 't have felt inhibited from jumping 2 in, and I say that so the witnernes know that, and I 3 think I would like to have their answer on this. You 4 have got some people on the panel who were there. 5 Now, I will let you do it in a few minutes if 6 you want to defer it, but it is nice if we can get it in 7 close proximity. You don't want to allow them to 8 respond now? I don't see why not. 9 MS. LETSCHE: Well, I got the response to 10 that, and I now know f rom M r. Carter tha t this is the 11 date on which that procedure was demonstrated. What I 12 vant to go over right now with ifr. Hodges, and I prefer 13 to do it now rather than break it up with comments from l'h (_i 14 LILCO, is the staff conclusion relating to that 15 demonstration. 16 JUDGE BRENNER: Well, the reason I jumped is 17 tha t he, Mr. Carter and other LILCO witnessec would 18 rightly take your comment to discourage them, and I want 19 to encourage them to jump in. So unless we are in a 20 particular area where it ic harmful, that is, you need 21 to zero in on what a particular witness knows, let's do l 22 it in the nature of -- in the name of efficiency. 23 MS. LEISCHE: Wall, Judge Brenner, I do feel (~') 24 that right new it is important to find out what the x/ 25 staff'c position is and what their review consisted of. O L.) ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
I l l 8993 1 1 1 1 I (~) 1 And Mr. Hodges is the staff witness here. < U 2 JUDGE EEENNEE. Wall, you have gotten Mr. 3 Hodges' answer, and I am not suggesting tha t you jump in 4 before he snswers, but after he answers, LI LCO 5 witnesses, feel free to jump in, and you show me where 6 you are hurt by it, Ms. Letsche. 7 BY S. LETSCHE: (Resuming) 8 0 Mr. Hodges, directing your a ttention to the 9 last paragraph on Page 13-4 of this SER segment, it 10 states that during the review it was noted that, one, 11 some plant specific da ta were not available, and noted 12 by a "(later)". Is that comment applicable to the AT7S 13 procedure?
,n.
(_) 14 A (WITNESS HODGES) No. 15 0 The second comment states that the graphs 16 referenced in the procedures need revision to improve 17 their usability. I assume that is one you referred to 18 before, that that is not applicable to the ATWS 19 procedure? 20 A (WITNESS HODGES) That is correct. 21 0 Comment Number 3 states, "There are a few 22 additional changes required in the procedures as noted 23 during the simulator exercises." Is that applicable to l l l (~] v 24 the ATWS procedure? 25 A (WITNESS HCDGES) I am not certain. , V ALCERSoN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S W., W ASHINGTON D.C. 20024 (202) 554-2345 L
8994 (N
%.)
1 0 It states here that the applicant has 2 committed to make -- to incorporate the plant specific 3 data when availsble and to make the agreed changes to 4 the procedures and the graphs. Do you know if that is 5 applicable to the ATWS procedure? 6 A (WITNESS HODGES) Obviously, the changes in 7 the graphs are not applicable. To the extent that I am 8 not certain about the third item, I can't answer you. 9 Otherwise, they are not applicable. 10 Q How about the la st sentence there, "The staff 11 will verify that the missing data and changes," and I 12 know missing data isn't going to be applicable, but tha t 13 " changes have been included in the procedures before
!D 'J 14 issuance of an operating license." Has the staff 15 verified tha t any n ecessary changes were included?
16 A (WITNESS H0DOES) I don't recall one as 17 applied to the ATWS procedures. But I was not thare. 18 JUDGE BRENNER: Mr. Hodges, who was there for 19 the staff? Do you know? 20 WITNESS HODGES: Yes, I do, but I am af raid 21 that my memory for names is terrible, and sometimes I 22 have trouble recalling them. Maybe his name is on one 23 of these pieces of paper. I /n; 24 WITNESS CARTER: Mr. James Clifford from the i %. / 25 staff was there. D. () ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON. D.C. 20024 (202) 554 2345
8995 (~') 1 JUDGE BRENNEPs I missed his name. xs 2 WITNESS CARTER: Mr. Janes Clifford. I would 3 like to say that the comments based upon the ATWS 4 procedure as were made by the staf f were incorporated 5 and a revised procedure was transmitted to the NRC. 6 WITNESS HDD3ES: Mr. Clifford is the gentleman 7 I have been tsiking with about this evaluation. I 8 apologize, but sometimes ny memory is just not very 9 good. 10 JUDGE BRENNEP: Quite the contrary. I think 11 during the course of this proceeding it has been. Is 12 Mr. Clifford, Mr. Hodges, also the person who is 13 reviewing the procedures, as well as being the one (E ') 14 present at the simulator exercise reviewing the ATWS 15 procedures? 16 WITNESS HODGES: He has been reviewing the 17 Shoreham procedures, and including the ATWS procedures. 18 , JUDGE BRENNER4 But now you, Mr. Hodges, are 19 going to be reviewing the specific proposed Shoreham 20 procedure? l 21 WITNESS HODGES: I am reviewing the 22 guidelines, the generic guidelines, if they were used to 23 revise their procedures. M r. Bill Kennedy in the same
,m j () 24 branch as Mr. Clifford is also working on the review of l 25 these guidelines from the human factors standpoint. He 1
[
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0996 (; 1 and I work very closely together. Once the guidelines 2 are approved and Shoreham modifies their procedures, it 3 vill probably be Mr. Clifford that would review that 4 again if he still ha s Shoreham. 5 JUDGE BRENNERs All right. Mr. Carter, you 6 referred to the staff's comments and the fact tha t you 7 believe LILCO has incorporated them in your proposal. 8 Were the staff comments in writing, or just oral 9 comments at the simulator exercise? 10 WITNESS CARTER: No, they were in writing. I 11 don't have a copy of them with me. They were 12 incorporated, and then th e revised procedures were sent
. 13 back. There was Mr. Clifford down there, and also s
14 members of Battelle Northwest Laboratories as well. 15 JUDGE BRENNER: Mr. Hodges, do you have Sr. 16 Clifford's formal comments on the simulator exercise? 17 I am not interested in the overall exercise,
, 18 just that they might relate to the testing of the 19 ef ficacy of the ATWS procedure on the simulator.
20 WITNESS HODGES: I read over a list of 21 comments. I may have them with me. I would have to dig 22 through and see. I am not certain, but I have read the 23 comments, and they culled out specific sections of the l (~'b i i, _) s 24 procedures, so I can go back and verify whether any of 25 those were ATWS procedure comments. I just didn't Q/' ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W , WASHINGTON, D.C. 20024 (202) 554 2345
8997 1 recall off the top of my head whether or not they were. ( }) 2 As far as the applicability of the simulator 9 3 4 itself, it is my understanding that the Limerick simulator could not be used to do a complete 5 verification of the AIWS procedures, but could only be 6 done partially, but I don 't kno w the details of t ha t . 7 That is just a statement that has been made in a 8 transmittal letter transmitting that evaluation over to 9 our Licensing Division. 10 JUDGE BRENNER: Tell me again where -- would 11 that he contained in some written staff eval ua tion, or 12 assessment, or comments also, that is, the extent to 13 which the Limerick simulator could be used for the ATWS h
'x.) 14 Shoreham procedura?
15 WITNESS HLDGES: Just one second. I will get 16 you the exact reference. 17 (Pause.) 18 WITNESS HODGES: This is a February 11th, 19 1982, memorandum for Robert L. Tedesco, Assistant 20 Director for Li ce nsing , Division of Licensing, from Joel 21 J. Kramer, Deputy Director, Division of Human Factors 22 Safety, Subject, Safety Evaluation Report Input, 23 Shoreham Nuclear Power Station Unit 1 [SNPS-1) Emergency i ) 24 O pe ra ting P rocedures a nd An ticipated Tra nsient Without 25 Scran. m ALDERSON REPORTING COMPANY,INC, l l 400 VIRGINIA AVE., S.W., WASHINGTON O C. 20024 (202) 554 2345 1
8998 E'i U 1 The last paragraph of the first page of that 2 letter says, "The purpose of our ATWS review was to 9 3 4 determine if interim requiren.ents to mitigate ATWS have been completed. Our technical review was performed as 5 required by Frank Schroeder's memo of June 9th to you. 6 Although the ATWS procedure cannot be fully exercised 7 because of limitations of the simulator, the ATWS 8 procedure is consistent with the guidance provided in 9 the June 23rd, 1980, memo from Frank Schroeder to you, to and is acceptable for issuance of a full power 11 license." 12 JUDGE BRENNERs I take it the enclosures to 13 tha t transmittal letter are the sections of the SER I L ') 14 supplement 2 that we are looking at? 15 WITNESS H0DOES: Yes. 16 JUDGE BRENNER. But the portion you just read 17 is from the letter, and therefore is not included in the 18 SER input? 19 WITNESS HODGES: That is correct. 20 JUDGE BRENNER: Okay. Thank you. 21 BY P.S. LETSCHE: (Resuming) 22 O Mr. Hodges, I take it from your comments and 23 from Fr. Carter's comments about the staff having (m) 24 questics and then LILCO responding to those questions
~a 25 that the ArWS procedure tha t was demonstrated in that
[ Q.) ALOCRSON REPORTING COMPANY,INO, 400 VIRGINIA mE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
i
, 8999 I'l 1 Limerick demonstration war not the procedure that is \_/
2 attached to the LILCO testimony. Is that right? That 3 was not the version of the procedure tha t is attached to 4 the testimony? 5 A (WITNESS HODGES ) I don't know. Maybe Mr. 6 Carter should answer that. 7 A (WITNESS CARTER) That is correct. At that 8 time it was only a draft. Although technically the 9 procedure didn 't change, it changed more or less on 10 human factors. 11 O Is the revision that is a'ttached to your 12 testimony, Mr. Carter, the revision tha.? was sent to the 13 staff following the receipt of their commen ts applicable ( ) i 14 to the Limerick demonstration? I 15 A (WITNESS CARTER) Y=s, it is. 16 (Whereupon, counsel for Suffolk County 17 conferred.) 18 JUDGE BRENNER: Gkay. I guess I was confused 19 before, Mr. Carter, with all of these revisions floating 20 around. So bear with us. You know them better than we 21 do. That is the problem. When you stated that further l l l 22 revision incorporated in LILCO's views the human factors ! 23 comments after the exercise of the Limerick simulator, I l (~ ( ,) 24 thought you meant -- I guess I thought you meant the 1 25 guidelines that Mr. Hodges was still reviewing, but you x/ ALCEPSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W , WASHINGTON. D.C. 20024 (202) 554-2345
9000 (') u-1 meant that the ATWS procedure that is attached to the O testimony in LILCO's view incorporates those comments? 3 WITNESS CARTER: The ATWS procedure attached 4 to the testimony is based on GE guidelines that came out 5 in July, 1980, and it was not based on the generic 6 guidelines that are now Revision 2. 7 JUDGE BPENNER: Let me start again. You had 8 received comments from the staff, including human 9 factors, comments after the sim ula tor exercise. Are 10 those comments incorporated and responded to in LILCO's 11 view in the procedure that is now attached to LILCO's 12 testimony? 13 WITNESS, CARTER: Yes, those comments have been n I k' 14 incorporated, and they are in the procedure that is 15 attached. 16 JUDGE BRENNER: And, Mr. Hodges, just so I 17 understand the chronology, Section 15.3 of Supplement 2 18 of the staff's SER, which reaches a conclusion with 19 respect to the Shoreham ATWS procedure, is that with 20 respect to the procedure as attached to the LILCO 21 testimony? 22 WITNESS HODGES: It is my understanding that 23 really those procedures were acceptable based upon the (,j 24 earlier version, but as far as satisfying the criteria 25 of Mr. Schroeder, which was really the basis for saying
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O C. 20024 (202) 554 2345
1 1 9001 l l l l 1 these were acceptable, these were more, I think, in the (m-) 1 ! l 2 line of recommendations that the staff made for the 1 3 changes. 4 Technically, the procedures didn't change. 5 JUDGE BRENNER I understand that, but we are 6 also interested in the human factors aspect, and I don't 7 know how far to take it with you, but this section that 8 was written by a staff member, I don't know, it doesn't 9 say anything that we have also made conments with 10 respect to human factors, so I don't know if this 11 conclusion is made before or after that. 12 WITNESS HODGES: I talked to Mr. Clifford, I 13 believe, before this Revision O was issued, and in his
' 14 mind they were s ec e pta ble , and he wrote the section.
15 JUDGE BRENNER: I can read the words, and I am 16 not being very clear. I can read the words in the 17 section that says the writer of that section thought the . 18 procedure was acceptable. I want to find out what 19 procedure he based that conclusion on, and then I want 20 to know how to weigh his conclusion in my mind, 21 depending upon whether he wrote that knowing there were 22 outstanding human factors comments, or if he wrote that 23 after seeing the response to the human factors comments, ,m ( ,) 24 and I am also not sure whether that person is Mr. Kramer 25 or Mr. Clifford or both, given the transmittal letter (o v) ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
I 9002 () 1 You also referred to. 2 WITNESS HODGES: Mr. Kramer would not have 3 been the reviewer. He is a manager. Mr. Clifford would (-)) 4 And really, to go -- I would be be the reviewer. 5 speculating to say exactly whether he was including the 6 incorporation of those comments or not. At the time 7 that I discussed with him, he did not have, I don't 8 think, this latest revision, but he may have been trying 9 to include the comments from that. 10 So, to go farther, I am speculating. 11 JUDGE BRENNER: To further emphasize the 12 futile nature of our discussion as of this moment, I at , 13 least don't even know what these " human factors" 14 comments are. 15 WITNESS HODGES: I will try to locate them 16 over the lunch break so we can discuss them. 17 JUDOE BRENNER: Ms. Letsche, whenever it is 18 convenient to you, we will take a lunch break. 19 MS. LETSCHE: Let me just ask, I think, only 20 one question. 21 BY MS. LETSCHE: (Resuming) 22 Q Mr. Hodges, you indicated that the Limerick 23 simulator wasn't adequate to fully go through the entire () 24 Shorehar. ATWS procedure. Do you know what the 25 inadequacies were or what it was tha t they were not able O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
9003 () 1 to do with the Limerick simulator? 2 A (WITNESS H0DGES) No, I don't. 3 MS. LETSCHE. This would be a logical place 4 for me to break, Judge Brenner. 5 JUDGE CARPENTER: Could the LILCO witness 6 respond to the last question? 7 WITNESS CARTER: At that particular time, I 8 think the simulator stalled for some reason. '/e ha ve 9 run the ATWS event en the Limerick simulater numerous 10 times for operator training, and although it probably 11 doesn't exactly model the ATWS event as predicted by GE 12 calculations, it does a fairly good job in predicting 13 the general trends of what happens during an ATWS 7_ ( ) 14 situation. At that particular time, I can't remember. 15 We were doing it between midnight and 3 400 in the 16 morning, and the system stalled about 4: 00 in the 17 morning, and I can't remember exactly why it stalled, 18 but it has demonstra ted that it can predict, and to some 19 extent, what happens during an ATWS. 20 JUDGE BRENNER Including being a good 21 simulation of the steps that the operator would have to 22 take at Shoreham? 23 WITNESS CARTER 4 Yes. We have run this 1 r">) (_ ,, 24 procedure for the operators during operator training 25 numerous times on the simulator, and they are abl e to O V ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9004 () 1 perform the procedure on the simulator, and that 2 includes the operators who took their license exam en (} 3 4 the Limerick simulator. JUDGE BRENNER: Ms. Letsche, I don't know if 5 you want to be helpful over the lunch break to the fact 6 that some of these documents have to be gathered up. I 7 think some of them that are pertinent are attached to 8 your cross plan. I haven't had an opportunity to read 9 them myself, because of the close time f rame in which we 10 got all of those attachments yesterday, and I don't know
. It if one of them is a thing that Mr. Hodges is going to 12 look for, but it might be.
G 13 MS. LEISCHE: I will go through and check (O 14 them, Judge Erenner. 15 JUDGE BRENNER: Well, just to add to the 16 potential amount of paper floating around tha t we 17 haven't focused on in the record , I don 't know why the 18 staff purposely did not also put Section 15.3 of the 19 basic SER into evidence. I am making no claim. I don't 20 know one way or the other whether there is material 21 there different or in addition to what we already have, 22 but since it is titled Anticipated Transients Without i 23 Scram, and consists of a greater number of pages than l () 24 just Supplement 3, it might have been pertinent to have i 25 put it in with tha testimony, but I will leave that up l l t ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
9005 (~l qj 1 to staff councel. It seems to have some brief 2 description of what would be looked for in the procedure 3 guidelines, at least. 4 WITNESS HODGES: I have to take the blame for 5 that. I didn't point that out to our attorneys, and I 6 didn't go back and look at it again, but I didn't 7 remember it as having that much pertinent information in 8 it. 9 JUDGE BRENNER: The test, I think, is arguably 10 pertinent. I point it out, and I am not claiming that 11 it adds anything tha t we don't already know through the 12 other pa pers. I don 't know. I got the hint when I read 13 Supplement 2 and it said, "We stated in the SER." l (^ 3 l
' 14 All right, let me state the obvious. Our 15 interest isn't in accounting for every possible piece of 16 paper floating around. However, our interest is in 17 being able to grapple intelligen tly with what the facts 18 are, and I am getting the sinking feeling that 19 notwithstanding your yeoman efforts, Mr. Hodges, that we 20 have been carrying you beyond your area of knowledge and 21 expertise as we want to delve into the efficacy of the 22 interim procedures, and I will let everybody think about 23 that over the break.
(m)
.. J 24 I also want to -- certainly we expect to hear 25 fully from LILCD witnesses on all of these points, and l /~h ! )
tj ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN D.C. 20024 (202) 554-2345
9006
\ 1 we may get all of the information by tne time it is all \s' 2 over, once all of the witnesses are involved, because 3 there are LILCC witnesses here who are cognizant of the 4 procedures, and presumably the training also.
5 We will be back at 1: 35. 6 (Whereupon, at 12:20 p.m., the Board wa s 7 recessed, to reconvene at 1:35 p.m. of the same day.) 8 9 10 11 12 13 , (D b/ 14 15 16 17 18 19 20 l 21 t 22 l 23 n 24 ( s) 25 I
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE.. S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9007 O 1 AFTERNOON _ SESSION 2 JUDGE BRENNER: We are back on the record, and () 3 we are going to go back to the County and allow Ms. 4 Letsche to continue her questioning in a moment. We 5 have at least one additional document before us. I 6 don't know if the parties want to state on the record 7 the status of the documents tha t came up this morning. 8 MR. REVELEY: Yes, Judge Brenner. LILCO 9 during the lunch break distributed to the Board and to 10 the parties a document entitled Prepublication Draft, 11 Emergency Procedure Guidelines, Revision 2, BWR 1 12 Through 6, May 20, 1982. This is the document to which 13 frequent reference had been made during the-morning 14 session. 15 JUDGE BRENNER: Let me suggest that off the 16 record, after we recess today, it might be helpful for 17 the parties to briefly get together and for LILCO to 18 point out which aspects of this document relate to ATWS 19 matters and also among those ATWS matters which aspect 20 or aspects are additions or changes, important ones, and 21 not just unimportant minor ones, to what the procedures 22 would require the operator to do as they are currently 23 attached to the LILCO testimony. 0 k- 24 MR. REVELEY: We will do that, Judge. 25 JUDGE BRENNER: Of course, if the County
)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9008 O 1 doesn't wish to do that, then you won't have to, but I 2 think it would be helpful, and if the parties find it () . 3 very helpful, it might then be helpful to highlight 4 those parts for the Board also a t your convenience, and 5 we will also leave the timing up to you, if not this 6 evening, whenever you feel it is appropriate. 7 Whereupon, 8 WILLIAM P. SULLIVAN, 9 JOHN A. RIGERT, 10 LEONARD J. CALONE, 11 HARRY T. CARTER, 12 EUGENE C. ECKERT, 13 HENRY C. PFEFFERLEK, 14 and MARVIN W. HODGES, 15 the witnesses on the stand at the time of recess, having l 16 been previously duly sworn, resumed the stand, and were 17 examined and testified further as follows: 18 WITNESS HODGES: Judge Brenner, may I make a 19 comment? Just before the lunch break, you asked a 20 question about which revision of the ATWS procedures Mr. 21 Clifford has approved and which ones the comments were 22 based upon. Over the lunch period, I talked with Mr. 23 Clifford. The series of comments were generated on 24 Revision C. The revision that the SER said was 25 screptable was Revision E, as in Edward. And now we are
}
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9009 O 1 talking about Revision O. 2 WITNESS CALONE4 Judge Brenner, if I may, th a t
) 3 is not a letter 0, it is the numerical zero, and it was 4 the revision that came immediately after E. The 5 difference between E and 0 is one word, and I can give 6 it to you right now if you would like.
7 JUDGE BRENNEF: Since you left it that way, 8 you might as well. 9 'JITNESS CALONE: As long as we are into this, 10 I will tell you something about plan t staff. 11 JUDGE BRENNER: Don't tell me how you 12 developed your numbering system, but whoever has been in 13 charge of the contention numbering system in this (~} 14 proceeding can also take over the numbering of I 15 procedures from now on. 16 (General laughter.) 17 WITNESS CALONE: E is a draft, and became a l l 18 Rev. O, and the only change was on the first page, l At the end of that line, it says l 19 Number 3.1.2. 20 " shutdown," " switch in shutdown." It was previously 21 " refuel." That is a position on the mode switch, the 22 reactor mode switch. So it was not a technical change 23 as far as procedure goes, but it was more consistent j ,T
- 24 with what the opera tor does in the shutdown. He moves 25 the reactor mode switch to shutdown, not th e ref uel l
(~)\ ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9010 1 position. 2 JUDGE BRENNEPs It sounds like a human factors () 3 aspect of the change, but I will let the parties 4 decide. S WITNESS HODGES: One further comment, based 6 upon looking at Revision C. I then compared the 7 comments that had been made against Revision C, and most 8 were incorporated, not all. There were a few that I 9 would Characterize as being trivial or not reflecting an 10 understanding of how the systems work, and when I spoke 11 with Mr. Clifford, he indicated these were questions 12 from the consultant and not himself, and so some of 13 those were not included, but most of the comments have l 14 been included in the version we are looking at. 15 JUDGE BRENNER: Okay. I don't want to belabor 16 the obvious. The fact that we may have spent time 17 talking about things that may turn out to be trivial is 18 a comment on what happens when we don't have all of the 19 information here so that we can see immediately that it i 20 is too trivial to go into, and of course the record 21 still does not know what the comments are that were not 22 addressed, but we appreciate the information you just 23 supplied and the fact that you spoke to Mr. Clifford. 24 Just to summarize, I guess it is obvious to 25 everybody Mr. Clif f ord in ef f ect reviewed Revision -- i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9011 . _.) 1 reviewed the procedure that is attached to the LILCO 2 testimony with the exception of that one-word change () 3 that Mr. Calone just indicated. 4 WITNESS HODGES: That is correct. 5 MS. LETSCHEs Judge Brenner, to help the 6 record out, I would like to have marked as the next 7 Suffolk County exhibit, and I don't know what the number 8 is -- 9 JUDGE MORRIS: Thirty-six. 10 MS. LETSCHE: Yes, Suffolk County Exhibit 11 Number 36 for identification, a document entitled 12 SP-29.024.01, Shoreham Transient With Failure to Scram 13 Emergency Procedure, and it is a three-page document 14 with the page numbers running from 21 through 23. I 15 think a copy of this has been provided to the Eoard as 16 an attachment to my cross examination plan. l 17 JUDGE BRENNER: I don't know if you indicated, 18 but it is Revision C. 19 MS. LETSCHE: Judge Brenner, the document -- I 20 don 't know what document you are referring to. The 21 document tha t I am referring to contains a list of what l 22 appear to be comments concerning procedure. 23 JUDGE BRENNER: Okay, I've got you. I will 24 reference it in accordance with your labeling of the ! 25 enclosures, and I was looking a t Enclosure 3 by . O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WA5ENGToN. D.C. 20024 (202) 554 2345
9012 O- 1 mistake. 2 MS. LETSCHEs This is labeled as Enclosure 4. () 3 JUDGE BRENNER: I am sorry. , 4 (The document referred to d was marked for 6 identification as Suffolk 7 County Exhibit Number 8 36.) 9 CONTINUED CROS EXAMINATION ON BEHALF OF LILCO 10 BY MS. LETSCHEs (Resuming) . 11 0 Mr. Hodges, do you have a copy of what has 12 been marked as Suffolk County Exhibit 36 for 13 identification? 14 A (WIT!iESS H0DGES) Yes, I do. 15 C And i's this exhibit the human factors comments 16 of Mr. Clifford that you have been -- that you described 17 before lunch? l 18 A (WITNESS RODGES) These are the comments of I 19 Mr. Clifford and the Battelle consultants, yes. 20 0 And these were the ones that arose out of the 21 Limerick demonstration of the Shoreham ATWS procedure? 22 ' Is that right? 23, A (WITNESS H0DGES) Yes. I think -- well, maybe 0 d
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' 25 ,
A (WITNESS CARTER) No, these did not arise out l l - , A
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O-' 1 and he has corrected you by saying these comments were 2 generated before the simulator exercise, and were () 3 modified to some extent after the simulator exercise, 4 modified or added to, I am not sure. 5 Also, there was some further finalization of 6 these comments by wa y of deletion, modifica tion, or 7 addition, or some combination thereof. 8 BY .5S. LETSCHE (Resuming) 9 Q Mr. hodges, are you familiar with the 10 addition, modification, or whatever additional comments 11 there were from the staff subsequent to the Limerick 12 demonstration? 13 A (WITNESS HODGES) I was not at the meetings, 14 no. 15 MS. LETSCHE: I would also like to have marked 16 as Suffolk County Exhibit Number 37 for identification a 17 document, the cover two pages of which is a memorandum 18 dated February 11, 1982, for Robert L. Tedesco from Joel 19 J. Kramer, Subject, Safety Evaluation Report Input, 20 Shoreham Nuclaar Power Station, Unit 1, Emergency 21 Operating Procedures and Anticipated Transients k'ithout 22 Scram, and attached to that two-page memorandum is 13 - 23 pages with an insert page following that. 24 JUDGE BRENNER: All right. It is so marked as 25 Suffolk County Exhibit 37 for identification.
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9015 ( 1 (The document referred to 2 was marked for 3 identification as Suffolk 4 County Exhibit Number 5 37.) 6 MS. LETSCHE: This document is headed on the 7 top, Enclosure 9, and it was provided to the Board as an 8 attachment to my cross examination plan. 9 JUDGE BRENNERa Yes. I guess we should 10 indicate for the record that those enclosure indications 11 are the County's indications in the context of 12 enclosures to the cross plan provided to the Board. T 13 MS. LETSCHE4 Judge Brenner, that is not quite (~/ 14 right. They are actually the staf f 's demarca tions, 15 because these were enclosures to the staff's discovery 16 responses provided to Suffolk County. 17 JUDGE BRENNER: Okay. Thank you. 18 BY MS. LETSCHE: (Resuming) 19 0 Mr. Hodges, do you have a copy of what has l 20 been marked as Suffolk County Exhibit 37 for 21 identification? 22 A (WITNESS HODGES) Yes, I d o. 23 Q And is this a cover letter that you referenced iO 24 this morning transmitting the SER input relating to the 25 ATWS procedures? i ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
i
. 9016 O 1 A (WITNESS HODGES) Yes, it is.
2 0 Directing your attention to Page 2 of the () 3 memorandum which is at the beginning of Suffolk County 4 Exhibit 37 f or id entification, that paragraph states, 5 "Although the ATWS procedure could not be fully 6 exercised because of the limitations of the simulator," 7 and then it goes on. I believe I asked you before 8 lunch, but I want to make sure it is with specific 9 ref erence to this sta tement. Do you know what the 10 limitations of the simulator were that are referenced in 11 this statement here? 12 A (WITNESS h0DGES) No, I do not. 13 A (WITNESS CARTER) I would like to add a little
}
14 bit to that. We managed to go through maybe two or 15 three minutes of the transient. The operator was able 16 to demonstrate quite a bit of the procedure. He was 17 able to turn on the stsndby liquid control system, and 18 he was able to secure the feedwater going in and just 19 run be. sed on HPCI and RCIC systems. We were able to 20 demonstrate a lot of steps in the procedures. It is 21 just that the simulator stalled out about two or three 22 minutes into the transient. 23 0 dr. Hodges, did the Limerick simulator 24 simulate the standby liquid control system hardware that 25 is present at Shoreham? ALDERSON REPORTING COMPANY,INC,
'" "" '"'^?"d* * ^S "'"" "- ? 2 24 <202, ss4 234s
9017 O 1 A (WITNESS HODGES) I am not familiar with the 2 Limerick simulator. I am only familiar as far as the () 3 boilers. I have only had training on the Brown's Ferry 4 simulator. 5 A (WITNESS CARTER) I would like to add to 6 that. Yes, it does. It has a key lock switch, and two 7 positions, a switch either returns on Pump A or Pump B. 8 (Whereupon, counsel for Suffolk County 9 conferred.) 10 JUDGE MORRIS: Did I miss something? I am 11 sorry. Did the simula tor simulate automatic operation 12 of the standby liquid control system, or manual? 13 WITNESS CARTER Yes, it does. I am sorry. 14 No, the Limerick simulator is a manual f unction. You 15 have to turn a key and then turn the switch, similar to 16 Shoreham. 17 JUDGE MOPRIS: Thank you. 18 BY MS. LETSCHE (Resuming) 19 0 Does the Limerick simulator include an ARI
- 20 system?
21 A (WITNESS CARTER) Not to my knowledge. 22 0 How about RPT7 23 (Whereupon, the witnesses conferred.) 24 A (WITNESS CARTER) I am not sure of that fact. 25 Q Is the con trol room configuration at the O ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9018 O 1 Limerick simulator the same as that at Shoreham? 2 A (WITNESS CARTEE) Please repeat your question. () 3 0 My question was, is the control room 4 configuration the same as it is at Shoreham? 5 JUDGE BRENNER: Okay, Ms. Letsche, here is 6 another example where I want to narrow the question. Is 7 the configuration the same with rerpect to everything 8 the operator has to do with respect to the ATWS 9 emergency procedure? I take it that is really what you 10 vant to know. 11 MS. LETSCHE: Yes, Judge Brenner, it is. 12 WITNESS CARTER: The 603 panel is very 13 similar. Some of the 601 and 602 panels, the layout is 14 a little bit different, and there are some differences. 15 Basically, the HPCI and the RCIC systems are pretty 16 identical. Again, standby liquid control is pretty much 17 the same. Of course, the simulatoc doesn't have the 18 back panels and some of the other things that you would 19 send the operator out in the field to do. We have to 20 cover that here in our plant training, but there are a 21 lot of similarities between the Limerick simulator and 22 Shoreham. 23 (Whereupon, counsel for Suffolk County 24 conferred.) 25 BY MS. LETSCHE: (Resumina) ALDERSON REPORTING COMPANY,INC. 00 _YlRGJNI A AyE Sy, W ASHINGTON, D.C. 20024 (202) 554 2345
._- _ 7- -
! l 9019
)
O 1 Q Mr. Hodges or Mr. Carter, if you can answer 2 this, what assumptions were used during the (/ 3 demonstration at the Limerick simulator? And let me ask 4 a couple of specific ones. What power level was assumed 5 at the time of the ATWS event that was simulated? 6 A (WITNESS CARTER) You are asking me to recall 7 something that happened about ten months ago at 4:00 8 o' clock in the morning. I think it was fairly high 9 power level, but I don't remember the exact power level 10 tha t we sta rted out a t. 11 Q Was the ATWS event that was simulated a total 12 failure to scram or partial failure? 13 A (WITNESS CARTER) It was a total failure to j 14 scram. I 15 0 How many operators were assumed to be on duty i 16 during the simulation? 17 A (WITNESS C ARTER ) We had three operators, a 18 watch engineer and two reactor operators. 19 (Whereupon, counsel for Suffolk County 20 conferred.) 21 JUDGE BRENNER: M r. Ca rter, I guess I don't 22 know what a watch engineer is. Is that like a shift 23 technical advisor, or like an SRO? 24 WITNESS CARTER: The watch engineer is an SRO 25 and the two other operators with them are R O 's. O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345 t
4 I 9020 () 1 BY MS. LETSCHE: (Pecuming) 2 0 Is that a minimum operator contingent for 3 operation? 4 A (WITNESS CARTER) No, the minimum contingent 5 is two, an SRO and an RO. There will be a total of four 6 on each shift at a minimum. In the control room it is 7 two. 8 0 I am not sure I follow you. You said in the 9 Control room would be two? 10 A (WITNESS CARTER) Yes. There would be four 11 per shift, two SRO's and two RO's. Two a re required to 12 be in the control room at all times. 13 0 Did the ATWS event that was simulated include 14 a recire pump trip? 15 (Whereupon, the witnesses conferred.) 16 A (WITNESS CARTER) Again, I don't recall 17 whether it has the recire pump trips in it. The 18 procedure itself has. You manually trip the pumps, if 10 they don't trip, I think the simulator does have the 20 trips in there, but I can't be 100 percent sure. 21 0 I assume f rom your earlier answer that you 22 don't know whether or not the simulator included'the use 23 of ARI. Is that right? ( ) 24 A (WITNESS CARTER) No, I don't. I am pretty 25 sure it doesn't. There would be no reason. I don't l l ALDERSON REPORTING COMPANY,INC. l 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202; 554 2345 l
w 9021 () 1 think they would simulate an ABI. 2 JUDGE BRENNER: M s. Letsche, those last two 3 questions sounded very familiar. I think you had just 4 asked them. 5 MS. LETSCHE: No, Judge Brenner. Earlier I 6 had asked if the simulator had the capability of 1 7 simulating thore functions. Wha t I was asking here was 8 whether or not the demonstration of the ATWS procedure 9 and the event that they were assuming that they had the 10 operator walking throuch included a recirc pump trip, 11 not necessarily the automatic one, or included the use 12 of ARI. 13 WITNESS CALONE: If I may just add one 14 statement about the operator training, in many cases one 15 of the operator's prime functions is to provide the 16 automatic action if it isn't done automatically, and the 17 procedure does require him to trip the recirc pumps, so 18 the scenario may or may not have had automatic recire 19 pump trip, to see if the operator would have tripped it, 20 so it is kind of hard. You can't be sure which scenario 21 was run, at least maybe not ten months ago. I know when 22 I was at the simulator, I have had them both ways. They 23 can trip it, but I am not sure whether it is an RPT trip v)
/ 24 or whether the simulator instructor trips the pumps, but one of the steps is to trip the recire pumps, so the 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W . WASHINGTON, D.C. 20024 (202) 554 2345
9022 1 operator would have to verify they tripped, and if they (]) 2 didn't trip he would have to trip them. 3 (Whereupon, counsel for Suffolk County O 4 conferred.) 5 BY .1S. LETSCHEs (Resuming) 6 Q Mr. Carter , does the Limerick simulator 7 provide the ssne transient response as would he 8 encountered at Shoreham with respect to the operation of 9 SR V 's ? 10 (Whereupon, the witnesses conferred.) 11 A (WITNESS CARTER) They haye the same type 12 valve. I think they just have three more than we do. 13 I 'm not sure. Shoreham and Limerick switches are very 14 similar in nature. 15 0 When you are demonstrating an ATWS procedure 16 on the Limerick simulator, does that demonstration 17 assume the operation of all 13 of the SRV 's? Or 14? I 18 am sorry. 19 A (WITNESS CARTER) Well, the instructor has the 20 ability to fail come SRV's. I don't remember whether we 21 have had any transients where we have f ailed. Some were 22 not. 23 Q Mr. Hodges, directing your attention to what i 24 has been marked as Suffolk County Exhibit 37, attached l 25 to that are a number of pages which appear to be a draft l I f~ l (-)/ l t ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE, S.W., WASHiNGio% 0 C. 20024 (202) 554 2345
9023 () 1 of the SER input. I notice that beginning on Page 10 of 2 that attachment, where the heading, 15.3, Anticipated 3 Transients Without Scram, appears, there are a number of 4 pages, a couple of pages of draf ts there th at don't 5 appear in the version of the SER which made its way into 6 the second supplement. Do you know why this additional 7 information was omitted? 8 JUDGE BRENNER: Ms. Letsche, I think for the 9 sake of the record as well as myself, you will have to 10 be more specific. I don't have any pages after Page 11 10. Do you mean the fact that there are reveral
~
12 different sections referred to on Page 107 13 MS. LETSCHE: I am sorry, Judge Brenner.
\/ 14 Maybe your copy did not contain the full version of this 15 attachment. The one that I have and, I believe, copies 16 tha t I have handed out --
17 JUDGE BRENNEPs I have it now. It is my 18 fault. I turned to the very last page because it said 19 Insert Page 10. My mistake. 20 WITNESS HODGES: A lot of the information 21 there which I would term fairly genersl discussions had 22 already appeared, I believe, in the original 15.3, and 23 so there would have been no reason to duplicate it in () 24 the supplement, particularly the discussion about the frequency of the events and consideration before the 25 O ALDERSON PEPORTING COMPANY,INC, 400 VIAGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554-2345
9024 () 1 Commission. I have not made a word for word comparison l 2 here in the last couple of minutes to see if that is 3 true of all that was omitted, but I expect that to be
/}
4 true of most of what was omitted, if not all. 5 (Whereupon, counsel for Suffolk County 6 conferred.) 7 JUDGE BRENNERs So that just what you are 8 sayinc, Mr. Hodges, is that instead of having all of 9 this writeup which you believe essentially if not 10 exactly repeats what was already in the basic SER, the 11 editor or some person performing that function in 12 finalizing Supplement 2 of the SFR substituted that one 13 sentence, "We stated in the safety evaluation report 14 that the applicant agreed to develop an emergency 15 procedure for an ATWS event," and then just plugged in 16 the last paragraph from this draft writeup, which is the 17 paragraph that alludes to the f urther review of the 18 revised procedure? 19 WITNESS HODGES: I expect that is what 20 happened. The editor in this case is usually the 21 project manager, and he compares what is,there against 22 -- in the letter against what is in the original SER, 23 and I would expect that he would decide not to repeat. () 24 BY MS. LETSCHEs (Fesuming) Mr. Hodges, directing your attention to 25 0 i ALDERSoN REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 l _
9025 () 1 Suffolk County Exhibit 36, that is, the comments that 2 were made, I believe, by Mr. Clifford, I would like to 3 ask you about a couple of particular ones in there. The { 4 one thst says, on the lefthand margin, 4.0, should the 5 IBM's be driven into the reactor, do you know what the 6 LILCO response was to that question or what the concern 7 was? 8 A (WITNESS HODGES) I think this was one of the 9 concerns by the consultsnt which I would sa y should not 10 necessarily be done at this particular point. It is 11 nice to do it if you have time, but because the operator 12 is trying to insett rods and do a nunter of other 13 actions to get the rods in, and if the power level is 5/ 14 high enough that it is a problem, his power is still 15 going to be on the source range, and not on the 16 intermediate range, then I don't think he achieves much 17 by inserting the IBM 's at this point, and so I don't 18 think that was incorporated into the final version, but 19 I don't think it should have been. 20 A (WITNESS CALONE) Let me add one point. In 21 the emergency procedure at 3.2 it talks about if the 22 reactor does scram and all rods go in, the operator then 23 moves to another procedure. In that subsequent 24 pro cedure it would hsve him putting in the IRM 's because ( 25 then he would be in a normal shutdown, but as Mr. Hodges
)
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
9026 () 1 says at this point in time he has immediate actions to 2 take care of, and IEM's are not one of them. 3 0 Mr. Hodges, again, moving down that page on
}
4 Suffolk County Exhibit 36, the first page, to the item 5 that is marked 4.1.1-4.1.2, it states how many rods not 6 fully inserted two below zero dash six position does it 7 take to indicate 6 percent power in any part of the 8 core. Was that incorporated into the revised LILCO 9 procedure? 10 A (WITNESS HODGES) No, it was not, and again, 11 it should not have been, because the power level, the 12 number of rods to cet any particular power level is 13 going to depend upon the rod pattern, probably even the , 14 burnup, and so you cannot put in one definitive number 15 f or tha t, and you don't want to add informa tion just to 16 confuse the operator, so I think this was another one of 17 these superfluous comr.ents that I referred to earlier. 18 JUDGE BRENNER: Who was this consultant, Mr. 19 Hodges? 20 WITNESS HODGES4 I think it was Battelle. I 21 don't remember which one. I did not think that a very ( ( l 22 pertinent comment. 23 JUDGE BRENNER: Doesn't the consultant know A how a reactor works? You wouldn't think so from this
/ )/
24 25 comment. 1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
9027 O i v1rstss noocrs. 1 taiax tot or the 2 consultants are human f actors consultants without a very 3 strong reactor background, but I am guessing nt that 4 point. 5 WITHESS CARTER: It was Battelle Northwest 6 Laboratories. I am not sure exactly what their 7 expertise was. I always thought it was more human 8 factors than it was technical. 9 BY MS. LETSCHE: (Resuming) 10 0 Mr. Hodges, moving down to the second item 11 listed under -- 12 JUDGE BRENNEE: Let ne stay with the other one 13 for a minute. 14 dS. LETSCHE: That is fine. 15 JUDGE BRENNER: Am I right, Mr. Hodges, you 16 don't have to know a lot about how a reactor works to 17 realize that you couldn't come up with a definitive 18 number for how many rods you would need for the 6 19 percent power indication in any.part of the core? You 20 would know that it would vary, as you indicated. 21 WITNESS H0DOES: That is my understanding. It 22 wouldn't take a lot to do that. Yes. 23 JUDGE BRENNER: I guess when I find one that [ 24 even I know it surprises me that somebody would make 25 that comment. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024(202) 554 2345
)
I 9028 1 (General lauchter.) 2 BY MS. LETSCHE: (Resuming) 3 0 Mr. Hodges, directing your attention to the 4 second item listed next to 4.2 in this document, it 5 talks about rewording after starting SLC Pump A, check 6 during SLC injection for system operation, flow meters, 7 ammeters, et cetera. Are there SLC flow meters at the 8 Shoreham plant? 9 A (WITNESS HODGES) No, there are not. 10 0 Do you know how the operators at Shoreham are 11 supposed to find out the information that presumaaly was 12 the source of the concern in this comment? 13 A (WITNESS HODGES) I think they would determine O 14 the flow rato by tracking the level in the standby 15 liquid control system tank, but maybe again some of the 16 LILCO people would like to elaborate on that. 17 A (WITNESS CALONE) The operator has available 18 to him the standby liquid control tank level, and when 19 he initiates standby liquid control by moving the 20 switch, he gets an indi stion that his squibb valves or 21 his isolation valves have fired. He gets an indication 22 on the an switches related to flow, but his key 23 indication in this case would be level dropping in the n 24 main tank, which would tell him that the pumps are 25 pumping liquid out of the main tank, and his pressure O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9029 l( ) 1 indica tion , which would tell him discharge pressure. 2 JUDGE BRENNER: Excuse me. Where in the LILCO 3 procedure attached to the testimony is that indicated? {} 4 I am trying to find the step. I am at 3.6.1, where he 5 is to start on either A or B. 6 WITNESS CALONE: 3.6.1 has him starting A or B 7 standby liquid control pump and injecting the entire 8 contents into the tank. We get back to the concept of 9 system training, and an operator, when he takec any 10 action, is expected to look for the required results of 11 that action. In this case, he is trained is part of the 12 standby liquid control or any system that when he takes 13 his action he has to look f or a positive indication that 14 that action was affirmative. He han been trained to 15 look at the tank level to verify injection. 16 JUDGE BRENNER: How fast would that tank level 17 indication start to move if the A tank or if the A pump 18 is working correctly? 19 (Whereupon, the witnesses conferred.) 20 WITNESS CALONE: I would say tha t he would get 21 some indication on the instrument within probably a few 22 minutes of injection to gat a realistic movement on the 23 indicator. It would take on the order of over an hour to inject the whole tank. So I would say within a ( 24 25 minute he would have an indication as to whether we are O c ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9030 () 1 pumping or not, and he has also got amps immediately 2 which tells him if he is pumping fluid. 3 JUDGE BRENNER: 'Jhat does the training tell 4 him? What do you tell him in training with respect to 5 wha t he should do af ter he starts the A pump? 6 WITNESS CALONE: He is to verify a level drop, 7 and tha t he has pressure in the squibb valves, and the 8 squibb valves have fired, and by indication of the pump 9 pressure and the amps and the tank levels there is a 10 combination of inputs to him tha t d etermine that the 11 standby liquid control is injecting. If the pump 12 doesn't start, he would have no amps.
, 13 JUDGE BRENNER: Is he trained, or do you think 14 it appropriate for him to be trained tha t he has to sta y 15 there for a minute or two to verify this occurrence 16 vis-a-vis what else he is supposed to be doing at the 17 time?
18 W ITN ESS CALONE: He will initiate, and based 19 upon the scenario or the transient you are in, I would 20 not expect him to be standino there waiting for that 21 level to drop immediately. I would have expected him to 22 proceed with the immediate actions and come back and 23 verify that he has standby liquid control being () 24 injected. Let me say one other thing. 25 He is stationed l (S) ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554 2345
9031 () 1 at the same location. He is not running around the 2 control room. Most of the absence he is taking is on 3 the 603 panel, which ir the front of the reactor panel, {} 4 so it is not that he has left or he has gone out of the 5 room or gone into the plant. It is all in the same 6 area. 7 JUDGE BRENNER: Is there something in the 8 training, given that it is not continuous? I understand 9 what you said, that he is in essentially the same 10 physical location, but is there sometaing in the 11 training that says, remember to go back in a minute or 12 two and verify that you have got the A pump working? 13 WITFESS CALONE: Well, you have to remember 14 that his actions right now are to reduce power, and that l 15 is driving him to do whatever actions he is going to do, 16 including verifying that he has a poison being injected 17 into that vessel throwing that power level around, and 18 so it becomes part of his integrated operation 19 training. 20 JUDGE BRENNER4 Mr. Hodges, even though you 21 are not the human factors person, as we have discussed, 22 there is that melding of disciplines between somebody 23 such as yourself, who is systems oriented in terms of l () 24 understanding whether the procedure could be more 25 clearly written. Do you think it would be a good idea ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9032 r (_) 1 to have the procedure flag the fact tha t he has got to 2 go back and verify that activation of the A pump is 3 resulting in the successful introduction of the tank 4 contents of the boron? 5 WITNESS HODGES: I think it could be useful. 6 As has been pointed out, he has got an indication that 7 his pumps are running from the power to the pumps, and 8 so with the pumps running he has a f airly good 9 indication that he may have injection, and an indication 10 or a caution to come back and verify level drop. It 11 would probsbly be appropriate, but the most ef f ec tive 12 means he is going to have for reducing the power is 13 going to be inserting the rods, either manually or 14 resetting the trips and getting automatic trip, or one 15 of those actions, and to that is where I think his time 16 is best spent. 17 JUDGE BRENNEP Staying with Mr. Hodges just
- 18 for a minute, and I will give you a chance in a second, 1
19 Mr. Calone, but I understand what you say. He is going 20 to be busy with a lot of things, and that is part of my 21 point. I am not suggesting putting something in the 22 procedure that says, don't do anything else until you 23 verify it, and I certainly don't mean to be dictating () 24 25 the writing, but I am talking about some sert of -- and I certainly understand the concept of leaving details to ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345 l - . . _ . - - . _ . .. -
9033 l O i- treining so thet you don t c1 utter u,oroceeures, but 2 within all of those concepts I am suggesting soliciting 3 your comment on something that says, verify that it is 4 working in the course of the next X time, or some other 5 way of expressing it. 6 WITNESS HGDGES: I think it would be a good 7 idea to have something that says, go back and verify 8 that the level has dropped. I don't think you want to 9 specify a time frame, because I think if the operator is 10 respondina to a lot of things in a hurry, he loses track 11 of the time frame, unless you have got a horn going off 12 somewhere to tell him that time has elapsed, and he has 13 got enough alarms in the control room already, so I 14 would not vsnt to specify a time frame for it, but maybe 15 a cauticn would be appropriate. 16 17 18 19 20 21 22 23 24 25 O l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9034 () 1 JUDGE BRENNEE: You anticipated my thought of 2 what happens when a lot of horns go off. Mr. Calone, 3 you wanted to add something ? V(~S 4 WITNESS CALONEs Yes, sir. Your statement is 5 well taken. As a matter of fact, it is included in this 6 procedure. The first action under subsequent operator 7 action is to verify immediate operator action is 8 completed. So once he gets to the point of Ster 9 3.6.1.2, he would then go back to the beginning of the 10 procedure and recycle through his immediate actions to 11 verify that they have all occurred as he anticipated 12 them to occur. 13 JUDGE BRENNER: I see. Okay. What step is
~# 14 the operator trained to include under that label, verify l
15 immediate operator actions? Does he go back to 3.07 I 16 suggest that because that.is the step that is labeled 17 immediate opera tor actions. 18 WITNESS CALONEs Yes, that is correct. 19 JUDGE MORRIS: Is it your understanding that i 20 an operator would essentially memorize all of these 21 steps and immediate actions? 22 WITNESS CALONE: The requirement is for them 23 to memorize all of the immediate actions on all of the () 24 emergency procedures, yes. JUDGE MORRIS: Wouldn't it be implicit really 25 O l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9035 () 1 in each action thit he took that he would somehow verify 2 that the result expected did occur? 3 WITNESS CALONEt Acain, as part of his 4 t ra ining , he is expected to look for the results that he 5 has duct initiated. However, when you get to these 8 procedures, it does get complicated to some extent, and 7 that is why thera is a specific sign-off. He ha's a n 8 initial box on tha right of that statement to verify 9 that he actually did do tha t , if that answers your 10 question, but it is generic in our procedures. The 11 first subsequent step is to verify the immediate actions 12 have been taken. 13 JUDGE MORRI5: And do all of the operators get 14 the simulator training on this? 15 WITNESS CALONE: Yes, they do. 16 JUDGE MORRISa How many times do they run 17 through a transient like this? 18 WITNESS CA10NE: It would actually vary. 19 There are required tra nsients that an operator must go 20 through, some of which are ATWS procedures. Just to 21 explain briefly, an operator always starts from a steady 22 state condition, and he is in that condition for a 23 period of tine. It could be minutes. If he is doing a () 24 25 normal evolution, like a startup, it could be an hour just to give him startup practice. Somewhere in tha t ALDERSoN REPORTING COMPANY,INC. 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9036 () 1 evolution he is going to get some transients, maybe an 2 ATWS. So, he may have twe during his training program. 3 He may have a dozen. It would depend upon the 4 instructor, but he must document the fact that there was 5 at least one ATES transient that he worked throuch in 6 the procedure as part of his training, so every operator 7 does go through ATWS training. 8 JUDGE M3 PRISS How is his performance 9 evaluated? 10 WITNESS CALONE: It is evaluated by the 11 simulator instructor, which are not LILCO people. These 12 are presently at Limerick. They are General Physics. 13 At Dresden it was General Flectric. I have only seen (~/1
~- 14 the sheets once. It is basically a checkoff list, 15 satisfactory, unsatisfactory, and comments, and there is 16 one per person, one per operator, and then we get the 17 end results back at the plant after they finish their 18 training.
19 JUDGE MORRIS : It sounds Itke whst you just 20 told me was the end recult. You get the overall 21 evaluation. What does he look for during the training, 22 during the transient? Does he check to see that each 23 operating step is done in sequence? Does he evaluate () 24 25 whether the operator is floundering around a little bit, or whether he has to go back and check his procedure? ( i l l l ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9037 () 1 WITNESS CALONE: I would say the simulator 2 instructor is looking for, one, the ability of the 3 operator to operate, that he doesn't get confused in 4 there, his ability to handle the procedure, his ability 5 to recognize symptoms, his ability to maneuver around 6 the control room and get to the place he wants to be and 7 do what he is supposed to do. It is all-encompassing, 8 looking down on the individual to see how he performs, 9 that the end result is sa tisf actory, completion of the 10 transient. So it is everything you said plus maybe a 11 little more. 12 JUDGE MORRIS: Thank you. 13 JUDGE BRENNER: Just to close the loop on the 14 last sequence, even though you stated operstors are 15 expected to merorize immediate operator actions and 16 procedures, including the immediate operator actions in 17 the ATWS procedure, nevertheless, in normal -- in the 18 real world the operator has these written procedures and 19 is trained to refer to them as an aid to the operator's 20 memory as distinguished from the testing and training 21 situation, correct? 22 WITNESS CALONE: That is correct. 23 JUDGE BRENNER: In addition, I note tha t -- () 24 25 and it is in the record, but just because the procedure is in the record, but just to tie it up here, there is a ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S W., WASHINGTON, D.C. 20024 (202) 554 2345
9038 () 1 box on Face 3 of the procedure labeled Caution occurring 2 after Section 4.u, which states "Do not shut down SLC 3 injection once it has been started until the SLC 4 colution tank is verified to be empty." Now, I take it 5 that although that doesn't serve the same purpose as the 6 4.1 requirement to verify immediate operator actions, 7 including that you have initisted flow, but at that 8 point he is going to have to reverify whether or not -- 9 he is going to have to reverify the contents of the tank 10 if he is goina to pay attention to that caution. 11 '4ITNESS C ALOKE: The caution was put in there 12 to warn the operator that cutting off standby liquid 13 control prior to total injection may cut him short on A k/ 14 reactivity at the end of the transient. It wasn 't mean t 15 as a subsequent followup. I am certain that before he 16 got to that step he knows that his standby liquid 17 control is injected. 18 JUDGE BRENNER: Thank you. 19 ( Whereupon, counsel f or Suf f olk County i 20 conferred.) 21 B Y !!S . LETSCHEs (Resuming) I ! 22 0 I don't know who to ask this question to, so I 23 will just ask it to the panel in general. If the () 24 25 standby liquid control system is activated so the pumps are running but the squibb valves don ' t open, do the l j ( l ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AE. S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9039
' **e r 11er v 1ve o# **e 11=e- a e-O retter t e= =r 2 that open?
3 A (UITNESS CALONE) Yes. The relief valve would I O. 4 open, but that is at a higher pressure than normal 5 injection, so the operator would at least know that he 6 is at a higher pressure. He is at a relief valve set 7 point by his pressure indication. And he will also Know 8 the squibb valvec didn't fire because of the continuity 9 circuit associated with the squibb valves. 10 (Whereupon, counsel for Suffolk Ccunty 3 11 conferred.) 12 0 In that event, though, the level of solution 13 in the SLC tank would get lower, right, because the pump 14 would be pumping that stuff out? 15 (Whereupon, the witnesses conferred.) 16 A (WITNFSS CALONE) I believe it returns to the 17 section of the pump. Just let me check that. 18 (Pause.) 19 A Yes, it does. The indication he would get 20 again would be the higher pressure on the higher than 21 normal injection pressure. The recire would -- the i 22 relief valve would lift, and he would return back to the 23 section of the pump, and these are positive displacement 24 pumps, so technically the level won't drop. They will 25 just need the same amount of fluid around the circuit or O' ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l l 1-9040 t () 1 the closed loop from pump suction to discharge and back 2 again, so the level technically will not drop since 3 there is nowhere for the level to go. , 4 0 Mr. Hodges, goinc back to Suffolk County-5 Exhibit 36, the next iten after the one we were just
. 6 discussing also labeled 4.2 sta tes, "Which pump will be
[' 7 used to ensure adequate mixing of the boron solution?," 8 Do you know the answer to that one? 9 A (WITNESS HODGES) Yes. I think if you go to 10 the Version C of the procedures and look at that 4.2, i t ill is a discussion that dould start either A or B standby 12 liquid control pump, and I gather that the people who 13 were asking the question, which one of those two pumps ( 14 would be used to ensure adequate mixing, and the answer i 15 is neither and again, I think this is one of the
, 16 instances enere the questions reflected a lack of 17 understanding of the system. It was stated more from a 18 human _ factors standpoint, trying to get some l
[' 19 clarification. f 20 A (WITNESS CAATER) I would like to add to i t 21 that. Based on the September meeting, it has become
, 22 evident that some of the remarks or some of the comments
-t .>
23 were really no t app ropria te , and tha t is one of the l 24 things that was beneficial from the meeting in September. l 25 JUDGE BRFNNER: Mr. Hodges, one thing I don't i ALDERSON REPoitTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
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4 factors person, and then you,have somebydy such ' a's c yhl l, 5 yourself or somebody who works for you. jWhy'isn't the ' j ,
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,- ,6 human factors person's comments coordinated through=your x 7 brahch before they are sent d'u t to a utility? '
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r f., , y 8 WITNESS H0DGES ? < u ' ' fha t is a $ery.pood question, J 4 .'.l l, 1N t,/ ( 9 but I don't have'aujnswer.
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',' .10 JUDGE BRENNER:
- You migh,t win t to suggest a j ;
s( n i> 11 change to the s ta f f 'G/. ope ra ting sp'rocedures.
.. ,b ,/ G-12 Yes. l-i< W ITJi ESS '4' g d'C \ f]fD.S s \
l ' 13 ' AY IS d'L SCllE s (Resuming) / b . Ecdger, N'jlu3t to try to cut , this short, v r c 14 e P, e' s' Jr.
,' $ ' 15 maybe you' :,o uld iJ e n'rtif in Suff;olk' County Exhibit 36
+s , s, .< ; ,1 l d > , z' (J.
" ,16 thar'c6mments that ' iou/frel are in th,e category that you 17 have described for us,/ these -
~
h urtaa'<f actors commen ts tha t r i
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is maybe yo,u feel were no+p~ appropriate.
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19 A ( WITNESS 300,GES) Just the ones that are not ' l c' s J > (j
/ 20 appropriate 7' .There is ,1so d couple tha t a re just
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J It is just /
- 21 comments tha t you .,can' t rec 11y l'ncorporate.
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22 comments on our qu.fst'3cns, so 6o you w' ant the sum total l 4 . 1, / ,# .- I ? '. ! 23 of those or only thy /ches that vprejnot appropriate? l s ], l I j 24 0 [. I would like .),oth t of those, please. E f. .
- 25 aP CWITNESS HODGES) 4.1.1-4.1.2, j
well, there are i a -- i ' . 1 ( -
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! ALDERSoN REPORT!NG, COMPANY,INC, it a4./"c
'j - , ,f t l- e ft,1 k 400 VIRO:P4A AVE.. S.W. WASHINGT AD.C. 20024 (202) 554 2345 i*
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90842 a C 1 two of those. 2 JUDGE BRENNER4 Excuse me. Let me interject. p 3 Normally we bind these things in at the end, depending d 4 upon the use that is made of it. Given what we are 5 about to embark on, it might be useful for the record to 6 bind in Suffolk County Exhibit 36 for identifica tion, 7 not in evidence, but f or the convenience of the rea d e r 8 of the record, since Mr. Hodges is about to comment on 9 the comments, if you will, if that is okay with 10 everyone. 11 MS. LETSCHE: It is fine with me. 12 MR. REVELEY: It is fine with us. 13 JUDGE BRENNER4 Okay. It is still only an , 14 exhibit marked for identification, and what I think of l i 15 it for its evidentiary worth you may only find out if 16 you try to move it into evidence, but we will hind it in i 17 for convenience at this point. 18 (The material referred to follows.) 19 i 20 21 22 23 O < 25 O l l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON, D.C. 20024 (202) 554-2345
. l~ ,- ENCLOSURE 4
*.,* $,Q~lA($-Q g&y
' ~
SP 29.024.01 Shoreham Transient with Failure to Scram Emergency Procedure 1.0 You need to give the operators a better idea of what constitutes a valid scram signal. O 1.0 A determination of rod position needs to de made somewhere in the procedure. . 1.1 An ATWS could also have all rods inserted but not fully. 3.1.2 Mode should be capitalized; In all cases the capitalizaton in the procedures should match that of the control panel (c.f. 4.4.3.5). 3.4 This should be the second subsequent opera' tor action. 4.0 The first subsequent operator action should be to-verify immediate operator action (c.f. 4.4.4.1.b). 4.0 Should the IRM's be driven into the reactor? _ 4.1 Rewrite this step in a standard IF..., IF NOT... logic format. p V 4.1.1- Need to be more specific on which indications to use for core 4.1.2 power, and how many instruments are needer 5bove 6T,. 4.1.1- How many rods not fully' inserted to below 0-6 position does it
'2 take to indicate 6% power in any part of the core.
4.2 Verify isolation of RWCU. Make separate step. Do not use
" isolation / isolate" to make conditional steps.
4.2 Reword after starting SLC pump A. Check during SLC injection for system operation, ficw meters, ammeters, etc. If not . operating, start the E pump. 4.2 Which pump will be used to insure adequate mixing of the boron i solution? l () 4.2 Specify which tank "the tank refers to. 4.3 Reword to clarify which systems the fica rate refers to. , i
.i-p womi)
KPN3 i O
mercency Procedure (Continued) ' Shoreham Transient with Failure to Scram 4.4 Are there enough operators to do all these substeps concurrently? tr aot. is there e preferred order' l O 4.4.1.1 Each breaker should appear on a separate line with its own ch'eckoff. 4.4.1.3 Restore what? 4.4.2 and Combine these 2 steps.into 1 step with 2 subtasks and 4.4.3 rewrite using standard logic format. 4.4.4 Is there a difference between steps 4.4.3.1 and 4.4.4? 4.6 How does the operator know he has this condition? 4.6 " Caution" - Be consistent in the use of acronyms SLC or SBLC. 4.7 Is there a preference for which of these steps should be tried or does the operator have to make that determination? If the 1etter. specier the 4arorimetio" eece uers to mexe t8et O determination. Logic of the step is unclear. 4.7.1 Should this be the main turbine bypass valve? 4.8 How do you use a consideration? 4.8 How does operator determine when reactor is to be placed in cold shutdown? If so, capitalize, 4.8.2 is " slow" speed marked on control panel? if not, indicate the range of speeds that corresponds to " slow". 4.8.2-4.8.3 Are these considerations or actions? Also, 4.8.3 Rewrite the Caution and list action step separately. specify the methods by which the operator can make the determination of tenporary dilution of the boron in the core. 4.8.3 Second Caution: This is an action steo and should be rewritten as sucn. Also, second Caution is not clear.
-E?-
l
~
Shoreham I ansient with Failure to Scram keergency Procedure (Continued) 4.8.3 What if the main condenser is not available? 4.10 How dces the operator find a source of water with the proper O V boron concentration? Should such information preced 4.10? A - U
.70_
i e h t -
9043 () 1 WITNESS HODGES: There are two comments 2 labeled 4.1.1-4.1.2. There is a comment we discursed 3 tha t is labeled 4.2, talking about the flow meters. 4 Ihere is another one on 4.2 which talks about the 5 mixing. Another one on 4.2 which I would classify more 6 as a nitpick. I don't think it was in the revised 7 procedures. It says, "Specify which tank 'the tank' 8 refers to." I don't necessarily think it is irrelevant, 9 but I thins it is a nitpick. 4.4 is strictly a question 10 that you can't include in the procedures. 11 Similar to 4.4, 4.6 is again a question that 12 you cannot incorporate. The same -- well, there are two 13 comments on 4.6, similar to the one labeled 4.7. It is ( 14 a question asking about pr9ference, but does not suggest 15 anything to the procedures. u.7.1 was included but I 16 think again is a nitpick. The one that is labeled 17 4 8 2-4.8.3, I age.in would consider to be somewhat of a 18 nitpick, although I think there were some changes made, 19 but I am not certain of that. The one labeled 4.8.3, 20 again, a question that could not be included in the 21 procedures. The steps for that could be, but the 22 question itself could not be. And I think u.10 would 23 also be in that Ostegory. () 24 25 4.6, JUDGE BRENNER: Mr. Hodces, just looking at 4.6, how does the operator know he has this , O ALDERSON REPORTING COMPANY,INC, j 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
1 9044
]
() 1 condition? I don't know what he is re f e rri ng to, 2 looking at this comment. What was your comr.ent on the 3 comment? Wha t didn 't you like about the comment? i 4 Depending upon what the comment refers to, it could or 5 could not be a valid comment in the abstract. 6 WITNESS HODGES. The second u.6, Version C 7 said, after the reactor is shut down, in Revision C, 8 Sectin 4.6 says, after the reactor is shut down, and 9 then it tells what to do, and ro, I am assuming that the 10 question there is, how does the operator tell when he is , 11 shut down. 12 JUDGE BRENNER: Okay. Say no more. Well, I 13 guess I should let you finish the thought f or the record. (wa 14 WITNESS H0DOES: The operator has definite 15 criteria for when he is shut down. 16 (Whereupon, counsel for Suffolk County 17 conferred.) 18 BY MS. LETSCHE: (Resuming) 19 0 Mr. Hodges, with respect to two of the 20 comments you have listed as being questions that t i 21 couldn't be included in the procedures, particularly u.4 22 and 4.7, the concern here seems to be whether or not 23 there is a preference for the order in which steps are
.)
) 24 taken. Do you know if any changes were made in the 25 procedures to address that concern about preference in O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9045 l 1 the order of steps to be taken? (]) 1 2 A (WITNESS HODGES) Give me a ninute, please 3 (Pause.) O 4 A (WITNESS HODGES) The final procedures do not l 5 list a preference. However, they appear to be listed in 6 the order of preference. 7 A (WITNESS CALONE) If I may, in Rev. O, since 8 that is what we are talking about, the steps to be 9 followed, 3.5 indicates tha t f ollowing attempts to scram 10 the reector are to be performed concurrently if manpower 11 is available , and it goes through a whole list of things 12 tha t can be done. I can go down them step by step. 13 Some are located in the control room. Some are located l (> (- 14 in the relay room, and some are located in th e reactor t 15 building. The question always comes into effect as to 16 what actually got you to this point in time, what , 17 scenario, what transient that would make available or 18 not available people in the field to perform the field 19 work to check these things. l 20 A (WITNESS HODGES) I believe you are talking 21 about 4.7. 22 A (WITNESS CALONE) This is the recurrent item. 23 I believe the reference is to the individual steps to () 24 25 scram the reactor. JUDGE BRENNER: '4a i t a minute. Let me jump
}
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9046 () 1 in, Mr. Hodges. Eear in mind that the number references 2 in these comments, because they were to a different 3 revision, is not necessarily consistent. 4 WITNESS HODGES: I have. bo th revisions in 5 front of me. 6 (Whereupon, the witnesses conferred.) 7 BY MS. LETSCHE: (Resuming) 8 0 Let me just see if maybe I could clear this 9 up. My question, Mr. Hodges, was, with respect both to 10 wha t is labeled as 4.4, which is, I think, what Mr. 11 Calone is addressing, and to 4.7, which is what I think 12 you were talking about, if that helps. 13 A (WITNESS CALONE) That is correct. I withdraw 14 my statement, because I was in another step. Let Mr. 15 Hodges continue. ! 16 A (WITNESS HODGES) My statament I just made 17 applied to the 4.7 comment, and I think they are listed 18 in the order of preference. 19 A (WITNESS CARTER) I would like to add to that, 20 yes, they are. Tha t is the order of preference. 21 A (WITNESS HODGES) And then the one for 4.4, 22 are there enough operators to do all of the substeps 23 concurrently, and if you had only two operators, which () 24 25 is what you have in the control room initially, that probably would not be enough to do all of them O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
9047 ('i 1 concurrently. However, you have two others that can be U 2 called up very quickly and, for example, you would not 3 send one of your control rocm operators down to open O 4 vents for the scracs. You would send one of your other 5 operators down. So, with that in mind, you could 6 perform a fair number of these simultaneously. 7 JUDF,E BRENNER: Through no fault of the 8 witnesses, of course, the record gets very difficult 9 with these different numbers. Let me just make sure I 10 understand you. '4 . 7 , the reference to Section 4.7 in 11 Suffolk County Exhibit 36 happens to be the same number, 12 4.7, in Attachment 1 to the LILCO testimony. Am I right 13 so far? ("T ( s/ l 14 WITNESS HODGES: The 4.7 in that exhibit, I 15 think it is 36, really gets into steps 4.2.1 and 4.2.3 16 in Revision O. 17 JUDGE BEENNER: Okay, thank you. And I infer 18 that the reference to 4.4 in Suffolk County Fxhibit 36 19 for identification is the portion that Mr. Calone was 20 referring to in Attachment 1 to the LILCO testimony 21 which is section 3.5 and subsections thereafter. Is 22 that correct? 23 WITNESS HODGES: That is correct. 24 (Whereupon, counsel for Suffolk County
)
25 conferred.) O I I l ALDERSON REPORTING COMPANY,INC, l l 400 VIRGINIA AVE, S.W., WASHINGTON, D C. 20024 (202) 554-2345
90148 O 1 BY MS. LETSCHE: (Resuming) V 2 0 Yr . Hodges, in the revised preced ure that is 3 attached to the LILCO testimony, is there a preferred 4 order listed for the concurrent actions referenced in 5 Section 3.57 My question is, is the order in which they 6 are listed here the preferred order? 7 (Pause.) 8 A (WIINESS H0DGES) It is difficult to say it is 9 a preferred order. I think it is an order that you 10 would start from from the control room and doing those 11 things you could do most easily, first from the control 12 room and then coing down to those that you might have to 13 send someone out to do. So in that kind of sense, it 14 has some preference associated with it, but whether he 15 went to do the breakers first or the scrammer system 16 first is an example. I am not sure there is a 17 preference there. 18 JUDGE BRENNER: Mr. Hodges, I inferred that it 19 is not, at least not contrary to any preferred order. 20 Is that correct? 21 WITNESS HGDGES: I think that's correct. 22 WITNESS CALONE: .Yes. Let me say that this is 23 not in preferred order. I don ' t think we tried to do 24 that. It is significant steps the operator can take by 25 location, I think, is a better way of looking at it. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9049 O V 1 (Whereupon, counsel for Suffolk County 2 conferred.) 3 nY MS. LETSCHE (Resuming) O 4 Q Mr. Hodges, you stated a minute ago that with 5 respect to the concurrent opera tions suggested in 6 Sect'.;n 3.5, that the two operators in the control room 7 could do all of those things, but that there were others 8 who could be called up. How many people would be 9 necessary to perform those actions concurrently as 10 suggected in this procedure? 11 A (WITNESS HODGES) Maybe the problem is with 12 the concurrently, because the strictest definition of 13 the word " concurrently" wouli mean exactly at the same y, 14 times where there would obviously be some time delay, l l ! 15 for ex3mple, if the operator went down to where the 16 CED's were located and was trying to operate valves 17 there as well as doing things with the control units, I 18 mesn, scram valves plus other things at that point. 19 They are very close to simultaneous, but not exactly 20 simultaneoas, but with that modification to the word ! 21 " concurrent" I think you could do it with four. 22 A (WITNESS CALONE) Let me jump in a second. 23 Step 3.5.1 and 3.5.2 and 3.5.3 are all done by the l ( 24 reacter operator, one individual on the front panel. v. 25 All of those controls are on the front panel. When you O i ALDERSoN REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9050 l l 1 get dcwn to 3.5.1, then you are talking about one
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2 individual going to th e relay room, which ir one flight 3 below the control room, and that is a natter of opening 9 4 a panel and pulling fuses. Tha t von 't take more than 5 about two minutes from the control room to exercise. 6 That same individual could then go out to do 7 Steps 3.5.2. Now, 3.5.3.3 is a restoration, so ve 8 wouldn't be into that point. We wouldn't be restoring 9 it right then. So basically the first three steps are 10 being done by the control room operator, not the second 11 operator in the control rcon but the main operator in 12 the control room. That is all taken :sre of from the 13 603 panel, the reactor panel. (~% 'q_,) 14 Then you have one action in the relay room 15 directly downstairs, and then you have an action out on 16 the elevation 63 on the reactor building, which is on 17 the same floor as the control room, dealing with the 18 vent air and scram valves. So, I don't think you need 19 four individuals to perform those functions, but we have 20 four. 21 (Whereupon, counsel for Suffolk County 22 conferred.) 23 A (WITNESS HODGES) Let me say the main thing (~'N 24 that is intended here by concurrently is, you don't go L) 25 all the way through and complete one action before you O
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ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9051 I 1 l, im'- ., .< o t, so the operator wculd not sit there and () I 1
- - ;i :to vith injection rods minually from the
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'trobnd do that for ten or fifteen minutes
)re to try out one of these other actions.
' finhtating it in this way is tha t You are i
!nqyhese things together.
? i 0
lalone, let me ask you, is that what LILCO I. '
! at arocedure by the use of the term
)
i ncuf i i ' Yes, tha t is correct. The i t Af ES3 CALONE) I hroaerator would -- the reactor operator in I I
' co a would be d oing most of the individual
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l 1 io n: sly sequentially, becauss each one n s o y"';
.uir' .
The field operators ey be doing one
.t w o of those items concurtstlY, depending u
. in .enario we are into as t what got us to J
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ALDERSoTING COMP ANY. INC, I i 400 VIRGINIA AVE., SNNGTON. D.C. 20024 (202) 554-2345
t 9052 1 MS. LETSCHE4 3.5.1.
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2 JUDGE BRENNER: Thank you. 3 WITNFSS CALONE: He knows very shortly after 4 he tries to select and move some control rods in front 5 of him whether or not the roi sequenca control system 6 will permit him to do that. In addition, his training 7 would have told him which permits would not allow him to 8 do it anyway, so there are some configurations he can be 9 in that he wouldn't even bother with that, because he is 10 locked out from using it based upon the system design 11 itself. There are other times he may attempt to use it, 12 but he would know pretty quick whether or not the logic 13 will allow him to use, to move individual rods quick, n and by quick I am talking 15, 20 seconds. 14 () 15 BY MS. LETSCHE: (Resumino) 16 0 If the logic tells him he can't move one 17 particular rod that he selects, is that sufficient for 18 him to then move on to the next step, or is he then 19 supposed to go and select another rod? 20 A (WITNESS CALONE) No, he would probably select 21 three rods, or try to select th ree rods. After the 22 third rod, he would give up on it. It is basically l 23 getting into three sepa rate rod groups. 0 Assumina that with the first rod he selects, S 24 25 he is able to cet that in, how long does it take for him 1 t v) ALDERSON REPORTING COMPANY,INC, 400 VIRGIN A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2245
9053 q 1 to move that rod in? V 2 -A (WITNESS CALONE) That would depend upon the 3 position of the rod. It travels at a constant rate, so U 4 if it is full out versus two notches, it would vary. 5 (Whereupon, the witnesses conferred.) 6 A (WITNESS CALONE) I believe regular drive on 7 emergency in, and that is not a scram, but on an 8 emergency in from full out is about 48 seconds. 9 0 And does he have to wait until that rod is all 10 the way in before he moves on to another one? 11 A ('JITNESS C ALONE) No, on an emergency in, 12 which is a control on the reactor panel, there is no 13 timer involved, and I won't get into the timer O Q 14 sequences, but there is no timer involved for him to 15 reselect another rod any time that he would like to 16 select another rod. Normally, once a rod gets past 17 four, notch four, and is driving iGSwe would let go, 18 becaure it will coast all the way in. 19 From thst point, he would than go get wha t we 20 would call a hot rod or power rod and grab that one and 21 try to drive that one in past point four, notch four. 22 Once you g?t to notch two or zero, the rod is 23 technically in. There is no power left in it. And so 24 he would grab the hot rode, which are the rods in the 25 notch 40, 36, 34, 30, in that range, drive them in as O ALCERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
l 9054 1 fast as he can. He would be selecting the hottest rods g x, xs l 2 in the core. And, as I say, once he gets past notch 3 four, let it go and immediately reselect another hot rod 9 4 or power rod to reduca power as rapidly as possible. 5 (Whereupon, counsel for Suffolk County 6 conferred.) 7 MS. LEISCHE I would like to have marked as 8 Suffolk County Exhibit Number 38 f or identifica tion a 9 document with the heading United S ta tes Nuclear 10 Regulatory Commission Office of Inspection and 11 Enforcement, dated July 3, 1980, I.E., Bulletin Number 12 80-17, Failure of 76 of 185 Control Rods to Fully Insert 13 During A Scram at A BWR. This documen t has on the top n () 14 of it En clo s ur e 1, and was enclosed with my cross 15 examina tion plan. I think the Board has copies. 16 JUDGE BRENNER. All right. It is so marked as 17 Suffolk Co un ty Exhibit 38 for identification. 18 (The document referred to 19 was marked for i ! 20 identification as Suffolk l 21 County Exhibit Number 22 38.) 23 BY MS. LETSCHE: (Resuming)
/'N 24 0 Mr. Hodges, do you have a copy of what has L.)
25 been marked as Suffolk County Exhibit 30 for 10 V ALDERSON REPORTING COMPANY, INC. 400 VIRGINIA AVE., S W., WASHINGTON. O C. 20024 (202) 554 2345
1 I 9055 l l 1 identification? I"3
\# 2 A (WITNESS ECDGES) Yes, I do.
3 0 Are you familiar with this document? 4 A (WITNESS HODGES) Yes, I am. 5 0 And is it fair to state that this is a staff 6 recommendation of actions to be taken following the 7 partial failure to scram incident at Frown's Ferry that 8 occurred in 19807 9 A (WITNESS HODGES) Recommendations might be a 10 little bit of a weak word. 11 Q Are these requiraments? 12 A (WITXESS H0DGES) I don't recall that an order 13 was sent out, but it was pretty strong. [) N_/ 14 JUDGE BRENNER: How about, the staff expected 15 that these things would be done, and if they weren't 16 done, the staff would then consider whether to issue an 17 order? 18 WITNESS HODGES: Yes. 19 BY MS. LETSCHE: (Resuming) 20 0 Directing your attention to Page 3 of Suffolk 21 County Exhibit 38, Hr. Hodges, Item Number 6 on that l 22 page states, "In order to mitinate the consequences of 23 an ATWS event, enhanced operability of HPCI, RCIC, SLCS, r~3 24 RPT/RHR/ pool cooling and and main steam bypass is l L .) 25 essential." Do you know whether or not the staff has ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
9056 l formed any review of the operability of these systems ('] v
) the Shorehan plant with respect to their ability to f-4 iga te the consequences of an ATWS event?
\ \
' '! - A ( W IT NES S HODGES) Some of these don 't make l
I se to apply to Shoreham yet, since they haven't i i tated, and in fact A and B under Item 6 would not 1 t issarily apply.
! l O Well, let's talk about A. Has the staff i
teved surveillance procedures or maintenance i 1tedures at Shoreham for the systems that are tirenced up in the beginning Paragraph 6? 1: A (WITNESS H0DGES) I have not personally. I am i 10 sure wha t level of detail those procedures have been p)i ( 14ewed a t. j 1E (Whereupon, counsel for Suffolk County
! 1Ee rred . )
l 17 0 How about Pa ragra ph C under Item 6 here? Has
)
18 type of review that is referenced in their 50.59 1 Sew been conducted for the Shoreham plant? 20 JUDGE BRENNER. Why don't you get to the H 2ttance of the requiremen t, because if you hang him up 22he applicability or lack thereof of 50.59 to a 23o pe ra t in g -- to a plant that has never received an g 24atino license , you are going to be diverted, and it 25t be important to where you want to go. You want to
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ALDERSON REPORTING COMPANY,INC, I 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 1
9057 1 know whether the staff or LILCC has considered using 2 both pumps at the same time to increase the SLCS flow,
- 3 correct? \-) 4 MS. LETSCHE: Yes, Judge Brenner, that's 5 right.
6 WITNESS H0DSES: I again personally would not 7 have been involved in th a t review, so I am not sure wha t 8 kind of detail. I don't know if someone else here would 9 like to give an answer. 10 WITNESS RIGERT: As far as Paragraph C is 11 concerned, we have done a conceptual design review and 12 concluded that it would require major modifications to 13 operate two pumps at once. The pump suction piping () 14 would have to be modified to give us adequate NPSH, and 15 the pump discharge to the reactor vessel would have to 16 be rebuilt, and it was to the point of being a F1 17 million type fix, not at all possible before a fuel 18 load , and also really a subject of a rulemaking, and 19 Paragraph A has been cancelled out by Supplement Number 20 5 to this SIL or to this bulletin. The only valid 21 paragraph now would be B, and I guess that is a 22 procedural question. 23 BY MS. LETSCHE: (Resu ming ) 24 0 Mr. Eigert, you said that -- I think your 25 answer was, we have performed a conceptual design O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9058 7- 1 review. Is that 1 LILCO review? 2 A (WITNESS RIGEET) Well, Stone and Webster did 3 some analysis for us. 4 0 You weren't referring to a staff review, were 5 you? 6 A (WITNESS RIGERT) No. We, LILCO and Stone and 7 Webster. 8 0 Mr. Hodges, to your knowledge, has the staff 9 reached a conclusion as to whether or not the SLCS flow to at Shoreham has been increa sed to the maximum consistent 11 with safety? 12 MR. REVELEY: Excuse me. Objection. That 13 cuts to the rulemaking directly, the capacity of the in i T 14 SLCS. t) 15 JUDGE BRENNER: The way you asked the question 16 does. As we indicated in the ruling on the motion to 17 strike, we are interested in the sensitivity of the time 18 involved vis-a-vis what the Commission might have had in 19 mind wi th other reactors and how that might affect the 20 procedures, and basically what the operator has to do 21 and wha t time frame you have in the transient. So, you 22 can keep it to that in going to the efficacy of the 23 interim measures. (~'S 24 If you are asking, would it be better overall ' ._ ) 25 to have faster flow, that is not going to h el p us in (
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ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S W., WASHINGTON, D C. 20024 (202) 554 2345
9059 73 1 terms of the overt measures. But if you want to try to V 2 establish what the flow change might be with two pumps 3 and then only if you are then ready to relate that 4 through the witnesses, through your questions, to what 5 effect that har on the time for operator actions, that 6 would be okay. 7 BY MS. LETSCHE. (Resuming) 8 0 Mr. Hodges, with respect to the interim 9 measures being taken by Shoreham in response to the 10 staff position on the ATWS issue, has the staff reviewed 11 the use of one pump in the SLCS system with respect to 12 the a r.o u n t of time available to the operators to 13 mitigate the ATWS event? In other words, the effect of
/m t
() 14 the use of one pump as opposed to the use of two pumps 15 on the time available to the operators to mitigate an 16 ATWS event. 17 A (WITNESS H0DGES) I think the SER that wrote 18 off on the acceptability of the procedurec, I don't 19 think went into the time available with one or two l 20 pumps. The criteria were those criteria specified in l 21 this letter from Frank Schroeder to Darryl Eisenhut, l 22 which did not include the pump flow rates, and as long 23 as the criteria in that letter were satisfied, then the (~N3 24 procedures were found to ba acceptable.
\.m) 25 I have looked at times involved for one I
i ("'; V ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
9060 1 standby liquid control pump, and I have not a v 2 quantitativo but a qualitative feel for what two pumps 3 will do, but I haven't looked at it in quite the detail 4 yet. 5 (Whereupon, counsel for Suffolk County 6 conferred.) 7 JUDGE BRENNER: Could I hear your last 8 sen tence again, Mr. Hodges? It is my fault. I missed 9 it. 10 WITNESS HODGES: I ha ve not done a 11 quantitative calculation of how much time you have to 12 actuate the pumps with two versus one. I have done a 13 calculation to see how much time you have for one pump, O) q 14 and I have looked at analyses that show the benefits of 15 two versus one pumps, but my analysis personally is more 16 q ua li ta tive rather than quantitative at this point, 17 JUDGE BRENNER: Do you want to clue us in to 18 the results of your qualitative look? 19 WITNESS HODGES: Let me speak only at this 20 point in terms of the worst case event, so we will start 21 out by stipulating several things. First off, that the 22 ARI doesn't work, that you have got main steam isolation 23 valve closure ATWS, so you are not dumping any heat to 24 the condenser. It is all going to the suppression pool, gg 25 and none of these neasures that yo'1 are taking to try to I^) \_/ ALDERSON REPORTING COMPANY,INO, 400 VIRGIN!A AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9061 r3 1 manually insert the rod to reset the trips or open vents V 2 and drains on the scram diacharge volume, none of those 3 types of measures work, and you are relying strictly 4 upon the standby l iq uid con trol system, so a lot of 5 stuff has happened that didn't work, that should have 6 worked to get to this point. So, we are talking about 7 the worst rase. 8 JUDGE BPENNER: Okay, you have got RPT, 9 though? 10 JITNESS HDD3ES: You have RPT in this case. 11 That is correct. For one pump, if you assure that you 12 are starting with a suppression pool temperature of 90 13 degrees, which would be a normal operating limit, and () 14 you ao to the 110 degrees that is in the procedures, as 15 the point a t which you would actuate the standby liquid 16 control system, then that increment added to the 17 suppression pool amounts to approximately 40 and a half 18 full power seconds. 19 Now, for a transient where you had the 20 recirculation pump trip, you are reducing the power 21 fairly quickly, so that in re ality you have somewhere 22 between a minute and a half and two minutes to actuate 23 the standby liquid control system before you reach that (~'] 24 110 degrees Fshrenheit suppression pool limit. That is
'm J 25 how much time you have to do some of these other things
(% ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (20 0 554 2345
l l l 9062 ' l f x, 1 before you have to actuate the standby liquid control (/ 2 system. 3 Actuating the standby liquid control system at 4 that point with no RHE cooling so the operator also 5 fails to turn on the RHR cooling to get the temperature 6 somewhere in the neighborhood of 240 to 260 degrees 7 Fahrenheit in the suppression pool, fairly high. I am 8 sorry, that is a little bit high. One second. 9 ( Pause. ) 10 WITNESS HODGES: I am sorry. That was a little 11 high. It is closer to 220 to 230, in that range. If 12 you had two standby liquid control system pumps 13 operating at 86 gpm, which would have required some (x) 14 piping modifications in order to get that at Shoreham, 15 then the temperaturc would be 170 degrees or less, and 16 these temperatures are temperatures at the time you 17 finally got the reactor shutdown, the 220 to 230 on the 18 one case and 160 to 170 in the other case. These are 19 temperatures at the time you finally got enough boron in l 20 to shut the reactor down to hot shutdown. 1 21 22 23 l (~N 24 C/ 25 l { v 1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D C. 20024 (202) 554 2345
9063 l l g-) 1 JUDGE M3PRIS: Did you reach any conclusion V 2 then whether it was unsafe to run two pumps? 3 WITNESS HODGES: No, I don't think it is 4 unsafe to run two pumps, and at this point you could 5 make the pipinc changes without irradiating anyone, so I 6 don't see anything there that would make it unsafe. I 7 do see it to be an economic penalty, but I don't see 8 anything unsafa about it. 9 JUDGE ECRRIS: Well, ! asked because of the 10 parenthetical phrase there that includes unless unsafe. 11 Is there something behind that question? 12 WITNESS HODGES: I think that was directed to 13 operating plants, and so there, when you start to cut up N (j
\ 14 the piping, then there may be things unsafe about that.
15 JUDGE MORRIS: Okay. I understand. 16 (Board conferring.) 17 JUDGE BRENNER: Mr. Hodges, I think you may 18 have implicitly or even explicitly said it for those 19 with a good technical ear in terms of turning the 20 transient around at that point, I think, or words to 21 that effect was your phrase, but assuming you are using 22 ona pump and say you ran in the 220 to 230 range in the 23 timeframes you indicated, what conclusions do you draw l (~'; 24 with respect to the reasonable assurance of safety of l ( / 25 using just one pump from the standpoint of the concern l (~h l L.! l l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202, 554 2345
1 9054 i , (~}' f 1 for the in of the ultimate heat sink? v
2 HODGES: The test data that we have 3 seen as f a the quenching and such works from the - 4 tailpipes elief valves in the suppression pool 5 indicates 200 degrees there is no problem, and I 1
6 think thef even go up to 210 to 220. It is --
, 7 some of tro up in that particular range, and the 8 quenchers, sa tisf actorily. The tiRC has written i
9 off on 20s not blessed the highe r tempe ra ture a t 10 this poins ing the data, you could probably oo to i 11 220. If,above 220, there is just no data to l 12 support imicht be okay, but it starts to be 13 question d so I would have to label it at this (T l V, 14 point as tne. s 15 RENFER: All right. I l 16 te flow you have assumed with one pump, i i i 17 is thatj flow as would actually occur at i
'l i
18 Shorehaq jg 3 H0DGES: That is the 43 gpm at A Shorehas
- ' L]) 20
< b
* 'A 21 lBRENNER: I am asking for your
, 22 assistar advice, whatever.
M
~
23 n we get a handle on whether the t (s.s i 24 operato e startino initiating SLCS in a ninute i 25 and a hn) minutes, assuming he follows the n [ j u .l t i ALDERSON REPORTING COMPANY,INC, I 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9065 73 1 procedures correctly?
~
2 WITNESS HODGES: In Step 3.6 cf the 3 procedures, he has explicit instructions to do that. 4 WITNESS CALONE: Let me also add, I think hr. 5 Hodges said he was going on suppression pool temperature 6 as the initiating action to start standby liquid 7 control. I would assume in the scenario he is speaking 8 of we would have a reactor power of higher than 6 S percent. 10 Now, I am going to give you my ex pe_-len ce on ', s 11 ATWS. In my opinion and as operating at least t t the 12 simulator and witnessing ee- people operate at the 13 simulaator, an Ati'9 is a .y highly recognizable A (_) 14 situation, the reason being the reactor protection 4 15 system notifies the operator in advance that he is . 16 approaching a scram limit, keys him into an area of the 17 scram. He knows when he doesn't ha ve it. He knows when 18 he wants to scram and it doesn't go in. He is 19 monitoring control rod drives and control rod 20 positions. In my experience and from what I have seen, 21 an ATWS is recognizable within seconds of the event. 22 And I have to say that I cannot see an operator sitting 23 around or wondering about what is happening for a minute (~'T 24 and a half or two minutes. It is my opinion that an 'n_) , 25 operator will respond within 10 or 15 seconds to get (D (_/ ALDERSON REPORDNG COMPANY. INC. 400 V!RGINIA AVE., S W., WASHINGTON. O C 20024 (202) 554-2345
c c ',r / l / ' - ' 9066 r ,, 3,, gg
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' e, , 2 of recognitt h e h a s ' a. n . A , '. f S , and if he has 3 i percent , plie ve me , he is interested in
- 9. I , :
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4 19 that pod around.
'q
,I e 5 WITN r:5 : 1 woe.ld tend to'disagrce. I
, )i s
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[j 6 ~ that he isto try siirst to Cet those :reans t t
, n' /
7 ~ would be idci6n t in' shutting the reactor g l 6 4 , 8 and also whh1 be the least penalty to him. t s, , , b' 9 lose are thshere he inserts the rods by 0, i < i ' f to r resettingrams or inserting them manually,.
. ./
1
~
11 ese others,think ht is gcing to uce the~ time s 12 s until ha . thst' 110 in order to try to use t . ,.
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13 other mea $ if hs~ sees these other means 4
/'~~N } l V y} j '
14 ' et f a ctive ,s wh s t h e wilL-u: c. l J !*
~
> 15' Now, lies / these of Mer tahans and they do i'
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/ 16 0 t n , then I recessa rily tFink hefwill wait '
I t l' - 17 3 to that an't a half . ! But he is not going
-l
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' '!] Idiimrer'iatelo standby liqcil, control system.
- I u , y ,
';d 19.~.k' 7.9 is cotrP these other actions first, I
20l thin', he secac:fo they do not take 20 or so
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21 es in ordec the' rasctor down. t They work l j
. I
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22,quickly , ibork.
, . ' l 1 f 23: JUDGE h Well, but are they going to
- .- um j j
("< A l 24 more than & and a half to two :ltinutes, or i
'v-i .c
'1 25 ou sta rt ttute and a half to two minutes L: ,.y i +
(, r,7 ? > ALDERSON REPORTING COMPANY,INC, RGiNIA AVE., S.W.. WASHINGTON, D.C. 20024 (202) 554 2345
9067
~
1 sf ter he had tried all of that?
\J 2 WITNESS !!ODGES: No, I am starting the minute 3 and a half from tima zero in the transient, and he vill S 4 try that until hic r.inute and a half is up, but he also 5 has to keep an ey? on the suppression pool temperature, 6 and when he gets to that point, he vill hit the standby 7 liquid control system ind go back to this other stuff.
8 JUDGE BREh!'ER: I have got you now. That is 9 why I don't have to worry about the time arsumption 10 because the temperature requirement, even under your 11 assumptions, Mr. Hedger, requires him to initiate 12 standby liquid control. 13 ITN
. ESS H0DGES: Yes.
x j 14 WITNESS CALONE: Let me add just the fact that 15 our procedure as written and ac the operators are 16 trained, it is the 6 percent power level that will cause 17 them to inject standby liquid control. It i= an "or" 18 statement to him, and the "or" statement would have 19 preference over the 110 suppression pool temperature. 20 That is the way they are trained, and that is the way 21 they respond. 22 JUDGE BRENNER: Isn't the reactor -- when does 23 he look at that 6 percent, as soon as he gets an initial
24 failure to scram, given the transient? ~J 25 WITNESS CA LONE: Once he notices the failure ,~
u-ALDERSoN REPORTING COMPANY,INC. 400 VIRGINTA AVE . S W., WASHINGTON, D C. 20024 (202) 554-2345
' 9068 l,
I I 1 cram, his first action is to sanually scram the v 2 tor. He does that by two mechanisms, as the Ha hits the manual scram, which is one, ! 9 , 3 edure says. 4 he puts the mode switch to shutdown, which is the
)
5 nd scram. The operator is trained in a scram 6 ario, his normal shutdown scenario is as he moves l 4 7 $ mode switch to shutdown, he scans his APRMs and 8 cts to see APE 3s, average power range monitors, 9 essin, in cover, and in a short period of time he 10 k know that he doesn't have or he does have greater 11 6 percent i:ver. So it is right there on the 12 b o 6 'i,snd ; hen te hits those buttons, he expects to see 13 th) ver icredit tely drop. p D 14 i 'il
' IESS DDGES: It should take about 5 15 seconc apprChately for the power to get down to that 16 racce,.f i s goitg to ge t down on s normal trip. So
~
! 17 if'it saysove 6 percent beyond the first five 18 seconds, hvould be aware that he has an ATWS in i
'l 19 progress.k q
'I 20 E ERENNER: Shouldn't that 3.6 requirement i
21 then, parprly the 5 percent aspect but not 1 22 exclusiveppear further up in these procedures? L 23 jtSS CALONE: As Mr. Pevely mentioned ( 24 before int procedures, these procedures do have a \~j i 25 tendency inging them. From our experience at the (v ) f ALDERSON REPORTING COMPANY,INC, I 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9069 (
^
x, I simulator, we have made that basic conclusion that the
\_/
2 step may be more functional up higher in the procedure, 3 but acain, we have to remember that the operator 4 memorizes immediate actions and he knows he has to go to 5 a standby liquid control injection if he reaches the 6 point of 6 percent power after manual scram. 7 JUDGE MOREIS: "ay I confirm that in 3.6 where 8 the words reactor power are used, it is meant to te 9 neutron level? 10 WITNESS CALONEs At tnat exact point in time 11 he is using his APRMs as an indica tion of reactor power, 12 tha t is right. It is neutron level that he is actually 13 monitoring, but he is usino that as his indication of p () 14 reactor power. 15 JUDGE MORRIS: There is no ambiguity about 16 that? 17 WITNESS CALONE: I think a a guide to the 18 operator, there is no ambiguity about it. The actual 19 ' reactor power is normally calculated by the process 20 computer. That is where he gets actual power. 21 JUDGE MOERIS: Right. 22 JUDOE PRENNERs Do the proposed procedure 23 guidelines go into the detail of suggestina that the I; 24 direction to the operator that he initiate SLC if the V 25 reactor power is above 6 percent, etc., the rest of 3.6, ( \.
'v' ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S W., WASHINGTON. D.C. 20024 (202) 554 2345
; 9070
! j
- 1
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/ 5-
~
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J 1avet in the procedures?
\_/ l 2 i EODGES: The emercency precedure 3hlidlittle bit different. First off, they 9 ,
4 t 43 pga guide rather than 6 percent. t It is j Shse:.y be the lower end of the APR" range is 6lthend, and for the plant that they use as t 7 r er.a t was 3 percent. Also in the l 8 alics I think assume that the operator will 9 thesteps first rather than tryino to go to 10 inj the standby liquid con trol systeit 4 11 y . as that he will wait until it reaches 12 sup pool temperature limit. I 13' 1RENNER: Okay. Let me come back to the I '; l
's-) 14 r d, Mr. Eodges, when you gave us your view 15; wh : to around something over 200 degrees, t .
; 16 f yc sure the basis is there to support a i
171usfou are okay with respect to inventory. j i 18 t the situation that we get into in I
~ ' -
'! 13! ehaciven the fact that it is one pump?
l
'~- :'- l 20 3 HODGES: Well, there is --
i l j
. BRENNEE4 And given the other
[ ' I. .) . , 21l1 221mpt you made about things that would work.
~ ,. x. a_ . ..y.,
'#I ' " ' " .y
? 23 % HODGES: It is a combination of
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2clene is you have got to worry about load on
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4 ALDERSON REPORTING COMPANY. INC, 400 VIRGINI A AVE., S.W., WASH!NGTON, D.C. 20024 (202) 554-2345 l
9071 rA 1 a net positive suction head for the HPSI or RCSI pumpe V 2 when you are using those to try to maintain level. So I 3 think you start running into problems on MPSH for those 4 pumps at thosc kind of temperatures as well. So I think 5 that for the one pump initiated at 110 degrees for this 6 worst case that we are talking about, it is very much 7 borderline and it might not make it th ro ugh i t. And 8 that is the reason I said in my prefiled testimony that 9 we did not necessarily think that these interdm measures 10 were good for all ATWS events, and it is good for a good 11 many of them, and I think, and in fairly rummary fashion 12 I have discussed wha t kinds of ATWS events you are okay 13 on. But for this very worst case event, you just may I i
' , ,/ 14 not be protected.
15 JUDGE 3RENNER: Okay. When you were assuming 16 the possibility of two pumps, you were doubling the 17 flow, correct, the flow rate? 18 WIThESS HDDGES: I was taking the 86, which is 19 double the flow, and I think to get exactly 66 you might 20 have to do some minor modificatins, but yes. 21 JUDGE BRENNER: Is the flow rate proposed for i 22 Shoreham of 43 typical of the flow rate at operating 23 boiling water reactors to the extent that that would I~')
~.J 24 have been the body of knowledge that the Commission had 25 in mind in their statement of considera tions with t
(~' , Y ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W. WASHINGTON. D.C. 20024 (202) 554-2345
9072 {j 1 respect to interim procedures? 2 WITNFES HODGES: That is very much standard. 1 3 WITNESS PFEFFERLEN Judge Brenne r, let me l 4 make one comment h?re. I think Pr. Ho.lges indicated 5 that the higher temperature was a result of not i 1 6 operating with the RHR. 7 WITNESS HODGESt That is correct. 8 WITNESS PPEFFERLEN: so with the RHR in 9 operation, the tenteratures would be lower, the HPSI can 10 take suction from the condensate sto ra ge tank also so 11 that there would be a source of water. And finally, I 12 think the temperature determina tion, the 220 that he
, _ . 13 cited, was a conservative value which did not take into
( 8 s v 14 account going through 212, the heat of vaporization, 15 which would of course have to happen in the process. So ' 16 it is a conservative assessment that you make there I 17 believe. 18 JITNESS HODGES: Well, I specifically stated 19 no RHR cooling, which is again one of the voret case 20 conditions. 21 JUDGE BRENNER: A lso , for what it is worth, 22 Mr. Hodges, I am not focusing on 220 as a number. I am 23 focusing on the thought tha t you are over the point
) 24 where in your view the analyses can support a conclusion 25 of acceptability that is over 200. So I am not -- or p
b ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9073 r 1 l
- 1 thereabouts. I am not focusing on any one particular
]
2 degree as you would in a rigorous analysis. l 3 WITNESS HODGES: That is correct. 4 JUD;E BRENNEPs I mention that so even if I 5 sssume you are st 2?1, for example, and not at boiling, 6 I am still thinking about it. 7 WITNESS HODGES: Well, I think the data does 8 go up into the 210 to 220 range, and so although the NRC 9 has only writtan off on up to 200 as far as the loads in 10 the suction pool, I think there are come data thst would 11 show at slightly higher terporatures you are still 12 okay. I' is just when you start getting up in the 240 13 or so rr.nge it starts to be questionable. () 14 WITNESS ECKERT: May I add one comr.ent here? 15 I do not want to overly complicate it, but as 16 we have started talking about the peak numbers, and a 17 lot of these have been presented in the past and 18 discussed as if the operator just let the ATWS event, 19 should it happen, run its course, as the guidelines have 20 been constructed, they are also looking at actions that 21 are protecting the containment area and looking at the 22 concerns tha t Mr. Hodces pointed out hera relative to 23 the quenching capabilities of the safety relief valve g 24 quenchers. And so there are 10tions in the guideline 25 that vill also be called upon that as pool temperatures 7-U ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9074 ; ('~i v 1 hea t up, the orerator would be asked to depressurize the 2 reactor so it is not blowing high energy steam into a 3 very hot pool, and coincident with what is going en in 4 the ATWS event, he would be taking actionc to protect 5 for those loads as well. 6 And if such high temperatures are approached, 7 it would be approached on the tail end of the event 8 where you have than depressurized the reactor somewhat 9 and are away from this region of high quenching loads 10 and the data that was talked about here, which is really 11 1000 psi or so reactor pressure data. 12 JUDGE BRENNER. That is correct, also, isn't 13 it, Mr. Hodges, that you in the sense of bounding worst i in 1
\-) 14 case analysis did not go into the kind of detail of 15 adjusting for what would be a complicated series cf 16 functions, including lowering of the pressure and so 17 on?
18 WITNESS HODGES: Well, there are conditions 19 under an ATWS where I think the operator is called upon 20 to lower the pressure, but normally for the ATWS he 21 would not do that unless if he could not maintain the 22 level, for example , with the systems -- let's say he 23 lost the suction head -- then he would have to reduce ( 24 the pressure. cut otherwise I think he would try to 25 maintain the pressure. Tha t is what the procedures tell n y ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W . WASHINGTON, D.C. 20024 (202) 554-2345
9075 1 him to do, or tha Emergency Procedure Guidelines, V 2 Revision 2. 3 WITNESS CARTER: I am not sure I entirely 4 agree with that. Once he hite the heat capacity 5 temperature limit in the contro] guideline, he would 6 depressurize the reactor. 7 WITNESS HODGES: Let me say that that is an 8 ambiguity that has not been cleared up in there at the 9 present. 10 JUDGE BRENNER: An ambicuity in the 11 proced ure ? 12 WITNESS HODGES: In the guidelines for the 13 procedures, yes.
- s,
( ,) 14 JUDGE CARPENTER: Mr. Carter, how can you make 15 such a sweeping statement? Is it documented someplace 16 that that would happen, that he would be instructed to 17 do that? 18 WITNESS CARTER: Well, he has other emergency 19 procedures. His containment energency procedures 20 instruct him explicitly to depressurize the reactor once 21 he hits the ca paci ty temperature limit. I have taught 22 them that, and they know that. 23 WITNESS HODGES: That is in the containment 24 control guidelines to do that, but the ATWS procedures 25 also I think tell him to try to maintain pressure unless
/~',s ALCERSCN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, O C. 20024 (202) 554 2345
9076 cm, 1 he cannot maintain level. So there may be a conflict (-) 2 there, and this is one reason that these ere not 3 approved yet. S 4 JITNE55 ECKERT: Let me add that I have worked 5 at the Anderson reactor, and at this point, as I 6 understand Rev. 2, and the way it stands for review by 7 the Commission, it doec involve the actions that the 8 operator would take even if he was in an incomplete 9 shutdown situation, that he would deprecsurize. The 10 actions are written in such a way that he would do so as 11 smoothly and logically as he could in view of the fact 12 tha t he ha s not had complete rod insertion, and that 13 that action as well helps reduce reactor power during f~s () 14 this period of depressurization, and to tha t extent 15 actually helps him control power and reduce power as he 16 rides through the event and until sufficient boron has 17 been injected to shut him down nuclearly. 18 And so my understanding of Rev. 2 as we have 19 worked it up ended up with that action being in the 20 guideline and being the wa y the Shoreham procedures are 21 written and the Rev. 2 procedures are written. 22 JUDGE BR ENNER. Mr. Hodges, just to help me 23 understand this in context -- and this gets into the (~'] 's,/ 24 rulemaking more than I think we have to, but it might 25 help in my non-techni:sl mind with the context. If you L, ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9077
,rm. 1 had an automatic ELCS, I take it one cf the subjects 'w]
2 would be at what point would you want that automatic 3 SLCS to be called upon automatically. 4 Are come of the possibilities in the 5 rulemaking that it would be called upon faster than the 6 parameters now in the procedures? 7 Can you help me out with that? 8 WITHESS HODGES: It is hard to say where it is 9 going to cone down at this point because the proposed 10 rules that were issued did not get in that kind of 11 detail. It talked only in terms of criteria and that 12 there are discussions now going on as to what should be 13 written which -- and that is getting into whether you
's ) 14 should talk about an injection system that basica.11y 15 both pumps running or should you co to a higher capacity 16 system, and there are a number of other considerations 17 that are being looked at. And so it hasn't at this 18 point been tied down to exactly when and on what 19 criteria it should be actuated. So it is still up in 20 the air.
21 (Pause) 22 WITNESS HODGES: Let me just say that at this 23 point the be st guess is it will probably be something /' ) 24 like a two-pump system, probably automatic, but that is LJ 25 doing a lot of supposing at this point on what the p
%d ALDERSON REPORTING COMPANY, INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9078
~ / 1 Commission will finally come down on and in fact wha t we
(_)) 2 will collectively, we being the people on this task 3 force and others who are inputting to the task force, 4 willk try to decide. 5 So that is my guess at this point as to where 6 it will cote down. 7 JUDGE BRENNEF Well, in terms of automatic 8 initiation, is there any of the proposals or the things 9 under active ronsideration by the staff, at least, to 10 get that automatic initiation immediately upon a failure 11 to scram, or would there be the artomstic initiation 12 up?n some of the same parameters being reached as is 13 currently indicated in the 3.6 of LILCO's a ttached p.
\js 14 procedure, that is, 110 degrees Fahrenheit, that type of 15 thing?
16 WITNESS fl0DGES: My recommendation at any rate
- 17 is going to be based upon the criteria like th e 110 18 degrees, primarily because if you can get those rods in, 1
19 that is the quickest way of getting the power down, and l 20 in many cases and for the ATWS situation, these other 21 steps to reduce power by inserting the rods, either one 22 rod at a time or resetting the scrams and getting them , 23 to go in are going to be effective, and that is the best 1 [<j ) 24 way of doing it. l 25 WITNESS ECKERT: May I add -- (- LY ALDERSoN REPORTING COMPANY, INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9079 (~) 1 JUDGE BRENNER: iet me just stay with this for LJ 2 a second. Then I will come right back to you. And we 3 are going to take a break soon, too, b.ut I will come 7~ i s
4 back to you before the break.
5 Under that possibility -- and we are just 6 talking possibilities here, if it was the same capacity 7 pump, you would hsve the sane considerations under the 8 automatic system, too, since the initiation is starting 9 at the same point as the manual initistion that you 10 assumed in your description before. 11 WITNESS HODGES. That is correct. We are not 12 talking about, I do not think, a 43 gpm, we are talking 13 about something higher capacity. /'N () 14 WITNESS ECKERT: Judge Brenner, I just wanted 15 to add, we have explored wi th the Staff possible logic 16 for the automatic initiation, and it is very similar to 17 the equipment in Shoreham to one extent, that it is tied 18 to the kinds of separate sensors that are initiating the 19 RPT function in the ATWS system that is at Shoreham, and 20 it is usina confirmation that high APRM power still 21 remains as the indicator that although scram should have 22 happened, it has no apparently happened. And so then 23 that signal becomes available very early in such an gg 24 event and the confirmation period is the only delay, and 25 that is in the neighborhood of a couple of minutes. v ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
9080
,c 1 That is the type of thing that has been studied.
V 2 JUDGE BRENNER: One other quick thing, I think 3 it is quick, on the subject. 4 Mr. Hodges, in looking at the Commission's 5 summary listing of their considerations for the finding 6 of acceptability of interin operation of reactors, they . l 7 do not list ARI. They list RPT but not ARI. I 8 Is there anyplace in the rule or elsewhere, to 9 your kno wledge , of the considerations of whether or not 10 ARI was assumed in terms of efficacy of interim 11 operation or on the contrary, that it was not asrumed 12 because none of the opersting reactors had it? 13 WITNESS HODGES: Well, basicall'y none of the (.- () 14 operating reactors had it, and we at this point are not 15 requiring it of them. 16 Also, I think there is some disagreement among 17 the NRC Staff members and some of the utilities and 18 raybe GE about how much you buy in terms of reduction of 19 ATWS challenges by incorporation of the ARI. I think 20 that GE and the utilities claim maybe a factor of ten 21 and the NR" staff talked about something like a factor 22 of two, something on that order of magnitude ! 23 difference. l l /~' s 24 JUDGE BRENNEP: Okay. But is there any l LI 25 possible argument that ARI could make things worse from V ALDERSoN REPORTING COMPANY,INC, 400 V!RGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9081
<"x 1 a certain point of view than what the Comr.ission U
2 considered would be the case for interin operation? 3 WITNESS H0DGES: No, I would expect it to make 4 it better. 5 JUDGE BRENNER: And the dispute is over how 6 much? 7 WITNESS HODGES: Yes. 8 JUDGE BRENNER: I suppose the real focus of 9 the dispute is it is so much better that you don't need 10 higher capacity automatically initiated standby liquid 11 control system. 12 WITNESS HODGES: That is one of the 13 questions. f'% () 14 (General laughter.) 15 JUDGE BRENNEP I just took a wild quess. 16 (General laugher.) 17 JUDGE BRENNER: We will take a break now, and 18 unless somebody objects to the break, having the kind of 19 day, we never know what a party might say. 20 MS. LEIS CH E: I was just going to ask you 21 where on my cross plan you were , J udge Brenner. 22 (General laughter.) 23 JUDGE BRENNER4 I will be honest with you and (~'l %J 24 I will state thic for the record. Although we looked at 25 your cross plan, I was not consciously following it, but 3 Q.s! ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9062 1
- p. 1 to the extent that I used up a fair anount of it, that Li l 2 is okay as far as I am concerned.
3 MS. LETSCHE: I just have to find it. 9 l l 4 (General laughter.) 5 JUDGE BRENNEF: I will tell you quite frankly 6 what occurred. We are very anxious to get to parametric 7 sensitivity type discussion of nonsequence and what the 8 operator is doing, and I think we sa id that many times 9 in the course of the pa st f ew weeks. Mr. Hedges' 10 statement saying he looked at that type of thing and 11 then stopping is what stimulated my saying, well, tell 12 us about it.
.3 MS. LETSCHE: I wasn't objecting to your t
N_) 14 questions. I thought they were fine. 15 JUDGE BRENNEP: '/ e ll , I apologize if I messed 16 up your cross approsch, but that is what happened. 17 (Board conferring.) 18 JUDGE BRENFER: Let's take a 15 minute break 19 until 3:55. 20 (A brief recess var taken.) 21 22 23 cm ( h 24
%)
25 (~~ N) ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
9083 ggg 1 JUDGE BRENNER: hs. Letsche, as a follow-up to 2 your comment that we have utilized some of your cross 9 3 4 plan, the always-asked question is how much time do you have now? 5 (Laughter.) 6 MS. LETSCHE: Well, I won't finish today, 7 Judge Brenner. I am actually -- I don't know if you 8 have looked at it, but I am just about finished with my 9 cross plan for the Staff and sm ready to move into the 10 one for LILCO. Certain portions of that I am not going 11 to pursue, given some of the thing that have happened. 12 I don 't k now. I guess it would be possible 13 for me to finich tomorrow, but I don't want to -- I juct 14 can't say for sure. 15 JUDGE BRENNER: I will tell you what I was 16 hoping. I was hoping you would be able to finish with 17 enough time to allow for some reasonable, but not 18 necessarily a large amount of, Staff questions, and 19 redirect and Board questions at the end. 20 MS. LETSCHE: It's very hard for me to 21 estimate it right now until I have sat down and really 22 had a chance to go through my plan and think about what 23 happened today, which is one problem I have answering lll 24 you righ t now. 25 JUDGE BRENNER: '4 e ll , let me make clear, even O ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
9084 (3, 1 if you finish todsy we will give you the opportunity to R.i 2 think about follow-up for tomorrow based upon the new 3 material. 4 MS. LETSCHE: Well, I know I'm not goinc to 5 finish today. 6 JUDGE BRENNEF: I suppose you have a certain 7 assumption in mind as to when today would end, when you a 8 say that. 9 MS. LETSCHE: Well, yes, I did, that's true. 10 I guess I should ask. Should I assume you had a 11 different assumption in mind? 12 JUDGE BRENNER: I don 't know. We are anxious 13 to finish the panel this week, but we are reaching the () 'N_) 14 point of being tired, as I'm sure you are and the 15 witnesses are, too. So we are not gcing to puch it for 16 the point of affecting the record. 17 If it made a difference for you finishing. 18 today, I would have run later. But I guess we will run 19 until around 5:00 or 5:15 if it's not going to make a 20 difference. But Mr. Reveley, you wanted to say 21 something? 22 MR. PEVELEY: Well, it would be grand if we 23 could finish this week, since three of our people are lll 24 from California. 25 JUDGE BEENNER: You're not going to get us to fr\ k. ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9085
) 1 run late tomorrow, I can tell you that.
("/ s-2 MR. PEVELEY: What about today? 3 JUDGE BREhNER: 'de will talk about it when we 4 get to 5:15, about whether to come back after a break or 5 not. And it would depend upon whether Ms. Letsche -- 6 what kind of estimate she can give us at that point. So 7 let's proceed and see where we are. 8 BY MS. LETSCHE: (Pecuming) 9 0 Mr. Hodges, I would li ke to direct your 10 attention to pa;e 22 of the LILCO prefiled testimony, 11 particularly the last paragraph on the page of 12 testimony, and ask you if you agree with the conclusien 13 contained in that paragraph with respect to all ATWS
,m
() m 14 conditions. 15 A (WITNESS HODGES) I think, as I stated a few 16 minutes ago before the break, that for the most limiting 17 ATWS conditions it might be marginal, and I 'n not saying 18 it wouldn't do it. I'm just saying it is a close call, 19 with what we know. 20 Sut I think you can say that for most ATWS 21 events that it would. 22 (Board conferring.) 23 MS. LEISCHE: I'm sorry, I thought you were [v ') 24 going to say something. 25 JUDGE BEENNEE: Proceed.
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
l 9006 l (^ 1 BY "S. LETSCHE: (Resuming) V} 2 0 I would like to ask the LILCO panel -- and I'm 3 not directing this to any particular person -- if in 4 your opinion or in your interpretation GDC-20 applies to 5 automatic initiation of reactivity control systems? 6 A (WITNESS PFEFFERLEN) Your question is does 7 GDC-20 apply to automatic initiation of reactivity 8 control systens? 9 0 That's right? 10 A (WITNESS PFEFFEBLEN) Yes, I think it does. 11 0 And do you 31so believe it applies to 12 automatic initiation of engineered safeguards systens? 13 A (WITNESS PFEFFEELEN) No, I think it applies 7_s
? \_ 14 to automatic initiation of reactivity control systems, 15 scram systems.
16 C Well, what systems would you put in that 17 categcry, reactivity control systems? 18 A (WITNESS PFEFFERLEN) The scram system. 19 0 The scram sistem; would that include the ! 20 standby liquid control system? l l 21 A (WITNESS PFEFFERLEN) No. 22 0 Would it include the recirc pump trip? 23 A (WITNESS PFEFFERLEN) GDC-20 I don't think ( ; 24 would include the recire pump trip, either. 25 0 How about alternate rod insertion systems? j /^N i O ALDERSON REPORTING COMPANY, INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
9087
/~' -, 1 A (WITNESS PFEFFERLEN) I think all of those are Q) 2 backups to the scram system as required by GDC-20. The 3 scram system is designed to meat all of the requirements 4 laid out in GDC-20, and the systems that you mentioned 5 are backups to or modifications of that system. But the 6 system was designed originally in all past plants as 7 completely satisfying GDC-20.
8 (Counsel f or Suf f olk County confe rring. ) 9 JUDGE M0ERIS: Excuse ne, Ms. Letsche. 10 Is it your position, then, Mr. Pfefferlen, 11 that the backup systems, in exercising a protection 12 function, 10 not have to meet the requirements of 13 GDC-20? n t,) 14 WITNESS PFEFFEPLEN: I don't think I 15 necessarily meant that. My point was that GDC-20 is 16 satisfied by the scram system and the scram system was 17 designed to satisfy that. Now, whether or not the 18 requirements of GDC-20 -- it requires an automatically 19 initia ted system and I think that is fully satisfied 20 with the scram system. So I think the answer is yes, I 21 think it does not apply to the ARI or the SLC systen or 22 the RPT. 03 JUDGE MORRIS: And the basis for that is that (~ ; 24 you do have a system that does comply? </ 25 WITNESS PFEFFEPLEN: Exactly. (~T N] ALDERSON REPORTING COMFANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9088 (v; 1 JUDOE MORRISS And you've defined this as a 2 protection system? 3 WITNESS PFEFFEPLEN: That is correct. 4 JUDGE MORRIS: Would you also say that the 5 backup systems are protection systems or reactivity 6 control systems? 7 WITNESS PFEFFERLEN: Well, they are backap 8 reactivity control systems. 9 Let me ask, vnich systems specifically are you 10 referring to, the ARI? 11 JUDGF MCFRIS Well, I was thinking of the 12 standby liquid control system. 13 WITNESS PFEFFERLENs The standby liquid 7
'\_) 14 control system is a backup system to that reactivity 15 control system. Put the reactivity control system, the 16 scram systen, is designed to meet all of the single 17 failure criteria, to function with rods stuck out. In 18 other worts, there is sufficient negative reactivity to . 19 perform its function, to meet all of the imposed failure 20 requirements that would go with a system de signed to 1 21 meet the GDC.
1 22 And I submit that in the past this has been an 23 acceptable situation, and since ATWS now is being ( f's 24 discussed we a re bringing into play the other systems 1 %) 25 that we are talking about now. l /n. l (._J l ALDERSON REPORTING CCMPANY,INC, 400 V RGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9089 ('; 1 JUDGE MORRIS: "aybe I am trying to
\J 2 manufacture a problen where there is not one, but in my 3 reading of GDC-20 it reemc to distinguish between a 4 protection System and a reactivity control syctem.
5 WITNESS PFEFFERLENs I'm sorry, maybe I should 6 read the saction. 7 JUDGE BPENNER I think maybe to fill it out 8 for the record, it isn 't necessarily 3.C-20 by itcelf 9 that draws that distinction, srquably, but it is tha 10 title of Roman III within the GDC. An d then if you look 11 at the different 3DC's under that, some of them include 12 " protection system" in the italicized introductory title 13 and some include " reactivity control systems." g 'j s 14 WITNESS PFEFFERLENs Yes, I do agree with your 15 statenent. But sidressing specifically GDC-20, "The 16 protection syctem shall be designed to initiate 17 sutomatically," okay, I would say that it is the 18 reactivity control system and the other protection 19 functions that -- core cooling, ECCS, and things of this 20 nature -- that would be required to satisfy the 21 acceptable fuel limits. 22 But as f ar ac the reactivity system goes, the 23 scram system is what -- the protection syctem I believe ('v ) 24 would include other systems that provide a protection 25 function, but not a reactivity control function, just as LJ ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9090 1 emergency cooling Oystems which are initiated by the (] L ,' 2 resctor protection system. 3 SY sE. LETSCHE: (Pasuming) 4 0 Mr. Pfeffarlen, I wonder, could you just read 5 into the record for u: GDC-20? 6 JUDGE BRENNER: I will read it in. It hasn't 7 changed, but I have got the slightly newer version, just 8 in case. It is 9 " Criterion 20, protection system functions. 10 T h r+ protection system shall be designed: 11 "(1) To initiate automatically the operation 12 of appropriate systems, including the reactivity control 13 systeme, to assure that specified acceptable fuel design (% (,) 14 limits are not exceeded as a result of anticipated 15 operational occurrences; and 16 "(2) To sense accident conditions and to 17 initiate tne operation of systems and components 18 important to safety." 19 MS. LETSCHE: Thank you, Judge Brenner. 20 JUDGE BRENNER: That's a nice little phrase at 21 the end of the criterion there. 22 BY MS. LETSCHE: (R esumi ng ) 23 0 Mr. Pfefferlen, can you tell me where in () xy 24 GDC-20 it exempts backup reactivity control system? 25 MR. REVELEY: Judge, I'm going to object to-
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9091
.f 3 1 the question. To repeat the objection I've made a L) 2 number of times today, the Commission in its notice of 3 proposed A!WS rulemaking has already found, and we are 4 bound as a matter of law by that finding, that neither 5 GDC-20 not anything else require an automatic SLC in 6 this interim period.
7 It could be that s. Letsche is going 8 someplace else, but I doubt it. And if in fact the 9 Commission by finding that the interim SLCS which are 10 not automatic in EWR's are acceptable for the interim -- 11 I don't cee that this line of inquiry will ultimately 12 help the Board in writing its findings. 13 (Board conferring.) (~%
\ ) 14 15 16 17 18
, 19 20 21 I l l 22 , l 23 ("') (/ 24 25 m
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9092 I[ j) 1 JUDGE BRENNERt Essentially we agree with Mr. 2 Reveley. Let me first sta te why the hedge on the 3 essentially. 4 We agreed to the point that we are going to 5 grant the objection. We do not agree that the 6 Commission has absolutely found that an automatic cyctem 7 is not required in the interim. They found tha t cubject 8 to a finding that the interin measures taken conform 9 with their expectation as indicated in the statement of to considerations of the interim measures. That is, it is 11 open to find that at a particular reactor, given certain 12 deficiencies such as training and procedures, then in
,. 13 the absence of an automatic system and given these
( ) 14 deficiencies that the reacter has not met the 15 requirements that the Commission had in mind. 16 And I say that so tha t our agreement with you 17 should not be taken literally with one phrase you had in 18 there that would imply an absolute finding that nothing 19 else possibly could be required, but the thrust of the 20 objection is correct. 21 Another way of saying it in the context of GDC 22 20, since that is where the objection -- that is wha t 23 the question was focused on and where the objection was n (_) 24 made is that it is not very productive given the fact of 25 the rulemaking to debate what is a protection system 0
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ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9093 () ' 1 within the meaning of GDC 20, sinc.e it might be fair to 1 suggest that whst is a " protection system" beccmes a 3 matter of definition through . analysis or rulema king or 4 both of what it is you have to protect fron. For 6' example, one possible; resul t of the rulemaking is that 6 the Commission will find tha t 7ou need an automatic that 7 you should protect from an ATWS, and in order to protect 8 from an ATUS, you need an automatic standby liquid 9 Control system. If they made that finding, then that 10 system could be a protection system within the meaning 11 of GDC 20. , 12 So the any to get at this is to focus at the 13 interim procedures given what the Commission had in mind O-14 and not try to define what might or might not be within 15 GD0 20 after the completion of the rulemaking. 16 (Counsel for Suffolk County conferring.) 17 BY P.S. LETSCHE: (Resuming ) 18 0 Mr. Pfefferlen, if you assume tha t the standby 19 liquid control system is not promptly initiated by an 20 operator, would you have assurance that the fuel limits 21 would not le exceeded in the event of a severe ATWS 22 event? ' 23 A i(WITNESS PFEFNERLEN) If the SLC.were not () 24 'promptly initiated, would I have a ssura nce ',tha t the fuel 25 limits would not be exceeded? , y l ALDERSON REPORTING COMPANY,INC,
9094 6 () 1 (Panel of witnesses conferring.) 2 I think, as Mr. Hodges pointed out, that 3 eventually if we continue to dump heat into the j 4 suppression pool, 'e
. get to a condition that may lead to 5 some kind of fuel damage. So I think the answer to your 6 question is no. I cannot assure that, but that is in 7 the long term that some understood problem may develop.
8 (Counsel for Suffolk County conferring.) 9 Q Mr. Pf e f f e rlen -- actually there are a number 10 of people on this item that I am goin0 to refer you to 11 -- on page 6 and 7 of your prefiled testimony you talk 12 about the Shorehst scram system. Can somebody tell me 13 how the control rod drives and hydraulic control units O N- 14 are arranged with re spec t to each other? In other 15 words, do the two hydraulic control unit groups divide 16 in a checkboard pattern of rods, or does each group 17 drive one side of the core? How is that set up? 18 (Panel of witnesses conferring.) 19 A (WITNESS RISERT) The hydraulic control units 20 are separated into east and west banks, and they split 21 the reactor roughly down the middle; they are not 22 checkerboard. East-west as far as the ccre spacing of 23 the rods. But the electrical system is checkerboard as () 24 far as the scram channels and the failure of an 25 individual channel in the reactor protection system. () ALCErsSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $$4 2345
9095 (~] 1 That has been che:kerboarded in the physical cora v 2 arrangement. 3 (Counsel for Suffolk County conferring.) 4 0 Mr. Pfefferlon, do other types of reactors 5 have diverse scram drive mechanisnc like an electrical l l 6 a nd a hydraulic drive? l 7 A (WITNESS PFEFFERLEN) I would imagine the 8 answer is yes. I know in the prototype LMFBR they are 9 talkino about that, but I am not aware of any operatina 10 plants that have. I really do not know the answer to 11 that other thin in the LMFBR prototype. 12 O Did GE ever consider putting diverse drives 13 into their BWR design? (% \ 14 MR. REVELEY: Judge, I object. I do not 15 understand the relevance of this line. 16 JUDGE BRENNER: Neither do I. 17 Ms. Letsche, do you want to explain? 18 (Counsel for Suffolk County conferring.) 19 MS. LETSCHE: Judge Brenner, I am following up 20 on the witnesses' testimony around page 8 of their l l 21 prefiled testimony where they a re describing their scram 1 22 system, and trying to find out whether there was any -- 23 and this was sonething that we had moved to strike to
- Iwj') 24 start with, and that motion was denied.
25 JUDGE BRENNER: I know that part. n ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (?92) 554 2345
l 9096 () 1 MS. LETSCHE And trying to deternine if there 2 wac any consideration of making the scran system more 3 diverse than it is. 4 JUDGE BRENNER: I still do not understand the 5 r el ev an ce . The reason that motion to strike was denied 6 is that this was -- it was helpful to have a description 7 of what the system is at Shoreham, but you are not 8 asking about what the system is at Shoreham now, and we 9 pre going to grant the objection. 10 BY MS. LETSCHE: (Fesuming) 11 Q Where is the standby liquid control system 12 located in the reactor building? 13 JUDGE PRENNER: Do you mean the key, Ms. ks 14 Letsche, or the tank or the pump? 15 MS. LETSCHE: I am talking about the major 16 part of the system, that is, the tanks and the pumps. 17 WITNESS CARTER: The tanks and the pumps are 18 located on elevation 112 north. 19 BY MS. LETSCHE: (Resuming) 20 0 Where in the reactor is the insertion point 21 for the standby liquid control system? 22 A (WITHESS CARTER) The insertion point is on 23 elevation 104 south.
,c ,
( ) 24 (Counsel for Suffolk County conferring.) u -
. 25 0 Where in the vessel is the boron inserted?
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9097 ( ', 1 A (WITNESS CARTER) It is inserted through a 2 pipe underneath the core plate. 3 (Counsel for Suffolk County conf e rring. ) 4 0 What is the necessary boron concentration in 5 the core in order to achieve sh utdown f rom full power? 6 A (WITNESS ECKERT) To achieve the hot shutdown 7 from full power at hot conditions we have used the terc 8 355 parts per million in the reactor water. That is 9 based in a funny way that the way the physicists have 10 kept track of their parts per million on a cold density 11 even though it is in hot reactor. If you really used 12 water density at the hot conditions, it comes out about 13 480 parts per million based upon the densities present ,3, i \ il - 14 at that temperature. That would be mixed solid water in 15 the core with that boron concentration. 16 (Counsel for Suffolk County conferring.) 17 0 Assuming the insertion point that Mr. Carter 18 stated and the boron concentration that you just 19 described, how nuch boron solution would have to be 20 injected to achieve the hot shutdown? 21 A (WITNESS ECKERT) The guidelines would direct 22 the operator to inject about a quarter of the tank to 23 a ch ie ve this amount of boron in the vessel. I[ ) 24 A ( W IT!;ES S EODGES) Can I answer that one? 25 0 Sure. f is ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W,, WASHINGTON, D C. 20024 (202) E54-2345
I 9098 ) (g 1 A (WITNESS HODGES) My calculations showed that C/ 2 if you had a water level in the normal range or after, 3 restoring the water level to the normal range, you would 4 have needed te insert a lit tl e over 258 pounds of 13 5 weight percent sodium pentaborate and add approximately 6 4.46 gallons per pound of boron; so you are talking 7 about 1,150 roughly gallons of sodium pentaborate. 8 Q Assuning the 43-gallon per minute flow rate 9 which we would have at Shoreham, a pproximately how long to would it take to achieve that condition? 11 A (WITHESS H0DGES) My calculations show 26.8 12 minutes. 13 0 Does the LILCO panel agree with that?
/"N ' ,,! 14 A (WITNESS ECY.ERT) Yes.
15 JUDGE CAFPENTER: Mr. Hodges, that was with 16 the 13 percent solution? 17 WITNESS HODGES: That is correct. Thirteen 18 weight percent in the standby liquid control tank. 19 JUDGE CAPPENTER. Is that nominal or a 20 conservative value for that? As I recall, the values 21 are somewhat higher in some of the documents we looked 22 at a few weeks ago. 23 WITNESS HODGES: I just do not remember. I l ()
%)
24 was thinking that was a nominal value, but there is at 25 least a minimun that is quoted. It could be above [] v ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE , S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9099 1 that. I do not recall for sure. ( 2 JUDGE CARPENTER: One of the other panel 3 members is nodding. (-} V 4 WITNESS ECKERT: It is a nominal-value, and 5 dependina upon the level in the tank between high or low 6 alarms it will vary a little bit around that 7 concentration. 8 BY MS. LETSCHE: (Pesuming) 9 Q Mr. Hodges, do your calculations assume the 10 insertion of the boron solution underneath the core 11 pla te? , 12 A (WITNESS HODGES) ^ha t is how much you need to 13 get into all of the water system. It is irrespective of 14 where you inject it; that is, to put it in and mix it, 15 that is how much you need. 16 0 How do you know ' that the solution has been 17 properly mixed in the reactor in order to achieve the 18 shutdown in your calculations? 19 A (WITNESS HODGES) I have seen results from ( 20 some mixing tests that the owners aroup ran that showed. I 21 the efficiency of the mixing. l 22 (Counsel for Suffolk County conferring.) l 23 0 What was the value of the mixing efficiency? ()) 24 A (WITNESS H0DOES) It varies with the water and 25 the power level, but as you increase the water level it l ALDERSoN REPORTING COMPANY,INC, 400 VIRGIN!A AVE, S.W., WASHINGTON, D C. 20024 (202) 554 2345
9100
\\
1 gets up near one very quickly. [} 2 (Counsel for Suffolk. County conferring.) 3 0 Does that mean that if you were a ttempting to 4 maintain the core water level at a low level, the ' 5 efficiency would be less? 6 A (WITNESS H0DGES) If you had the water level 7 down at the top of the coro, it would not be mixing. 8 0 Under those cond '. tions , assuming you are l 9 maintaining the water level at the top of the fuel, how 10 much time would it take to achieve shutdown, hot 11 sh u tdown ? 12 A (WIINESS HODGES) If you never raised the 13 water level back up, you would not get the mixing that 14 you would need; and that it why you have act to raise 15 the water level back up after you get the boron injected. 16 (Counsel for Suffolk County conferring.) 1 17 0 That is a step that is not in the current 18 Shoreham procedures, is tha t right? 19 A (WITNESS H0DGES) It is not explicitly in 20 there. I would expect that the operator would probably i 21 take that action, but it is not explicitly in there. 22 (Counsel for Suffolk County conferring.) 23 Q Mr. Fodges, what other variables other than () 24 the water level would affect the mixin7 efficiency? It is primarily the natural 25 A (WITNESS HODGES) I O i j ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345 1
l 9101 ("'y 1 circulation flow rate which is controlled by the water kJ 2 level, so they are late rrela ted -
,3 3 (Counsel for Suffolk County conferring.) \ !
4 0 So when you have the recirc pump turned off, 5 that redu:9s the circula tion a nd tha t would reduce the 6 mixing, is that right? 7 A (WITNESS HODGES) Hold on for one second. 8 (Pause.) 9 As long as the power level is above about 15 10 percent you still get very good mixing, and tripping the 11 recirc pump drops the level to the 30 to 40 percent 12 range, so natural circulation rate with a reasonably l 13 high water level will give you good mixing. As you drop (~)S
'x 14 down near the top of the core the mixing starts to 15 decrease sharply.
16 (Counsel for Suffolk County conferring.) 17 0 Mr. Fodges, I would like to -- I guess maybe 18 not F. r . Hodges but the IILCO panel -- talk a little bit 19 about the various things that would affect the time in 20 which the standby liquid control system has to work. 21 Does the operation or the correction operation of the 22 safety relief valves affect the time in which the 23 standby liquid control system has to inject the boron g 24 into the reactor or to be effective, let us say, to 25 achieve hot shutdown?
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ALDERSON REPORTING COMPANY,INC, 400 V:RGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345
9102 (T 1 A ('4IIN F55 ECK ERI) No. There is really no V 2 close tie to those functions. The safety relief valves g3 3 are working very early in the event controlling the
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4 initial disturbance if there was one, and the action of 5 shutting down nuclearly becomes on a much slower time 6 frame. 7 0 How about the reactor water cleanup system? 8 Does that have an effect on the time in which the 9 standby liquid control has to be effective in achieving 10 hot shutdown? 11 A (WITNESS CALONE) Yes, that would have an 12 effect except when you initiate standby liquid control 13 there is an automatic isolation and reactor water g) k m 14 cleanup, and one of the steps is for the operator to 15 verify isolation. 16 0 What does he have to do to verify it? 17 (Panel of witnesses conferring.) 18 A (WITNESS CALONE) The reactor wa ter cleanup is 19 -- the reactor water cleanup system is about two feet 20 from the reactor panel. He would walk over there or 21 just visually look from the control panel and verify 22 that the suction valves were not closed, an indication 23 by a green licht. ll 24 0 Nhy is it that that systen is isolated when 25 the SLC is activated? ID wa 1 1 1 ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S W., WASHINGTON. D.C. 20024 (202) 554 2345 i
9103 A (WITNESS CALONE) It would remove the poison (^) us 1 2 from the reactor vessel. 3 0 Does whether or not the main steam isolation 4 valve is open or closed have an effect on the time in 5 which the SLC has to be effective in achieving het 6 shutdown? 7 A (WITFESS CALONE) We may be talking about some 8 chemistry here. My understanding is that the sodium 9 pentaborate does not carry over in the steam. The stsam 10 leaving the reactor would not carry the poison out. The 11 reactor water cleanup, which is a water discharge from 12 the reactor, would carry the neutron poison out; so the 13 MSIV should not have an effect upon removing the sodium. f ~ss N ,/ 14 0 Are there any other systems or componente that 15 would have an effect on the time in which the standby 16 liquid control has to be effective in achieving hot 17 shutdown? 18 (Panel of witnesses conferring.) 19 A (WITNESS CALONE) I cannot think of any system 20 that would affect it directly. It is a constant 21 displacement pump putting in a given volume per unit 22 time into a volume of water, and the only thing tha t 23 would stop it is if the pump stops. (^'; s,- 24 0 Does the operator have an alterna te technique 25 to initiate the standby liquid control system if the p o ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C 20024 (202) 554 2345
l 9104 () 1 switch that normally activates it does not work properly? 2 (Panel of witnesses conf erring. ) 3 A (WITNESS CALCHE) There are two situations 4 in vol ved . The cnly way to activate the squibb valves 5 without crawling ander the panel and shorting them out 6 is by the standby liquid control switch on the 603 7 panel. If the squibb valves fired, we could operate the 8 pumps manually from elevation 112 in the location of the 9 standby liquid control system. 10 0 If the squibb valves do not fire, is there any 11 way to get to inject the boron into the vessel? 12 A (WITNESS CALONE) If the two redundant squibb 13 valves fail to fire off the safety-related switch, then 3 14 there is no way of getting the boron into the vessel 15 that I know of. 16 (Counsel for Suffolk County conferring.) 17 0 Gentlemen, at pages 9 and 10 of your testimony 18 you discuss the recirc pump trip systen at Shoreham. 19 Would the opera tor trip the recirc pumps from full power 20 in normal controlled shutdown? i 21 A (WITNESS CALONE) I am sorry. Could you 22 repeat that? 23 0 Yes. In a normal controlled shutdown () 24 situation would the operator trip th e recirc pumps? 25 A (WITNESS CALONE) In a normal controlled I ALDERSON REPORTING COMPANY, INC, l 400 V:RGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
9105 (') us 1 shutdown? 2 0 From full power. 3 A (WITNESS CALONE) No, na'am. {~'} v 4 0 Why not? 5 A (WITNESS CALONE) In a controlled shu td o wn you 6 would control the reduction of power. Tripping the 7 recirc pumps is not a way to control reduction of 8 power. That is a way of rapidly decreasing power. In a 9 controlled shutdown we wouldn't want to decrease power 10 at a rapid rate just to trip then. Whst we would 11 normally do is nanually reduce their speed from full 12 speed to min speed which will take the reactor power 13 from 100 percent to about 60 percent. So there are some ft 14 thermal limits associated with the turbine and the - 15 generator as far as load cycling. We would not just 16 arbitrarily wheel that thing down to 60 percent power 17 and put a thernal transient on the turbine and 18 generator. So in a normal shutdown we would reduce l 19 power using the recirculation pump spced to about 60 l 20 percent and then move rods in. l l 21 0 Is it stressful for the fuel structures to l l 22 undergo the quick change in power such as would occur 23 with the RPT? (,,) 24 A (WITNESS ECKERT) That is one of the design 25 basis cases that is used to evalua te ma rgins f or f uel p
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1 thermal limits and is done, is tested at the plant when (} 2 it starts up, and has been something that has been done 3 frequently. So it is not an unusually stressful (] NJ 4 situation. 5 0 What signals does the RPT rely upon for 6 activation? 7 A (WITNESS RIGERT) The Shorehan recire pump 8 trip is initiated off of a high reactor pressure at a 9 set point of 1120 psig or low reactor level, what we 10 call level two. 11 0 How are thoce sionals derived? 12 A (WITNESS RIGERT) We are using signals off of 13 level and preccure transmitters that are in the ECCS 14 systems. Those transmitters send their signals into the 15 inalog trip system where we have trip units, electronic 16 trip units that are calibrated at the settings I 17 m en ti on e d , and then they go into a logic which is 18 basically two low level signals or two high pressure , 19 signals. Either one of those will complete the logic 20 and give you a trip signs 1. And then there is two sets 21 of that logic, a division 1 and a division 2, and.those 22 go to redundant breakers in the power f eed to the motor 23 of each recirc pump so that the division 1 system will 24 go to breakering both each pump power supply and also ( ]) 25 the division 2 will do the same, so the system is a ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345
I 9107 1 single failura-proof. (} 2 O The level and pressure transmitters in the 3 ECOS system that you mentioned, are those the sensors 4 for those conditions? 5 A (WITNESS RIGERT) The transmitter is the 6 sensor. 7 Q And so the sensors that will trigger the EPT 8 are the sar.3 as those that would trigger the ECCS system? 9 A (WITNESS EIGEET) The ECCS, yes. Not EPS, 10 though. 11 (Counsel for Suffolk County conferring.) 12 O Was the RPT design f eature added to the BWR 13 design because or in response to the ATWS interim (s /\ 14 mea sures required by the Commission, or was this 15 something that was in the GE design prior to that? 16 A (WITNESS RIGERT) In the case of Shoreham this 17 was being put in before the notice of rulemaking, and I 18 believe because I think on the operating plants there 19 was an order to install it. I am not -- since we a re 20 not an operating plant, I do not know the details of 21 that, but as far as I know, it was just an accepted fact 22 that everyone shall have an RPT. 23 Maybe Mr. Hodges could confirm that. dr. Hodges, can you confirm that? l ( -)- 24 Q 25 A (WITNESS HCDGES) I think he has accurately Ov i ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S W., WASHINGTON, D C. 20024 (202) 554 2345 l
9108 characterized that, yes. fl
~_J 1
2 (Counsel for Suffolk County conferring.) 3 0 Gentlenen, on page 10 of your testimony you 4 indicate that the RPT feature provides prompt reduction 5 in power to less than 40 percent. Somebody might have 6 said this before, but how fast is this prompt reduction 7 that we are talking about here? 8 A (WITNESS ECKEET) It is in less than a minute. 9 0 Why is not this tripping of the recirc pump 10 left to the operater to perform? 11 A (WITNESS ECKERT) This was added on the front 12 end of the event and is a part of the very effective 13 overpressure protection that is being used here on the g! i
\/ 14 front end of the ATWS event, so that it is a part of the 15 front action happening up within those first few seconds 16 and the first part of the first m'inute with the relief 17 valve action to reduce power quickly and allow the 18 relief valves to turn the pressure peak very quickly and 19 get us all down to a power level that alloas time for 20 the rest of the actions.
21 A (WITNESS HODGES) Let me add a little bit of 22 description, if I could, to his previous answer on how 23 fact you get down with the recirc pump trip. Once you i p) (x, 24 t rip the pump, just a C0asting down from the inertia of 25 the pump, you follow a curve that is not ex ac tl y a (m _,s ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S W.. WASHINGTON, O C. 20024 (202) 554 2345
9109 () 1 decaying exponential, but it looks almost like a 2 decaying exponential, and you get down to about half of 3 the pump flow in six seconds, and then it starts to 4 level out so you get down in order of maybe 20 seconds 5 down on a natural circulation flow rate. 6 JUD3E BRENNERs That sounds to my nontechnical 7 ear, Mr. Hodges, is being very consistent with the rapid 8 time frame that the LILCO witness testified that you 9 would get down to that 40 percent. 10 WITNESS H S DG ES's He said less than a minute, 11 and I was just trying to put a little bit of 12 clarification on what was less than a minute. I was not 13 disagreeing with him. O
\J 14 BY MS. LETSCHE: (Resuming) 15 Q Mr. Eckert, what criteria was used in 16 determining -- in making the decision to automate the 17 RPI rather than leave it to the operators to do manually?
r 18 A (WITNESS ECKERT) Well, as I stated, it has l 19 really been in our development of resolving the ATWS 20 situation with the staff for quite a time and is 21 connected with the front-end transient of overpressure 22 protection that was involved in the first few seconds of 23 the event. And it made the most sence to us as well as i () 24 to the staff that that be a front end automatic action. 25 It has very little negative consequences on the reactor O ALDERSON REPORTING COMPANY,INC, 400 VIFGINIA AVE., S.W . WASHINGTON. D C. 20024 (202) 55 b2345
9110 1 should it happen, and it is not an ATWS situation, so it 2 is not the kind of action that we need a lot of 3 pro tection against, so we put that right up front as a 4 strong part of overpressure protection even for this 5 type of an event. 6 0 I assume one of the reasons for that is to 7 avoid the probability of the operator not doing it or 8 doing it too late, is that righ t ? 9 MR. REVELEY: Judge, I am going to object. k'e 10 are clearly talking again about whether or not to 11 automate the SLC. 12 JUDGE BPENNER: Is that where you are headed? 13 MS. LEISCHEs Nc, Judge Brenner. I am trying O) ( 14 to find out why they decided to automa te the RPT. 15 JUDGE BRENNER: Yes. And then what do you do 16 with that information? You see, the Commission 17 strictures on us on what to assume in the interim is to 18 requite the automated RPT, and on the assumption that 19 you do not want to require that they should make it 20 manual. I do not know where you are headed. We are not 21 Writing on a clean slate, as we said many times. If 22 there was no proposed rulemaking and no interim 23 g uida nce , we would be hearing a lot of information as to h G 24 what the parties and thereafter this Board thought 25 should be done in the interim, but we are not f ree to do O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O C. 20024 (202) 554 2345
l 9111 (~'i 1 thst.
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2 PS. LETSCHE: Judge 3renner, I think the 3 object of my cuestioning here is related to the 4 contention of LILCO that relying on operating proceduras 5 are sufficient in the interim to mitigate ATWS events. 6 And the question there is whether or not relying on 7 opera to r actions is reasonable in light of how long it 8 is going to take them to do things, or whether or not 9 they are going to do them. 10 The point of my questioning here is what 11 criteria -- with respect to those criteria whether 12 operators are going to do something and how long it is 13 going to take them to do it entered into this decision, ( f7 I N> 14 and whether or not the decision was different with 15 respect to the other operator actions they were relying 16 upon in terms of nitigating AIWS events. 17 JUDGE ERENNER: ' Jell, given that, we are going 18 to grant the objection on the basis that the Commission 19 hac found that interin steps relying on procedures and 20 training in the absence of an automatic standby liquid 21 control system are acceptable. 22 Now, we ha'7e sided the gloss over the 23 utility's strono objection, as you might recall, that it ('N ; 24 is open to an individual board to scrutinize the
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25 particular procedures ani training for the utility so [x ( / ALDERSON REPORTING COMPANY,INC. 400 VmGIN A AVE. S W . WASHINGTON. D C. 20024 (202) 554-2345
9112 1 1 (} 1 that we can determine whether they are acceptable. We 2 can argue in the findings as to what the measure of
~g 3 acceptability is. We have already stated we would take b 4 into account how com plex the ste ps a re being called upon 5 for the operator to perform and what kind of situation 6 he is in with respect to time f rame and wha t else has to 7 be done in that time frame and so on. And one arguablo 8 measure is whether these are the type of procedures and 9 training tha t the Commission had in mind when they wrote 10 that. Somebody might want-to argue that we should look 11 at that, and we might. But those are still quite narrow 12 guidelines, and it is not open to us to conclude that 13 operator actions and training in the absence of the b)
N, 14 automated system are una :sptable, and that is what you 15 want to argue, and that is the subject of the 16 rulemaking. So the objection is granted. 17 I also frankly thought the question was 18 answered by now, but that is another matter. 19 (Counsel for Suffolk County conferring.) 20 BY MS. LEISCHE: (Resuming) 21 0 Gentlemen, on page 15 of your testimony you 22 discuss the ARI system. What signals initiate the ARI 23 system at Shoreham? 24 A (WITNESS SIGERT) The API system is initiated (V~D I 25 off the same signs 1F I described before for RPT. () v ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W , WASHINGTOh, D C. 20024 (202) 554 2345
9113 1 (Counsel for Suffolk County conferring.) 2 O 4 5 6 7 8 9 10 11 12 13 14 15 l 16 17 18 19 20 21 22 23 24 25 O ALDERSON REPORTING COMPANY,INC, t 400 VIRGIN!A AVE., S W . WASHINGTON, D C. 20024 (202) 554-2345
l 9114 l BY MS. LETSCHE: (Eesuming) (]) 1 2 0 You indicate in your testimony that there 3 would he, if I can find the reference for you, I think 4 it is in Answer 18 on page 15, that a control rod 5 insertion initiated by the AEI sytem would involve a 6 small delay in the time of initiation. 7 What is the small delay that you are referring 8 to there? 9 A (WITNESS RIGERT) The normal time to scram is 10 in the range of 5 seconds. I would say that is a good 11 estimate of it. There is test data right now on the 12 test that was done at Shoreham by our start people on 13 our backup scram valves which are identical to the ARI n N' 14 valves and this accomplished a scram in 11 to 12 15 seconds. 16 0 In light of what you indicated was the case 17 with respect to the sensors for the RPT and for the API, 18 since they share the same sensors, that means that if 19 the RPT failed, you also wouldn't have ARI, is that 20 right? 21 A (WITNESS RIGERT) Well, if some of those r 22 sensors failed, you would probably still have both of ! 23 them because they are single failure proof and diverse
. (sJi 24 in that you have level N pressure; it would take 25 multiple failures in order to defeat the systems. So it i
I I l
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9115 () 1 depends upon what kind of failures you are postulating. 2 (Counsel for Suffolk County conferring.) 3 JUDGE BRENNER: Es. Letsche, while you have ( 4 paused, let me take stock of deciding how much we should 5 do with our time this week. I saw the promised -- I 6 hesitate to use the word anticipated -- application for 7 issuance of subpoenaes and alco a response, and I am 8 pleased that the procedure was worked out so that we 9 have the positions of both parties. 10 Do you want us to consider that prior to 11 tomorrow morning? 12 MR. PEYELEY: No, sir. I don't think that is 13 nececsary. My uniarstanding is that two of the requests
\' 14 have been mooted by subsequent developments, that only 15 one-remains, but the company is perfectly willing to 16 have it resolved later if the resolution involves the 17 opportunity to take the deposition beyond the period 18 that the Board has scheduled. Otherwise I guess we need 19 to resolve it sooner rather than later, and I will just 20 have to take five minutes to read the miserable thing I
21 carefally, and Ms. Letsche will have to do the same, and 22 thcn we can argue absent our emergency planning notice. l 23 JUDGE ERENNER; You are going to need us (
) 24 because of the Board's schedule, to consider it no later 25 thsn tomorrow. That is my point.
O . ALDERSON REPORTING COMPANY. INC, l 400 VIRGINTA AVE., S W., WASHINGTON, D.C. 20024 (202) 554 2345 I
9116 () 1 MR. REVELEY: What I was going to suggest at 2 the end of the day was that once you have had an i 3 opportunity to read it carefully and we have had a 4 chance to read it carefully, you could let us know if 5 you wish is. Letsche and me to argue it early tomorrow. 6 MS. LETSCHE: I think bo th M r. Reveley and I 7 are a t least somewhat aware that there might be 8 conversations going on between Richmond and Washington 9 relative to that, and I know I have not talked to the 10 people down there since lunch. 11 MR. PEVELEY: I have not either. 12 MS. LETSCHE: I think that is his position, i 13 too.
\- 14 JUDGE BRENNER: I guess I thought there was 15 still a possibility of taking Mr. Jones' deposition 16 tomorrow, depending upon our ruling.
17 Is that incorrect? 18 MR. REVELEY: That is correct so far as we are 19 concerned, as I understand the situation, but given Mr. 20 Jones' commitments, I don't know whether it's feasible 21 or not. 22 JUDGE BRENNER: I thought the response was 23 tha t he was committed starting on August 6. I 24 MR. EEVELEY: I am not adequately up to speed 25 on that. ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W , WASH!NGTON D.C. 20024 (202) 554-2345
9117 () 1 MS. LEISCHEs Judge Frenner, I'm not either. 2 MR. PEVELEY: I can be very quickly. (~} 3 MS. LETSCHEs I could, too. D Fr. Jones is here, Ms. 4 JUDGE BRENNER: > 5 Letsche? 6 MS. LETECHE But I have not spoken-to him and 7 I have to do so before I could. I didn't get this item 8 from Mr. Reveley until our last break. I didn't know it 9 was coming up. 10 JUDGE BRENNEE: '1h y d o n ' t you ask him if he is 11 available tomorrow for the deposition, and if not, why. 12 not. 13 (Pause) 14 JUDGE BRENNERt I guess I should state for the l l 15 record, ani I am sure somebody will rela te this to Ms. 16 Letsche, that we have read the motions and the 17 responses, so we are ready. 18 (Pause) 19 JUDGE BRENNEE: Ys. Letsche, if I had known 20 you were coming back so quickly I would have waited, but t 21 I stated while you were out that we have read the motion 22 and the responses and we are reasonably ready. '4h e th e r 23 or not I had to give the Parties time to get ready, () 24 depending upon whether tomorrow made a difference, and 25 that is the sole ceason that I raisad it, and I O t ALDERSoN REPORTING CCVPANY,INC, t 400 VIRGINIA AVE. S.W., WASHINGTON, D C. 20024 (202) 554 2345
9118 (m, 1 apologize for interrupting your examination, but because (_/ 2 it is 5:00 o' clock, I wanted to get a handle on what it 3 is I am supposed to be doing with the re st of my day. 4 MS. LETSCHE: Judge Brenner, Mr. Jones informs 5 me that he does have a comi.itmen t tomorrow. He has to 6 be in New York City on government business and so is not 7 available tomorrow. 8 JUDGE BRENNER: Okay. That answers the 9 question. 10 Well, we will either do this at the end of the 11 day today or tomorrow norning. If I am correct that the 12 only question is Mr. Jones' deposition and the only 13 question about that question is whether we would require G
'N ) 14 it, that is the basic question, and there doesn't seen 15 to be any disagreement as long as the timeframe is 16 August 27 or thereabouts or thereafter. When we get 17 back to it I am curious as to why the da te is so late 18 that LILCO has asked for, that is, September 15, as the 19 closing time.
I 20 MR. REVELEY: I don't now, Judge, other than l 21 perhaps an attempt to find a time period that would be 1 I l 22 acceptable. My understanding is tha t our people want to 23 take Mr. Jones' deposition now and that that could not f~) 24 be arranged on tha basis of agreement between the 25 parties. e, N ALDERSON REPORTING COMPANY, INC, 400 VIRGINI A AVE.. S W., WASHINGTON. O C. 20024 (202) 554 2345
9119 r^T 1 JUDGE BRE3FER: Did I hear something in (/ 2 passino that this still may be resolved? Discussions 3 between Washincton and Richmond sounded like very high 4 level things. 5 ES. LETSCHE: Judge Brenner, I am not sure 6 that I can represent that. As I said, I have not spoken 7 to the people in Washington since the lunch break, and I 8 actually ca n 't even speak to wha t Mr. Reveley just said 9 because I don't know all of the information or all of 10 the details wi th respect to the scheduling involved in 11 these motions. I can make a phone call and find out all 12 of that information, however. 13 JUDGE BRENNER: Well, I guess we are a little ex *
\m) 14 ahead of you. If you read the response, there are no 15 longer any objections as tc the takina of the 16 deposition, and in fact, a date has been arranged for 17 the other two county employees. So we are not going to i 18 issue any subpoen3es because that is on the basis that 19 we have been assured as to the resolution as stated in 20 the papers, and we appeciate the fact that the parties 21 continued to work it out even after initiating a formal 22 request to us. And we commend you all for that.
l 23 As to Mr. Jones, the question in essence is we l s s ) 24 are being asked to decide whether he knows anything v, 25 wortawhile, and we cannot and are not going to decide l t l ALDERSON T2ESCATING CoMAANY,INC, 400 VIRGINIA AVE., S W., WASH;NGTON, D.C. 20024 (202) 554-7345
9120 (~) 1 that, civen his position with the county and his overall v 2 position and what has been alluded to many times by the g" 3 county, his involvement in emergency planning. We b] 4 cannot decide that he knows nothing relevant to Phase 1, 5 and given the liberal discovery standard of matters 6 which could lead to admissible evidence, we are going to 7 grant the deposition. 8 This does not mean that the county is 9 incorrect, that he knows nothing pertinent to Phase 1 10 issues. We just cannot decide that. To sone extent, 11 given our action on rec onsid era tio n, the portion of the 12 county's argument relying upon our actions on EP I 13 doesn't have the same vitality it might have once had, O k/ 14 but even assuming tha FP I was still absolutely 15 rejected, our ruling would have to be the same. We 16 would have to conduct a mini-inquiry to decide whether 17 or not he knows anything given his position with the 18 county and his involvement in emergency planning. It is 19 not unreasonable For LILCO to suggest that maybe he 20 knows comething. And once you have that starting point, ! 21 and given the fact that we are talking about a 1 22 deposition and not a requirement that Mr. Jones 23 personally, with no help, answer interrogatories or [J 24 something of that nature, we are going to order the 25 discovery. I C) ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., W ASHINGToN, D.C. 20024 (202) 554-2345
q 9121 () 1 It may be that once they start deposing him, 2 his answers are going to be I don't know, I don ' t .know, 3 and I don't know. 4 MS. LETSCHE: I think the county's argument is 5 set forth in its papers in opposition to this, and that 6 is that he does not have any relevant knowledge of the 7 Phase 1 issues. 8 JUDGE BRESNER: I just 'cannot assume that. ! 9 am not saying that the county is incorrect, and I want 10 to emphasize that, but it is not as if you have got some 11 Mr. Jones off the street here who doesn't have anything 12 whatsoever to do with the area. You've got Mr. Frank 13 Jones, the Deputy County Executive who is coordinating 14 the emergency planning work for the county. 15 MS. LETSCHE: Well, that is with respect to 16 the county's planning efforts, and as I understand it, 17 this subpoena is with respect to the Phase 1 issues 18 currently before the Board, and that is what the 19 County's argument has sta ted in the papers, and I think 20 it is adequa tely sta ted there, and I do not want to 21 belabor it since you have already ruled, but that is our 22 position, that as to those issues, he does not have any 23 knowledge. (), 24 JUDGE BRENNERs Again, in the end you might be 25 right, but we cannot make that determination now, nor do O ALDERSoN REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASH;NGTON, D.C. 20024 (202) 554-2245 l J
9122 {} 1 ve have to make that determination to order the 2 discovery.
~ 3 As long as we are en this subject, I made 4 certain handwritten deletions in the subpoena out of 5 courtesy, since we have already established that Mr.
6 Jones isn't going to be available en August 5, so I will 7 issue it to LILCO, and ho pe f ull y they can mak e copies 8 and eventually file it in the record of this case, and 9 the deletions are on the first page I have deleted the 10 time and date. I have left the location. I have 11 certainly left in,the portion of the second page that 12 leaves it up to the parties to work it out, work out a F 13 mutually convenient time and location. So we are not 14 requiring that the location be that requested by LILCO. 15 We expect the parties can work that out. 16 We are leaving in the fact that the date and 17 location be established prior to August 20 since that is 18 the time we are going to start focusing on whether 19 there -- or begin to refocus on whether there are any 20 remaining problemc. 21 In terms of the date LILCO has suggested, 22 prior to September 15, that strikas us as being quite 23 late, and I just don't know what the purpose is, and () 24 nei ther doe s a nybody else. MR. REVELEY: I think I can speak to that. 25 O ) ALDERScN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON, D.C. 20024 (202) 554 2345
9123
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() 1 Whatever Mr. Chrisman and Ms. cCleskey may have had in 2 mind, so far as I am concerned, the sooner th e better, 3 3 and I am sure they will see it that way. Also, once I
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4 have had a chance to talk with them. 5 JUDGE BRENNER: Well, maybe they know about a 6 problem that Mr. Jones has that week, too. 7 Mr. Jones, why don't you come up here, since 8 we are discussing you and we know who you are, and the i 1 9 idea is we have ordered the discovery, and'I want to 10 keep it in as tight a timeframe as possible. Given your 11 vaca tion time a nd so on, we are not going to intrude en 12 that at all. So the question is af ter August 27, is 13 there a reason why it has to be as late possibly as A 14 September 15? I am inclined to put it in a tighter 15 timef ra me such as Friday, September 3, and then leave it 16 up to the county and LILCO to pick a mutually convenient 17 time between August 27 and September 3. 18 I hope Ms. Letsche doesn't mind my doing this l 19 with her client. We are trying to find a convenient 20 time. 21 MS. LETSCHE: Let me just say one thing, and I 22 certainly don't object to Mr. Jones answering your 23 questions directly, but it could very well be that one l l r" (%) 24 of the reasons for that date -- and I don't know either 25 without checking with our people -- is related to some ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTC:4, D.C. 20024 (202) 554 2345
9124 1 of the other discovery things that are going on during f) 2 that timeframe and the other obligations of the f 3 attorneys who would be involved in this deposition of i 4 Mr. Jones, both from our end and from LILCO's end. I 5 don't know, and I frankly can't speak to that unless I 6 had an opportunity to talk to them. 7 JUDGE BRENNEE: I will take care of that 8 possibility in a ninute. But let me find out if Mr. 9 Jones is booked that week. That would explain it. 10 ER. J3NES: I am scheduled to leave on 11 vacation this weekend and I don't know whether the 27th 12 date -- where the 27th date comes from because I won 't 13 be back until the 29th. 14 JUDGE BEENNER: I think the county thought you 15 would be back on the 27th. But in any event, the 16 timeframe I am suggesting would be after the 27th. r 17 MR. JONES: Well, other than the fact tha t I 18 would be away for three weeks, and that first week back 19 would undoubtedly be a hectic week in working something 20 in there and making the prior arrangements, since I will 21 not be local, making the prior arrangements before I get 22 back on Monday woald be somewhat difficult. So that 23 first week back could be a problem or could pose a () 24 problem. So perha ps tha t is why they set that back. 25 JUDGE BRENNER: Other than that there is O ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9125 () 1 nothina specific? In other words, we are already 2 delaying quite a few weeks because of your vacation, ,
/~ 3 which I think you should take and have a good time on, b) 4 but when you get back they are entitled to depose you.
5 MR. JONES: Other than the first hectic week, 6 I know of no other restrictions of my own. 7 JUDGE BEENNER: All right. 'I am inclined to 8 set the date, but I will le t -- I don't have to sign 9 this until tomorrow. I will allow Hs. Letsche and Mr. 10 Reveley to let me know. I am inclined to set the date ; 11 f or September 6, which would run until that following 12 Monday in case there a re insurmountable problems. 13 Well, that is Labor Day. I am inclined to set 14 it for September 7, just in case there are real problems 15 that first week. The 15th strikes me as gatting quite 16 late into the discovery period. However, we would hope 17 a mutually convenient date can be worked out, even that 18 first week, unless you have particular problems. 19 MS. LETSCHE: Judge Brenner, we will certainly 20 look into the situation. I will talk with Mr. Reveley , 21 and see if we can resolve it. 22 JUDGE BRENNER: But if there is 4 reason that 23 you don't know about that you want to tell me about () 24 tomorrow as to why I should leave it for tne 15th, you 25 can do that also. ("%
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9126 P. S . LETSCHE: I will check into that. (]) 1 2 JUDGE BRENNEE One reason I did it now was I i 3 want to take advantage of f.r. Jones' presence because I t O 4 did want to work his schedule out consistent with the 5 needs of the proceeding and take due regard for his 6 schedule I guess is the way to phrase it. 7 (Pause) 8 JUDGE BEENNER: Incidentally, perhaps we 9 should -- well, I won't bind it in. We know what the 10 motion is, and it starts to get a little thick. The 11 granting of the motion does not necessarily connote i 12 agreement with LILCO's view that their example of 13 Contention SA would necessarily get into matters of 14 local conditicns. Frankly, that is not the way we read 15 5A, but again, we are talking about discovery and not 16 the scope of litigation and trial. Eut I don 't want to 17 preclude that either. It just doesn't necessarily 18 connote agreement. l 19 How nuch more do you have of this panel, do 20 you think? An hour, two hours, three hours? 21 (Counsel for Suffolk County conferring.) ! 22 MS. LETSCHE: Judge Brenner, I would say 23 probably about three hours. () 24 Judge Brenner, let me just make one other 25 comment. I think that when we break I can go through my
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9127 O ' cro e exe=tastio ntee >=* come up with the moet 2 efficient way to finis h up , and I think it would be 3 helpful, frankly, to have the opportunity to do tha t, 4 and I think I could hopefully finish up in the timeframe 5 I indicsted tomorrow. 6 JUDGE BEFNNER: Could I get a time estimate 7 from the other parties, recognizing that it is 8 conditional on what hac happened so far? 9 MR. REVELEY: I think, Judge, if we end up to havinc; a realistic opportunity to get this panel off the 11 stand, that will severely limit whatever we might have 12 had in mind, and in any event, we don't have much in 13 mind. 14 (General laughter.) 15 MR. REVELEY: I mean, that was somewhat 16 facetious, but if, for example, we have our chance at 17 redirect at 2:00 o' clock we will finish it brisAly. l 18 JUDGE BRENNER: I keep telling Mr. Heer that 19 if only he could talk faster, we would finish this 20 proceeding sooner. 21 (General laughter.) 22 MR. REVELEY: It does sound like we have a 23 credible shot at finishing with the panel tomorrow. 24 JUDGE BRENNER: How about the Staff? 25 MR. ELAGK: I certainly anticipate no more O ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
9128 4 1 than a fistful'of quastions on redirert for Mr. Hodges. 2 It certainly wcn't take long. p 3 JUDGE BRENNEE4 How many questions is a L/ 4- fistful. 5 (General laughter.)' 6 JUDGE BRENNERs Is that biccer than a 7 bread bo x? 8 (General laughter.) 9 WITNESS HODGES: The question is, is that a 10 clenched fist? 11 ( G en e,ra l laughter.) 12 JUDGE BRENNER: We have questions, too, about 13 a half an hour's worth. I don't think we are going to l 14 make 2:30 if we adjourn now, even if we started at 15 8:30. 16 We would only have five hours of actual 17 hearing time if we assume an hour for lunch. I am a 18 little surprised you have three hours left. 19 MS. LETSCHE Judge Brenner, it might not take 20 that long. For obvious reasons I as trying to b.e ! 21 conservative in my estimate. 22 J UDGE BRENNER: Yes, I underctand. 23 MS. LETSCHEs Obviously the main thing I have 24 left in my cross examination plan, to give the Board 25 some indiration of what I intend to do, is items IX and O ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9129 {} 1 X. X I think is going to be the =ajor thing I will be 2 doing tomorrow. 3 You can see by 1 coking at that that it is a 4 little hard for me to esticate how long it might take. 5 It might be very quick, but it might not. But I think 6 that is basically what I ha ve lef t with my quick review 7 of my plan. 8 JUDGE BREhNER: All right. I think we will 9 adjourn, and with your ability to think through the 10 order again, I think you are right, that you will be 11 more efficient. It has been a long day for the 12 witnesses also, and while I know they wouldn't say that 13 because they are anxious to get off, I am concerned 14 about the quality of the record when you start passing 15 or aproaching that point of fatigue, and we are tired 16 also. 17 But let me suggest this to you, Ps. Letsche, 18 in that last area -- and le t me make sure I can say this 19 without disclosing i t -- in tha t last a rea when you 20 consider what you need to know in order to get to where 21 you want to get, you can go through all of the 22 variations and how they might affect the ultimate 23 estimates, or you could consider whether you could cut O 2. right threegh it ane beund these veristione es 1 25 attempted to do today, and therefore not have to worry O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
9130 () 1 about the interim arguably bounded variations. And as I 2 read the cross plan, I think that can easily be done by 3 the County.
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4 MS. LETSCHE I will certainly consider tha t 5 this evening. 6 JUDGE BRENNER: So you get your worst case, 1 7 and if you want to put a little meat on it, your next to 8 the worst case, but you don't have to get all of the 9 cases. And if you did that, I think you could cut about 10 a half an hour off of that page. But don't do it unless 11 you agree with me that you will get to where you want to 12 go because we are interested in that also. 13 One thing we can do is see -- we will 14 terminate the questions of the panel on this contention 15 at this time, and the witnesses can leave. We won't 16 talk about this issue anymore. 17 Are there other miscellaneous matters that we 18 have to consider this week that we should do tod a y 19 rather than tomorrow? 20 MR. REVELEY4 The main miscellaneous matter I 21 think we got, and Ms. Letsche and I were wrestling with 22 lt this morning, is what order to propose to you after 23 the break, and we were having real problems. We .can () 24 talk about our problems off the record or we can wrestle 25 with it some more. I don't think they are worth dealing O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554 2345
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9131 O i witu on tse rec =ri. 2 JUDGE BRENNER: All right,. work them out and 3 '
't come back until you do.
4 (General laughter.) 5 MR. REVELEY: It is not so much we are 6 disgreeing with each other; we are really net. We are 7 running into some scheduling problems. l l l 8 MS. LETSCHEa I think the only other thing, I 9 Judge Erenner, is there are two settlements I think that 10 have been, or resolutions that have been submitted to 11 the Board that you had indicated you wanted to take care l 1 12 of at some point. I 13 JUDGE BRENNER: Yes, let's leave that for O 14 tomorrow. I think we can do it fairly quickly. We just 15 haven't had a chanca to talk about all aspects of it 16 collectively as a Board. I don't now if there are 17 other -- there are other sattlements for which we aave 18 not seen the written product, and I was holding it for 19 that partially. 20 MR. REVELEY: I am afraid there won't be. It 21 is moving very slowly. 22 JUDGE BRENNEE: All richt. We will take those 23 two up tomorrow the. 24 One thing we are going to emphasize is when 25 you pick the order, which you will be talking about O ALCERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHlNGTON. D C. 20024 (202) 554 2345
9132 1 between toiay and tomorrow of what we will litigate 2 after, we expect vicorous possible narrowinc or 3 settlement conferences to continue over the break, 4 presumably, as to the issues that will come up afte'r the 5 break, and that is pretty much all issues on which 6 testirony has been filed now. 7 MS. LETSCHE: That is really one of the things 8 we have been discussine and one of the problems we are 9 encountering, I think, is where we will be after the 10 break in light of discussions that are scheduled to take 11 place during the break. 12 JUDGE BRE2NER: Well, you can pick a sequence 13 and obviously pick it with due regard to that which is 14 less likely to settle, but nevertheless, make sure 15 settlement conferences take place en even that issue 16 since narrowing could take place. And then if, as we 17 get closer to that week, you inform us that you need to 18 cuitch the order because there has been a hoped-for 19 settlement or narrowing or sone other reason, we will 20 consider it. Eat so we are not locked in to being ready 21 only on the first one that comes up, but we would like 22 it to be as much is possible close to the order that you 23 choose and maybe jump us to number two but not certainly 24 to number four the day before we are going to start the 25 litigation. O ALDERSON REPORTING COMPANY. INC, 400 VIRGIN;A AVE., S.W , WASHINGTON. O C. 20024 (202) 554-2345
9133 I forget the testimony unless I reread it (]} 1 2 sciin the day before the hearing I must confesc, and it 3 is very helpful when I reread it a few times with the 4 cross plan. Eut we have caught up to that. In fact, 5 let me remind you of that, that the cross plan on SC 25, 6 RPV integrity and testing is due on August 24. 7 Now, if you want to schedule that the first 8 one suddenly for sone reason, that is okay, but if you 9 do that, file the cross plan with th e Board a week 10 before, that is, August 17. 11 .. S . LETSCHE: Judge Brenner, is that due on 12 the 24th or the 25th? 13 JUDGE BREUNEE: k'hatever the Tuesday is. But O 14 accelerate that a week if you want to try that issue, if 15 there is a possibility tha t you will want to try that 16 issue the first week. But otherwise keep that date. 17 MS. LETSCHEs I guess we will talk about it. l 18 JUDGE BPJNNER: Okay. I don't think other 19 than the order and the settlements that there will be 20 anything else that we need to discuss tomorrow that I 21 know cf, and in that case, let's adjourn now and we will 22 reconvene at 8:30 tomorrow morning. 23 (Whereupon, at 5:25 o' clock p.m., the hearing () 24 in the above-entitled matter recessed, to reconvene at 25 8:30 o' clock a.m., Thursday, August 5, 1982.) O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
i b NUCLEAR REGULATORY COMMISSION O . This is to certify that the attachec prcceedings 'cefore the ATOMIC SAFETY AND LICENSING BOAPD
-O in the matter o f; LONG ISLAND LIGHTING COMP 7NY(Shoreham Nuclear Power Station)
Da.te of Proceeding: Auaust 4, 1982 Docket Nu=her: 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 Co==ission. Ray Heer Official ?.eporter (Typed) 9,._,
, s C
OfficiaY,eporter(Signature) O 3' . _ _ __}}