ML20081C288
| ML20081C288 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/07/1984 |
| From: | Eddleman W, Eddlwman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20081C272 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8403130230 | |
| Download: ML20081C288 (20) | |
Text
.. ., ,. - e ; Dr. '. ;
1 UNITED STATES OF AMERICA" og p?
March [, 1984 NUCLEAR BEGULATORY CO$j[SpION2 All:25 p /f7C g ?V l BEFORE THE ATOMIC SAFETY AND LICENSING ~ BOARD i Glenn O. Bright l Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of CAROLINA POWER AND LIGHT CO. et al. )
' (Shearon Harris Nuclear Power Plant, )
(Jnits 1 ani 2) ) ASLBP No. 82-h68-01
) OL Wells Eddleman's Resnonse to Applicants ' Interrog'1 tories Concerning Contentions 9, 11 and 132(c)(2)
Due to the timing of this response l, I will give Anulicants reasonable additional time beyond March 15 (should they need it) to file followup interrogatories.
/Some or all of the following resnonses may renuire updating when I get healthy enough to more thoroughly go through my files.
Right now, and for the last 2 weeks or so, I've not been able to do that because it involves heavy lifting as well as rapid sorting through large amounts of material, and I haven't been up to doing such.
RESPONSES TO GENERAL INTEPDCGATO"IES l, L(a). I used the PSAR and my memory of various critiques of g environmentalqualificationinformulatingEddleman9: an article
- a. .
in sci'ence News re Gillen 8 Clought's work on indsulator degradation en l U 1
l Sac Judge Kelley granted my oral motions for extens$on of time i
due to illness, setting finally on March "f as the resnonse date, y I had called Judge Kelley after Apnlicants became unwilling to grant I
m any further extensions, and afvised him that Applicants opposed the
$ requests I was making. He instructed me to tell Applicants that I
, AG would show the timing flexibility for them that I have connitted to l above. Idid so by telephone, also agreeing to send by first-class nail the early-completed parts of resnonses to Attorney Baxter, and to hand-
, serve lhe comoleted resnonse on CP&L ~in Raleigh (anticipated to be done l March %) as well as mailing a comnlete resnonse to Geo. F. Trowbridge.
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by radiation to fornulate Eddleman 11; the DCRD9 and NUREG-0737 Rev.1 and cossibly something else to formulated 132(c)(2). The authors Oillen and Clough oresumably have first-hand knowledge of their work (re 11). He 9 and 132(c)(2), the adequacy or inadequacy of the documents and analysis speak for themselvec.
(b),(c) see (a).
- 2. Not anplicable sinen Applicants have said they don't care who actually mailed me the information. M Set $-5 N 3 Not identified yet. I am in contact with a couple a,of experts on environmental qualification and on insulation /
e 9 polymers :butineither has agreed to be a witness as yet.
- 4. S(a) See 1(a) above. (b,c) see 1(a) above.
5 ,(a) ar? specific responses. Where no pages are identified, the entire document is referred to. I may be able to soecify better later, but now my physical condition makes a detailed nage search unduly burdensome. (b) see specific responses; sone reference documents identified in previous resconses.
6 (a) Memory and common sense. (b) Menory, all. Connon sense, as referred to in responses (or as is obvious from context).
- 7. Not identified yet, but UCS petition, NU9EGs re F-11, and Bonzon et al (this, like UCS supplemental petition, re F-9), and NUREG-0737, 0737 Rev 1, 0801, and the DC9DR and the SER (iten 18) re 132(C)(2) are likely to be used. (b) pages not yet identified except that those mentioned humain these responses may be used.
Responses on Eddleman 9 I object in part to the first 4 interrogatories as they call for "each and every reason" and my analysis is not cocolete yet.
4 9-1 Testing and analysis is not adequate. See UCs' autalemental petition 2-7-84 '(ppl-2, etc) re environmental cualification of electrical equipment. See also response to 9 9(Pd) below as to other matters it should deal with. See SER pp 3-47 to 3-51 for
concerns,and added info to be required,by NRC Staff. Further reasons are the " anomalies" identified by Bonzon et al (see "An Overview of Equipment Survivability Studies at Sandia National Laboratories" by L1. Bonzon, C.W. Craf t, W.H. McCulloch, W.A Seb= ell, TS 3 1 in proceedings, International Meeting on Light Water Reactor. Severe Accident Evaluation 8-28 to 9-1-83, Cambridge Mass (publ. American Nuclear Society, ANS Order 700085, ,
ISBN O.89hh8-112-6). See also pd 4-6 of Union of Concerned Scientists 11-17-83 "The State of the Nuclear Industry and the NRC: A Critical View" by E.E. Van Loon and E.R. Weiss.
29-2. nSee response to 9-9(2d) below. The deficiencies also include inadequate treatment of systems interactinn of qualified equinment, see e.g. UCS supplemental netition at 1-2 and throughout, See also p.33 of Sandia National Labs Final Report, Phase I
" Systems Interaction Methodology Applications Program" to OSD and NRR (NRC) by G.J. Boyed, W R. 6ramond, S.W. Hatch, J.W. Hickman, A.M. Kolaczakowski, and D.W. Stack (Nuclear Fuel Cycle Safety Research Dept, SNL, 12-21-79) which says "The Task Force concludes l that comnrehensive studies of the interaction of non-safety-grade i
components, equipment, systems and structures mad with s afety systems and the effects of these interactions during normal oneration, transients and accidents need to be made by all. licensees and
. license applicants ... The extent of simultaneous interactions considered in this review should reflect the number of non-safety-l grade items simultaneously exnosed to conditions for which they i
were not designed. Equipment identified as the cause of unaccentable l
l l
interactionsshouldbeaporopriatelymodifiedtoreducethebrobability of that interac' tion, of the safety system that is advsersely affected ahould be modified to cope with the interaction. In either event, l
operating vrocedures and operator trtining must be exnanded to include consideration of the possible permutations and combinations of
-g-non-safety-grade systems with safety systems." Look at this recort and its references for exolanation (ref. Recommendation 9, e.g.).
9-3 First, because of the use of comoarison to other systems in the testing. See UCS suplemental petition at 1-2 for reason this is a problem. Second, as stated in past response (s) on another contention, the temperature inferences for equinment are in error.
See UCS (op cit) re temperature rises, p.25; Bonzon, op cit, p.31.1.a3).
See also past response. Third, estimation methods not apolicable to actual or anticipated accident or normal oneration conditions are used (see FSAR). Fourth, systems interaction is not properly
'* "" accounted for (see above for reference and rationale, resoonse-9-2).
Fifth,the matters identified under 9-9(2d) (to the extent not mentioned already in this response) need to be corsidered accurately.
Sixth, NRC and Applicants have a tendency to downnlay safety oroblems from environmental qualffication (see UCS suopi petition and UCS State of N industry critique). Further analysis continues when I have time.
9-4 See SER pp 3-47 to 3-51; Bonzon paper cited above; UCS " critical view" pp 4-6 and " supplemental netition" op 1-2 and through out, suora. See also the above 3 answers and the answer to 9-9(2d). All of these problems to some extent involve failure to have, or use, or use sufficienktly, or use accurately, the nost up-to-date information on problems with environmental qualification l of el'ectrical equipmen*.. Up-to-date information is particularly important as to sourious signal effects and distortions of trans-mitted or measured information, which can cause severe system interaction problems, improper automatic actions or lack of proper automatic actions (or a combination of some of both at the same time or close to ench other in time). See " Systems Intreaction Methodology Aunli- I cations Program" report noted above under 9-2. All these issues are ones on which up-to-date information is necessary. J l
9-9(2d) continusd adequacy of platt maintenance urograms to assure that equienent is kept in condition it was tested under; failure to assure that terminal blocks, connectors, insulation on wiring where it fits into equiument or into connectors, etc, will function in accident conditions, steam, spray, flooding, high temperature, object impact, etc; (re this, even dust on a terminal block or connector resistance can lower insulation 4and distort signals. See references,in Bonzon et al as cited below re E-11); failure to consider radiati.on effects on equipment outside containment, eg. from high energy line break outside containnent, circulation of water with radioactivity in it vthrough the aux. building in an accident; failure to consider steam
' effects in the auxiliary building adequately, e.g. from MSLB (Main Steam Line Break), high energy line break outside containment, or emergency feedwater and/ aux feedwater system failures, steam lines to steam driven pumps inside or outside containment breaking; potential steam plus heat olus radiation effects in containment and in the aux building and other places (e.g. cable screading rooms); synergistic effects of fire on degradation of electrical equip' ment from other cuauses; failure te assure that fire-fighting measures do not impazir or destroy equipment needed for safety; failure to properly evaluate potential for submerging or partly submergiming equipment, connectors and cables and wiring and instruments and instru$entation and d data lines. If water $s highlh radioactive (as at TMI) you have to leave it inside containment so the flood level is higher -- you have to keep on injecting in a LOCA, you can't go to recirculation cooling alone or your coolant will go away from the reactor (or at least it couldn't be kent adequately cooled). In answering this question, I've used the opinions of a non-witness expert. However, all of this stuff is sufficiently sensible to be considered logical and not just resting on that person's opinions as an expert.
9-5(a). My cony of 10 CFR shows this section to exempt apolicants from compliance until some indefinite date in the future.
(b) No I'm not aware of this, indeed I believe it is false since UCS won its petition against the NRC on Environmental Qualification of Electrical Equipment (UCS v. NRC, DC Circuit, slip op, late 1983).
9.6(a) Yes, if it has to comuly with 50.49. See pn 3-h7 to 3-k9 of SER -- Staff doesn't believe CP&L connlies with aoplicable rules on this. (b) My 10 CFR 50 49 has no criteria. Staff lists the criteria in the SER, pp 3-k7 to 49, see also 3-51) and 51 wheret the a - staff lists what CP&L must show compliance with. I. infer that WCP&L< has. notashown such . compliance 'or the SER would have asaid .so.
Staff is notoriously complacent re environmental qualification of electrical equipment (with a few dedicated exceptions in their midst), see UCS supplemental petition ce environnental qualification of electrical equipment, 2.7-84, and could be expected institutionally to approve almost anything, even a sham, that CP&L put forward.
(c) I don't know, but you better figure it out, and get into como11ance with everything the Staff says you need to (see (b) abov I continue to analyze this question.
9.7(a) My 50.49 shows no format. p.k24 of 1983 edition.
(b)(c) see (a). I am not endorsing your format or info.
9,8(a) Same as 9.7(a). (b),(c), see (a).
9.9(a) I think so, but mv analysis is not conolete and due to illness I haven't carried it out yet. Anticipate getting to it in April or May, but this may be delayed to summer. I have to teach and do other things as well as this case. (b),(c) see (a).
9.iA 8(2d)l- See response to 9.6(b) above for a starter, including all electrical equipment criteria in SE9 pp 3-h7 to 3-51. My analysis of this matter continues. Reasons for inclusion obvious, see 9-6(a).
(b),(c) see above.
9-9(2d)Yes. See UCS petitions to N9C for action re environamental qualification appeal of electrical from NRC env. Qualequioment198$;1977,198h;b=*efofUCSon rule of alec test procedures understate radiation effects; lack of similarity between equinnent tested & that insta11edt failure to consider configuration & orientation effects. _
Rasponsco en Eddicman Contention 11 11-1(a) See, e.g. , NUREG/CR-2156, NUREG-CR-2157,NU9EG-CR/2877, Nuclear Technology 59:344-354 (Nov 1982) by Clough and Gillen, NUREG/CR-2763 (b) See (a).
-(c) Objection, burdensome. You can read it for yourselves and I have already done some of this in resnonses re 29/30 which you possess. I object further to having to give a reason to idebtify an item.
(d) Hypothetically speaking, under the conditions stated
. (although stripped insulation would not have a "mdch larger surface area" if stripped properly to keep the insulation intact, but only about twice the surface area (less than twice since inside diabeter is less than outside diameter) and that wculd b e mostly in a tube ofsome length, reducing air access to the internal surface), it could increase exposure to oxygen and that could increase oxygen diffusion. I doubt very much whether such an effect, even if denonstrated, would account for the effects cited cables or in the contention, since they happen on insulation left on the wires as well as on wiring and cable insulation removed from the conductors.
If the conductors or parts of sheathing or other things in contact with the insulation are intact, they may increase the effect by such means as free radicals, chemical reactions, and emissions from induced radioactivity or secondaries from imoacts of radiat* on into them.
i (I)gNo. For example, IN 83-72 reports that Anaconda flexible conduit has a poloyethyalene copolymer jackeb. (It also degrades when exposed to high stempreature, pressure and stean. )
If the conduit is metal, if there's air in it it would diffuse into the insulation, though the air supply might be limited to the extent the conduit it tightly sealed. With pressure variations such as one finds in nuclear plant containments, air could get in if
11-1(c) continusd the sealing was not excellent and excellently inspected and maintained on a continuous basis. Polyethylene is subject to the degradation effect (you should know that) cited in the contention.
You can look up the citations, try NUREG CR 2763, 2156 and 2157.
A metal conduit, by creating secondary reradiation, and by induced radioactivity, would spread out radiation dose in time, increasing the effect. Secondaries from mother jacket;ing could also have this effect to some extent.
11-2(a). I'm not sure. Further analysis is neehd.
'(b) silly question, since at extrenely high dose rates, J " degradation will occur whether accelerated or not, and be able to degrade insulating abilities of insulation on instrumentation, control and power lines or cables, leading to inaccurate readings. See Bonzon, pp3.1 3-5 et al, An Overview of Equipment SuFvivability Studies at Sandia National Laboratories; see re discrecant signals, pp 26-27 of UCS 2-7-814 Supolemental Petition for Emergency and Remedial Action.
(c) I don't know and have not established a lower linit on this dose. The increased degradation per unit dose may continue down to minimal or even near/zero dose.
11-3(a) I have not completed all such identifications, but clearly flexibility, integrit i, tensile and comoressnive steength, resistance to cracking, resistivity, dielectiric strength, resistance, and so on are necessary. Detailed explanations are burdensome and analysis can [o much further than I've done, but clearly flexibility is necessary or the naterial will crack. If it cracks or lacks any of the other pronerties listed above, it won't insulate nrocerly and that can lead to spurious signals, shorts, etc (see Bonazon et al as ref'ed above, UCS as ref'd supra),
(b) Criteria should be that it can perform its safety function
. 11-3(1) continuad after exposure to any combination of the normal and/or accident environments it can fache in a lifetime of nuclear niant onevation of the maximum extent believed possible (e.g. if a plant is operated past 30 or 40 years, will all the cables and wirinE be replaced? I doubt it).
The acceptance criteria should be performance-based and guarantee with a good margin of error (factor of 10, I'd suggest for signals, though it could be more for some signal systems or instrumentation) (factor of 5 or more for safety-related insulation for power alone -- that may not be conservative enough. Pove analysis needed here -- not sure when I'll get to it), that all safety-related
' functions and a11' functions that impact on safety-related functions can be' performed under the conditions stated in the carevious sentence. The basis for my answer is sense Lnd reliability--
your acceptance criteria for complex systems' components should -
be based on their ability to perform in that system under its full range of possible operating environments, with a good safety factor added since the consequences of nuclear a ccidents are not acceptable (or do you want to lose Eastern NC?). If the calbe or wiring insulation or any part of it (e.g. in a conduit, near a junction box or connection of any kind) deteriorates such that after the longest conceivable operating life it would not insulate adequately to insure fully correct signal quality and full insulation of all currents and voltages passing through the conductor it insulates, under the severest accident known or thought possible (e.g. LOCA, ATWS), it wouldn't meet the accentance criteria (which should include the safety factors nentioned above).
i 11-4(a). Don't you know that loss of insulation leads to short circuits? Who taught you electronics or electrical engineering?
(b) Short circuits aren't absolutely guaranteed but are very likely
! (and also not predictable as to when they may occur if the short doesn't happen immediately, e.g. moisture may affect a degraded
11-14(b) continued) cable or wire insulator and lead a short to occur; the probability eventually becomes so high it is virtually 1.
11.$. Analysis as yet incomplete. That these matters have safety significance is shown by their inclusion in NRC research programs. (see e.g. Bonzon et al cited above) referring to " anomalies" on first 2 pages (and elsewhere, I think); see UCS mapetition cited above (at 1-2) "... Sandia has recorted a number of testing " anomalies" that affect the ax11 validity of environmental qualification testing and thus raise doubts ad tonka whether equip &ent whose cualification l .
was approved on the basis of those tests is actually qualified, c '#-'- Not only are the co nponents actually tested imolicated,(but).so is equipment which has been aoproved by comparison t o those conobnents.
. . . Any plant for which this determination (that it can operkte safely w/O qualification of those comuonents) should be shut down until the components are qualified or replace, or iuntil the licensees can provide justification for continued operation pending qualification of the components". It seems to me obvious that a plant with insulation on wiring, power cables, sensor and instrumentation lines and other electrical signal or power transmitting components, is not safe if that insulation can degrade to the coint of oroducing or allowing spurious signals or short circuits eighther in" normal" operation or under the stress of a s evere accident af ter operation for-some period of time. Signals and power cannot be relied on if tIeir insulation cannot be relied on.
11-26. I may have a list from you but I can't find it (PE cables and wiring). I'll need discovery to answer better. I hope you have a list of all ,the cable and wiring sterials in the plant (esp those exposed to radiation inna containment or in the aux building or elsewhere, which carry power or information needed for safety functions (or which the lack of can screw up safety functions))
p 11-6 continusd by conductor material, insulation material, sheathing tyne(s), etc, or information from which this information can be derived. You really should be doing this research yourselves (or having someone in the industry do it for you on an honest and competent basis,
-if that's possible) in light of the safety risks of degradation
. of insulation in nuclear plants.
11-7(a) Anywhere there 's radiation. Discoverv needed to give greater specification. Gamma is not annarently the only radiation causing degradation effects that vary with dose-rate.
The lack of testing with beta or alpha or combined -sources -is a problem in my view. Please note that 11-2, supra, identifies a very broad range of dose rates and at the uuper end there will necessarily be degradation due to high radiation dose.
I am not sure if there's a list of all Harris calbe and wriring by radiation zone or whether radiation-exposed cable or wiring outside cont &inment (including lines transmitting information or signals ) is listed. I'll ask.
(b) Discovery needed for more detailed answer, casee (a) above.
Also, conditions other than " normal, full nower operation", e.g.
up-and-down operation in the style of Brunswick (or Robinson 2 with degraded steam generators), accident conditions, etc must be considered to give a valid answer as to the risks posed by ins'ulation failures. Also note (Bonzon et al, op cit,n.3 1-1) that failures of supposedly similar or identi6a1 material for insulating can happen when other similar material passes the test.
This is another reason to have a big safety factor in acceptance criteria (considerthisanupdatedtoanswersto11h(a)and(b).
I hone you've done such an analysis. You need to.
11-8. Because during an accident the conditions, including
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11-8 continuad -
heat, pressure, moisture, steam, physical spray pressure or object impacts, shocks or vibrations (including earthquakes and impacts of pipe whip, expslosions, falling objects, shrapnel, whip of severed power cables or conductors, etc),as well as radiation can push a degraded insulation past its breakdown point, individually or in combination. Once these effects (individually or in combination) have had this result , the insulation hasn't got the integrity .
it needs for safe function of the plant, Why do you think you c
put insulation on donductors anyway? It's to segregate the signals
% . sand /or .information and/or power and/or characteristics of the s
.' electrical 'einergy -in the conductor (s ) from the environment so that this electrical energy performs its oroper functions and does not perform anny other functions (e.g. sourious signals, power drains or surges), or fail. Further analysis can be done on this, but the basis should be evident to you if you have common
. sense.
11-9(a) I don't know, because a lot of this material may not be subject to visual inspection, and taking it out of service for detailed einctBical tests on a regular basis may not be possible unless the plant is completely renwired to nvovide backups to all
( wiring, cable or signal pathways. Inspection should be very frequent as suddent insulation failures (e.g. cracking) are apt to happen randomly and (by Murphy's Law) where you least exuect them or where you ust looked before.
(b) I'm not sure. I'll ask you on discovery, but I don 't recall such guides right now.
11-10(a.).Use cables, wiring and signal paths with insulation which is either (1) Not subje,ct to degradation of the type (s) identified in this contention, or (2) able to meet the acceptanco
11-10(n) ccntinusd criteria identified above by me (e.g. 11-3 answers). If you can't do one or the other of these, you shouldn't operate the plant.
Basis: as stated above; not overating the plant based on Atomic Energy Act's safety-first requirement. Using equipmert not subject to the effect(s) would obviously obviate the contention if such equipment could be found and demonstrated conclusively to not be subject to any of the effects.
(b) I d'on't recall now; OBXJECTION to research as burdensome, besides, Applicants should have figured this out for themselves.
, ANSWER: It is not rational to tolerate the effect in the first place, and I am not sure any maintenance standards humanly nossible in a plant laid out end designed as Harris is,can " correct" the degradation effeeb described in interrogatory 11-1 or in contention 11.
11-11. I'm not sure. I'll ask you on discovery, but I think possbly neoprene is less subject to the effect. I haven't searched for test data on it.
11-12(a) I can't find a 50 49(e)(4) in my 1983 version of 10 CFR. Page 424 lists a section 50 49 which suspends the June 30, 1982 deadline for environmental qualification of electrical equipnent to be conpleted. It is my understanding that the DC Circuit Comurt of Appeals overturned this suspension in UCS v NRC, decided in late 1983 (b) You bet! See UCS 2d petition (supplemental vetition) cited above. N40 fails in many respects on environmentat qualification (exanples galore in UCS petition op cit), takes ridiculous risks inn allowing plants to operate with safety related equipment known to be able to fail either in normal operation or under accident condition, doesn't even require notice recipients to take any action or (in some cases) even check their plants for such equinment or identify such equipnent in their plants to NRC, fails to order necessary or appropriate corrective actions on such failed or falliable equipnent.
The odds that against this background they'll do right on the cable
11-12(b) continuod and wiring insulation degradation issue are small indeed.
(c) See(b). "It's hard to make things foolproof because fools are very ingenious" (paraphrase -- Mark Twain). NBC Staff's record as laid out in UCS Supolenental netition (suora) can well be said to be one of a bunch of fools. I believe NRC Staff will continue such foolish practices until someone (or a horrible
- nuclear accident) stops them. (This does not apply to those NRC employees dedicated to preserving public health and safety --
but the idea that someone so dedicated could have auproved of
. <7 . ithe inactions and foolishness outlined in UCS's sunplemental
< petition, is just ridiculous.)
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Responses on 132(C)(2) 1(a) The contention does not say the enerator is at the desk.
Rather, it refers to the fact that an operator standing, e.g., by V b or Q [N fro R vf d) one of panels 1 thru 5,qhas a view of panel 10 or an operator or other person standing there, which is blocked (apparently) by panels 12 thru 15. The block angles from panel 1 are about 20 to 30 degrees from a line narallel to the east wall. From panel 5 the block angles are about 10 to 20 degrees
- f m the same an narellel.
frbm b Tw WC Gbouf 39 h> JE' It is not possible to give distances in feet on this daart since
+ ? GbOu t 33 k ;% gp8 Figure f has an inconsistent sacale. For example, the distance smarked.518 5'0" sfrom panel 16 to panel 5 is about 1/2 inch, but the distance marked 1580 from panel 5 to a centerline is about 1 and 3/8 inches. A line marked 6,'O by nanel 1B1 is 9/16 inches while a nearby distance of 2'O is actually 5/32". The distance marked 1180" by section 19 is about one indh, (31/32"' as I measure),
and all these are uretty inconsistent. I should not have to puzzle out a drawing that direct measurement indicates is not to scale.
It says on figure 2 "DWG not scale"; dittto on Apnendix D figure 2 and figures A and B of Anpendix D (all to DCRDR), all of which are drawings of the control room. I therefore OBJECT to asking me to measure distances bn a drawing that l says it is not to scale, and is considerably smaller than it is I convenient to measure distances on. I suggest that if you will get a competent draftsnerson to draw a large scale drawing of your control room design (which I understand you have set into concrete already) you can figure out the distances yourselves.
Likewise as above, a view from the frnnt of panel 10 is blocked between angles about 50 degrees to 65 degrees from a line parallel to the north wall, by cabinets 12 tnru 15 d possibly 3 fren nanel 10.
Tnis cuts off views of panels 1, 2)
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132(c)(2)-1(a) continued.
From panel 9 the block angles are about 45 to 60 degrees from the same line, blocking panels 1 and perhaus 2, as well as 6 and 7.
Panel 10, of course, cannot see panel 7 and probably not nuch if any of 6's front. (It should be obvious that a blocked view is blocked in both directions, i.e. each block innlies a block from the last paneh4to the first as well as from the first nanel(s) to the last. )
From panel 8 angles about 32 to 52 degrees from the north wall varalle1 line are blocked, obscuring panels 1, 6 and 7 and nart of 2 nerhans.
a5his list may not be exhaustive because I'm exhausted writing this
- v. .4 i, <
& may have to update (see p.1 of these responses).
(b) read the contention. Unfortunately, the drawings in my copies of Appendix B of the DCRDR are illegible and may not even cover the panels this contention deals with. I will file discovery to get your latest panel layouts in a legible form.
(ii) This calls for more detailed analysis; read the contention for the basic info. I will file discovery on this too (see (1) above),
but it is clear that during an accident operators could not just read panels from distances that appear to be on the order of 25 or 30 feet on your not-to-scale drawing of the control room, DCRDR
" Figure 2" (iii) as to other panels, I need discovery to see what info is on most of them. I do not believe the SPDS nrovides the infocrequired in useful form; indeed, Applicants have said in response to my criticism of the SPDS that if it doesn't have the info, other panels will have it. Applicants' layout of the control board in DCRDR App B is illegible in general.
(c) If you' are unable to provide legible and to scale drawings of your own control room in a' report on its design that you have submitted to NRC for approval, I think you're in bad shape. I'll answer further once you provide the information needed (see above).
132(c)(2)-1 continued (d) The basis is your failure to provide sufficient information to do analysis beyond that stated in the contention.
2(a) I need discovery to see if that's all that's on panel 7.
If you didn't need it in the c ontrol room, I wonder why you lef t it there . However, a failure of the condensate booster pump would cause trouble for keeping the plant cool and/or nroperly demineralized.
Further analysis whill have to await discovery resnonses from you.
(b) If the condensate booster pump doesn't work, or its cottrols mess up, its operation can be affected advmersely. If that havnens, the operators need to know it. Reca11k that the TMI accident began with some "non-safety" demineralizers screwing up. I have exnlained before how hydraulic controls can foul things uo with water hammers.
The TMI-2 accident should certainly snow that is possible. However, I need discovery to clarify these matters and make further ananlysis.
3(a) You shouldn't' assume I agree with your analysis in the DCFDR. I am concerned that a failure of makeup water can contribute to cooling failures, and that it might not be noticed in an accident where many things go wrong at once.
(b) Without the cooling towers, you have to go to another heat sink, but it might be biologically clogged, broken by an earthquake, crushed or blown up by terrorists, etc. This cooling tower water then becomes very imnortant, because without it you'll probably be venting radioactive material to atmosphere to keen the reactor cool. More analysis of such scenarmios can obviously be done. I'll try to get to it in the next counle of months.
h(a). Please look at the contention and my July P, 1983 fil$ng at 6. I believe you are in violation of GDC 1 (10 CFR 50 Anp A) because the control room is inadequate to its purpose and functions; also in violation of GDC 19 because you can't naintain the plant RrA n. hncaR@m_flonrkMX6AlfvmMbaham_ _ _
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l
- ?h s r@t (bVta[ MY5L h&W h (b) read the contention and above-cited documents, please.
1.ag '
(c) For reasons stated above and in above-referenced documents and inn above responses on this interrogatory. Further analysis awatits (a) discovery and (b) time for me to do it.
(d) Not Applicable.
5(a) Yes.
(b) For the reasons stated in the contention and/or above, and because the signal demnsity analysis on up 6-11 is just exactly backwards of what is needed for anecidents (where high signal t ,
density and rapid change would be what is going on), thus violating
%GIE 12end '19;: because the changes increase the error rate on panels 8-11 (Table 3, App D to DCRDR, p.10; because, an as discussed in section 2 4, having to move to see the nanels (e.g. as mentioned in the contention and above) imposes more strain on short-term memory. This would be critical during accident conditions where a missed memory could lead to a lost plant. Further, during accidents interruptions would be frequent and signal deansity would be high.
Moreover, the data cited on pp 11-12 (2.hb) shows that operktors could not be exnected to remember 3 semparate things for more than 3 seconds with 75% accuracy, and that retention would drop to 25%
in 12 to 14 seconds. Under those circumstances, a complete analysis of what each operator would need to be remembering at each noint of any accident sequence needs to be done, especially for severe accidents. The effect of interruptions (e.g. from NRC or odier plant personnel or other things going wrong) needs to be factored into this analysis. Section 2.4 e (p.12) says that to walk 28 to 30 fett "at a fairly rapid pace" (e.g. from panels 8,9 or 10 to 1,?,3,h,5, 6 or 7) takes 6 seconds and thus in involves a menory decrease of 50%.
Oral communication might not be possible or reliable in an accident due to numbers of alarms sounding, numbers of people in the room, etc.
132(c)(2)-5 continued (5(b) continued)
The DCRDR does not appear to have done any such analysis.
You could do it with a computer and some good memory scientists.
Please don't forget.
,. The radiation monitors (p.14, see 2 4.2 ibid) are said to have unumerous small lights of possibly low luminance. These are critically important, it would seem to me : radiation monitoring is crucial in an accident. Also, under emergency conditions, the control room lighting could flicker or not be at 100%. Burnt-out light bulbs could have an adverse effect on readability of these monitors. The assumotion that 1/8 inch lights can be read well at 23 feet distance, especially under accident conditions of high information overload on the operators (and possible panic or stress) is highly questionable. Have you considered testing the ability to discriminate between 2 lights 1/8 inch in dianeter j at a 23 foot distance? I think it would be very difficult to reliably know which light was in which position at that distance, since few people have depth perception accurate enough to judge such small offsets at distance.
The movements required for operators (tables 6 and 7) are such l that the operators better be 017mnic runners with amar.ing short-i term memories in a seiious accident. Or there will have to be
! a lot of people in the c ontrol room to read all the info you need to inanptge serious accidents, including LOCAs, power excursions, steam generator tube ruptures, rod ejec* cions, ATWS, etc.
(c) Because the recommendations (3 0 DC2tDR App D) fail to l
address and/or resolve the above problems.
- 6. Objection to extensive search required to answer this.
It's burdensome. When I am able, I will dig out what I have on this that is readily accessible and will identify it to Apolicants and produce at a mutually agreeable place and time for insnection & couying.
l _
_I don't believe the one videotanti tann.arvs
Production of Documents Documents identified in the above resconses, except NRC documents identified and documents in Applicants' possession or originating with Applicants, will be made available for inspection and conying at a mutually agreeable time and place.
VERIFICATION Wells Eddleman hereby affirms that the above answers are true, except as to matters stated therin unon information or belief,
- and that he believes those to be true, to the best of his nresent Jknowledge and belief. March 7, 1m981.4 czg, -
Wells Eddleman Special Arrangements
" rushes" in readable form of parts of the above to be mailed to' Tom Baxter, SSP &T, for Applicants, as available (oral agreement of W.E. with Baxter) response comolete Hand-service of the aboveg to be made on CP&L (anticipated March 8 at Raleigh headquarters, legal dept.) (commitment by WE to Applicants)
Express mail service to Judge Kelley of ASLB and to Applicants in Washington DC (phone conversation of W.E. with Judge Kelley when extension was granted to file today).
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