ML20069F029
| ML20069F029 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/16/1983 |
| From: | Brandenburg B, Colarulli P CONSOLIDATED EDISON CO. OF NEW YORK, INC., MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Gleason J, Paris O, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8303220261 | |
| Download: ML20069F029 (8) | |
Text
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QQTp POWER AUTHORITY OF THE STATE OF NEW YORK
- d3 '7? 21 N0:44 10 Columbus Circle New York, New York 10019 CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
4 Irving Place N ew Yo rk, New Yo rk 10003 March 16, 1983 James P.
Gleason, Chairman The Honorable Frederick J.
Shon The Honorable Oscar H.
Paris Administrative Law Judges Atomic Safety & Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Re:
In re Consolidated Edison Co. of New York, Inc. &
Power Authority of the State of New York (Indian Point, Units 2 and 3), Nos. 50-24 7 SP, -286 SP
Dear Judges Gleason,
Shon, and Paris:
This letter is to inform the Board of our understanding of the status of additional mitigation testimony.
Licensees originally objected to the introduction of pre-filed testimony on new mitigation measures raised for the first time by Nuclear Regulatory Comrission (Comnission) Staf f wit-nesses William Trevor Pratt and James F. Meyer in their Question 1 testimony.
See Transcript at 7608-09 (Feb. 10, 1983).
The objections wer'e~ Eased primarily on the fact that the proffered testimony was not relevant to Commission Question 1 issues, but rather should have been submitted during the hearing on Commis-sion Question 2 issues.
Although it ruled that the pre-filed testimony should be admitted, the Board was evidently persuaded by the due process arguments raised by licensees.
After the Board termed the evi-dentiary problem raised by Staff's new testimony "a question of fairness to the Licensees," ijl. at 7 618, the parties and inter-venors agreed to a procedure whereby the Staff would " defer the whole testimony package on containment analysis until some fur-ther time."
Id. at 7624 (statement of Staff counsel Janice Moore).
In the interim, the licensees were to depose the Staff's witnesses, the focus of which was to be the Staff's additional mitigation measures.
See id.
Once discovery of the Staff's witnesses was complete, the licensees would file, if they so chose, responsive testimony.
See djl. at 7625.
9303220261 830316 PDR ADOCK 05000247 2
O PDR J
Judges Gleason, Shon and Paris March 16, 1983 Page 2 At the deposition of Dr. Meyer and Dr. Pratt conducted on March 4, 1983, it was revealed that, in addition to filing testi-mony on mitigation issues under Question 1, the Staff also plans to file additional testimony on still other mitigation features under Question 5.
See Deposition of William Trevor Pratt and James F.
Meyer at 7-9, 113 (Mar.
4, 1983) ( Attachment ).
The licensees reserved on the record their objection to the admission of such additional mitigation testimony under Question 5.
Ic[. at 13-14.
In light of the revelation that Staff intends to submit new, and as yet un fo rmulat ed, testimony dealing with mitigation issues under Question 5, licensees wish to inform the Board that licen-sees do intend to file responsive testimony on all f urther miti-gation devices that were not part of the Staff's Question 2 case.
To file responsive testimony at this time, however, would be wasteful because it would, in all probability, have to be supple-mented to respond to Staff's additional mitigation testimony under Question 5.
Therefore, rather than file piecemeal respon-sive testimony on the subject of mitigation, licensees intend to file a single piece of testimeny addressing all of the Staff's l
post-Question 2 mitigation measures following Staf f's completion of its submission, presumably on March 22, 1983, the due date for Question 5 testimony.
However, licensees reserve their right to object to any additional mitigation testimony filed by Staf f under Question 5.
If unsuccessful in this objection, licensees reserve their right to seek further discovery of the Staf f, before filing responsive testimony, with respect to mitigation testimony that is to be presented for the first time under Question 5.
Sincerely, kd%//w n
t-j rent L. Frandenburg F /(/ V '
aUl F.
ColarQTli Assistant General Counsel Morgan Associates, Chartered Consolidated Edison Company Counsel for the Power Authority of New York, Inc.
of the State of New Y rk o
cc:
Official Service List
7 1
this system or the other systems that you discuss in 2
rour testimony?
3 A
(WITNESS HE!ER)
As stated under cross 4
examination under Question 2, yes, and there vill be 5
recommendations either for a particular mitigation 6
feature or against the requirement of a particular 7
aitigation feature or strategy.
8 Q
Could you give us a hint as to the timing of 9
that recommendation?
10 A
(WITNESS HEYEE)
The recommendation vill be
' 11 part of the Question 5 Staff testimony to be presented 12 in April.
- [
13 Q
So that is just, so I understand it, the 14 Staff's position that -- well, let me ask you this 15 question.
Has Staff concluded what those 16 recommendations are going to be?
17 A
(WITNESS EE!EE)
I don 't know.
18 Q
Dr. Pratt, would you happen to know th a t ?
19 A
(WIINESS PRATT)
No.
20 0
Are the recommendations going to focus upon 21 the three items sentioned at page III.B.29 of your 22 testimony, namely glow plugs, the passive containment
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heat removal system, and a system for flooding the 2
reactor cavity?
e.
3 A
(WITNESS MEIER)
The recommendation vill take 4
consideration of those three elements in the mitigation 5
strategy that was presented as part of the Question 1 6
testimony.
They are candidate mitigation f eatures which 7
vill be under consideration, ss mentioned in my Question 8
2 testimony.
There are other candidates under 9
consideration.
10 Q
I have always been somewhat confused by the 11 reference to the aitigation strategy that you made here, 12 and I believe earlier.
When you said the aitigation
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13 strategy, are you referring to the strategy that was 14 part of an earlier EUREG, or are you simply using those 15 terms to ref er to the f act tha t you are undertaking a 18 process on the review of mitigation systems?
17 A
(WITNESS MEYER)
Well, are you asking how I 18 would define the term " mitigation strategy?"
)
19 Q
Yes.
How are you using that in this context?
20 A
(VITNESS HETER)
The term "mitiga tion 21 strategy" means the following rather than single out one 22 particular :cntainment failure mode and address the
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question of mitigation for that failure mode with a 2
particular mitigation feature.
3 The approach that we chose to follow is to 4
consider a group or family of mitigation features that 5
would have the requirement to prevent failure of all 6
containment failure modes that are preventable in the 7
mitigation context; that is, overpressurization from a
steam and noncondansables, overpressuriration from 9
hydrogen burns and the basemat penetration.
10 The strategy is directed to preventing f ailure 11 by all three of those containment failure modes.
In 12 this particular case it is made up of three specific 13 mitigation features that we have explored in the 14 testimony, namely glow plug igniters, heat pipes or 15 hydrogen control, and the requirement of a flooded 16 cavity.
17 0
The earlier mitigation devices that v
> the l
18 subject of the Question 2 testimony, are they sti,
19 candidates in your galaxy of mitigation features?
20 A
(WITNESS NETER)
As stated in the Question 2 --
l 21 Q
The specifi: contentions referred to on l
22 filtered vent separate contairment, are those still i -
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1 to explore any and all possible candidates, the l
2 particular ones that would be cost benefit, would be 3
attractive from a cost-benefit standpoint.
4 As indicated in the discovery materials, d
recommendations f or such alternativ6s to mitiga tion 6
features like heat pipes were suggested, and we
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7 considered it vithin the scope of our Indian Point study 8
to study these matters further to see if there was some 9
advantages to this particular system, for example, 10 relative to the ones that vera incorporated in such 11 studies as those at UClA.
12 Q
Okay.
We vill come back to the spray systems
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13 in further detail.
14 I guess, Mrs. Moore, just so the record and l
15 notice is clear, there is a distin ct possibility that if l
16 Staff is going to be presenting additional testimony on 17 other mitigation features that have not been captured 18 under Question 2 testimony, not on Question 1 testimony, 19 that we would very likely object to that kind of 20 testimony coming in under Question 5, since, as you 21 know, our position was that we thought all of this 22 mitigation testimony and discussion should have been
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under Question 2 to begin with, and now we obviously are 2
considering something under Question 1.
3 So if there is even further new analysis under 4
Question 5, I think tha t there is a strong possibility
/
5 that we would be asserting objections to that.
6 ES. 200BEa I think it should be noted that 7
the auxiliary spray system, if I remember correctly, was 8
mentioned under Question 2 as one of the better ways or 9
,o n e of the mitigation features which was being 10 considered along with the passive containment heat 11 removal system.
12 I think Dr. Meyer listed that,- and perhaps he
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13 can correct me if I am wrong.
It was listed in the 14 Question 2 testimony.
15 ER. COLABULLI:
Yes.
I guess the key question I
16 would be whether or not there would be a significant 17 elaboration of that system and of its worth in terms of 18 risk reduction.
But obviously we vill have to wait to 19 see exactly what you decide to do on that matter.
20 ES. MOORE:
Right.
21 BY HR. COLABULLI:
(Resuming) j 22 Q
Dr. Heyer, are there any o ther viable
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (2C2) 554 2345
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1 for preventa+dve f eatures that would be weighed under 2
your fifth prong as possible trade-offs to futher 3
mitigative features?
4
- 55. MOORE:
Did you mean Ques
- don 2?
5 HR. BRANDENBURG:
Commission Question 2, yes, 6
Commission Question 2 being are there other specific 7
devices to reduce the risk, et cetera.
8 BY NH. BBANDENBURG: (Resuming) 9 Q
AS I understood it, in your decisional 10 analysis for these features, the fif th prong is the 11 trade-off between miticative and preventative.
12 A
(WITNESS METER)
That is correct.
That will 13 be addressed under Question 5.
14 0
Okay.
Well, take it, then, within the context 15 of Question 5, but you have a competing list, if you 16 vill, of candida.tas that are aimed towards prevention 17 rather than sitigation?
18 A
(WITNESS HEYER)
There are, of course, th e 19 prevention fixes that have taken place over the course 20 of the last s.everal months on both units, and those, of 21 course, have been factored into the assessment and have 22 a desirable impact in ter1ns of risk reduction.
Whether ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554 2345
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