ML20093L399
| ML20093L399 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/24/1984 |
| From: | George Minor TECHNICAL ASSOCIATES |
| To: | |
| References | |
| CON-#484-558 OL-3, NUDOCS 8410180553 | |
| Download: ML20093L399 (60) | |
Text
l ":P ORIGINAL #em UNITED STATES OF AMERICA P-NUCLEAR REGULATORY COMMISSION
- 0M ETED
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'84 00T 12 P3:58 L m u.
- ...w :.a recy,~: i j f,~ a::q In the matter of:
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LONG ISLAND LIGHTING COMPANY Docket No. 50-322-OL-3 (Shoreham Nuclear Power Station, Unit 1) l l
1 Deposit' ion of: Gregory Minor i
I, Location: Hauppauge, New York Pages:
1
- 37 l'
Date: Friday, August 24, 1984 O
1 PDR TAYLOE ASSOCIATES Coun Repon m 1623 i Suset. N.W. Sete 1004 Waslunston, D.C. 20006 (202) N 3 3950
o 1 W1'l 1
1 UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION 2
3
X 4
In the Matter of:
- Docket No. 50-322-OL-3 LIGHTING COMPANY 5
- (Emergency Planning
- Procedures)
(Shoreham Nuclear Power Station, Unit 1) l 7
X H.
Lee Dennison Building 8
Ninth Floor Veterans Memorial Highway 9
Hauppauge, New York 11787 10 Friday, August 24, 1984 11 The Deposition of GREGORY MINOR, called for 12 examination by counsel for LILCO, commenced at 9:01 a.m.,
13 the witness having been duly sworn by Myrtle H. Traylor, 14 a Notary Public in and for the State of Virginia.
15 16 17 18 19 20 21 22
.AL 2
1 APPEARANCES:
2 On behalf of LILCO (Deponent) :
3 LEE ZEUGIN, ESQ.
Hunton & Williams 4
707 East Main Street Richmond, Virginia 5
On behalf of Suffolk County ( Re spondent) :
6 CHRISTOPHER M. MC MURRAY, ESQ.
7 MICHAEL S. MILLER, ESQ.
Kirkpatrick, Lockhart, Hill, Christopher & Phillips 8
1900 M Street, N.W.
Washington, D. C.
20036 9
On behalf of the State of New York:
10 RICHARD J.
ZAHNLEUTER, ESQ.
11 Special Counsel to the Governor Executive Charaber 12 Room 299 State Capitol 13 Albany, New York 12224 14 On behalf of the Nuclear Regulatory Commission:
15*
BERNARD BORDENICK, ESQ.
Office of the Executive Legal Director 16 U. S. Nuclear Regulatory Commission Washington, D.
C.,
20555 17
,18 19 20 21 22
l 3
=
l 1
ESEEEEES 2
3 WITNESS DIRECT CROSS 4
Gregory Minor 4
30 6
7 8
EXHIBITS 9
Minor:
For Identification 10 No. 1 7
11 No. 2 10 12 No. 3 12 13 No. 4 21 14 15
~
16 17 18 19 20 21 22
PROCEEDINGS 4
.o-GREGORY MINOR was called as a witness and, having been first duly sworn, was examined and testified as follows:
1
-DIRECT EXAMINATION 2
'BY MR. ZEUGIN :
3 Q
Please state your full name and business address 4
for the record?
5 A
Gregory Minor, my business address is MHB 6
Technical Associates, 1723 Hamilton Avenue, San Jose, 7
8 0
I would like to start by asking you, I think, 9
some very brief backg.round questions.
I have looked at 10 your resume, and I was wondering if.you have currently 11 l
or have ever had an operating license to operate a nuclear 12 power plant?
13 A
No, I have not.
14 Q
Have you taken any courses in reacter operations?
r 15 A
It is hard to say.
You can almost call the 16 Shoreham hearing a course in reactor operations, but no l
17 formal courses.
I I8 0
What documents have you reviewed in preparation I'
for testifying on the strike issues?
l l
20 A
In preparation for the strike issue, I have, 21 of course, looked at the affidavits originally submitted 22 on this issue by LILCo.
I have looked at the Board order I
5 1
which sets out the issues that are concerned, and I have 2
looked at some of the Chapter 15 analyses in other reviews 3
that have been done.
For instance, low power, and then 4
the FSAR to see what the content would be, and how that 5
would compare to Mr. Rigert's and Mr. Stergakos' analysis.
6 In addition, I have looked at the few discovery 7
documents that have been supplied, including the portions 8
of the tech spec which I am not sure of their status or I
revision or finality, but at least the portions that 10 were provided, and the other discovery documents which were 11 related to the analysis done on the refueling accidents to 12 determine the length of time fuel must be held before they 13 would r61 ease PAG limits levels of radiation to the boundary.
I4 0
Okay.
Let me try and distill for you the 15 question I still think that is in front of us, now that the l'
Board has taken out its first question, and ask your opinion II on that question.
And that is whether placing a plant in I8 cold shutdown during a strike by the LILCO unions is an II adequate measure -- and let me read you the Board's language, to give reasonable assurance that. adequate protective measuren 21 can and will be taken in the event of a radiological emergency.
22 A
And your question is what is my opinion about that?
6 e
1 Q
Yes, sir.
How would you answer that question.
2 A
In general, I would say that I am not satisfied 3
that the proposed LILCO solution will meet the question posed 4
in Question 3.
5 Q
Could you detail for me why you are not satisfied 6
where the, in your view, the LILCO proposal may fall short?
7 A
Well, an area of concern for me is the question 8
of whether the staffing is really adequate, and this is based 9
on my preliminary review of some of the numbers of people 10 involved, and some of the numbers of people required.
11 Q
Is that staffing that you are referring to the 12 onsite staf fing that would be required to keep the plant 13 in cold shutdown, or are you talking about staffing of 14 perhaps an offsite response organization?
15 A
I think the staffing of an offsite organization 16 is certainly inadequate in terms of a strike being carried 17 on by the union.
So, I am speaking more of the onsite 18 staffing.
I9 Q
What particular questions do you have about 20 that staffing?
21 A
Well, based on my preliminary review and the 22 documents that have been provided in discovery, it looks
o 7
s l
1 like there is a fairly minimal skeleton group available 2
to cover the requirements of operations and other functions 3
which would have to be performed during the transition to 4
cold shutdown, and maintaining the cold shutdown.
5 0
Are there any particular job functions you are 6
concerned about as being particularly thin?
7 A
You have to divide workers into two categories.
8 The operators, and the others.
And the operating level they identify in this discovery document of a few operating 10 personnel who are non-union, not a large number, but there 11 are some, and they identify very few people in the non-12 union functions.
By this, I mean some of the maintenance 13 and instrument techs and things like this, who would l
14 normally be around but wouldn't necessarily be around during l
15 a strike.
14 0
Let me make sure I know which discovery document 17 you are referring to.
Let me show you a document that I 18 will have marked Minor Exhibit No. 1, and ask you if that I'
is the document you are referring to regarding the manning 20 levels and drawing some of the conclusions we have just 21 discussed?
22 A
Yes.
I believe this is the same document I
8 I
was referring to.
2 Q
Now, as I recall that document identifies the 3
fact that during a strike there would be twenty licensed 4
operators available to operate the plant, is that correct?
5 A
It identifies twenty people with different 6
job titles, and says that these are non-union LILCO 7
employees who are licensed Senior Reactor Operators, yes.
8 Q
And I believe it also says that as many as 9
five could be available to man each shift that would occur l
10 during a strike, does it not?
11 A
It says five licensed operators will be available 1
12 on each shif t during any perceived work stoppage, yes.
13 Q
Now, is your concern that the five operators l
14 that would be available on each shif t are not a sufficient 15 number to maintain the plant in cold shutdown or, I guess l
14 to use your term, a skeletal crew?
l l
17 A
If I look at a strike condition, I would wonder l
18 if five people would always be available, for various l-II reasons.
I can't list them right now, but you just have l
20 to think that a strike can occur at any time.
Various 21 seasons of the year, or what have you, and it may not be 1
22 that all those people would be available.
9 1
Q Do you have any opinion as to what number of 2
operators would be required on each shif t to maintain the 3
plant safely in a cold shutdown condition?
4 A
A portion of the tech spec has been provided 5
to us, which sets out some minimum requirements and I 6
would rely on that as sort of an agreed upon minimum 7
of the staff, but that is for licensed operators.
8 Q
Let's talk briefly about the other jobs in the 9
plant that are non-licensed jobs.
Is there any particular 10 document that you would use to determine whether or not 11 people available at the plant, or a skeletal force, are 12 more than sufficient to carry out those jobs?
13 A
I would have to ask you to repeat that.
14 0
Let me draw an analogy, and I think that may 15 make the question a little clearer.
You just told me that 14 the tech specs are a way of determining a minimum amount i
17 of people -- of operators needed to operate the plant and 18 keep it in a cold shutdown condition.
19 What I guess I am getting at, is there some 30 type of parallel document -- is there some type of parallel 21 document that you would look to to determine whether the 22 amount of other workers in the plcat are sufficient?
10 1
E.
There are other documents that would - define 2
normal-shif ts, I think, in the LILCO documentation, but 3
I am not sure where I would look to find the minimum 4
required non-licensed operators in the plant.
5 Q
Are" there any particular job categories that 4
are of more concern to you in that group than in others?
7 A
Just the ones I mentioned.
8 Q
In your deposition you stated that you had 9
reviewed the af fidavits that have been provided to you.
10 Let me show you a document that I will have marked as 11 Minor Exhibit No. 2, which is the affidavit of John 12 Scalice, and ask you if that is one of the affidavits 13 you are referring to in your review?
M A
Yes.
15 Q
Let me ask you to turn to pages 2 through 4 14 of that document, which describes the procedure that 17 would be followed in bringing the plant to full shutdown.
A All right.,
M Q
In reviewing this affidavit, did you find any 20 reason to disagree with the steps that are described there?
21 A
Are you saying would I have written a different-22 procedure to bring the plant to cold shutdown?
i
)
m-t 4
,v Ca1 11 1
Q I think what I am asking you is chat a reasonable 2
way of bringing the plant to cold shutdown. safely?
3 A
When you add the word, ' safely, ' you change 4
the predicament.
I would say that these are steps which 5
will probably bring the plant to cold shutdown in an orderly 4
fashion.
7 0
On page 4 of that affidavit, there is an 8
estimation of the time required to complete those steps.
9 Do you have any view on the reasonableness of that time l
10 estimate?
l 11 A
I think if you were trying to maintain the 12 cool down rate at a steady value within the normal tolerances 13 of what you would like 'for your vessel temperature change 14 and so forth, these are probably in the ball park.
l 15 0
Let me go back a minute to an earlier statement 14 you made, which is basically the fact that you weren't 17 satisfied that the LILCO proposal necessarily answered the 18 Board's question, and you stated that one of the reasons l'
for that is you have some questions about the staffing, 20 and we have explored that.
21 Were there any other reasons why you feel that 22 the LILco proposal may not be satisfactory?
12 1
A Well, based on my preliminary look at this, I 2
have some concern about the wording of the licensing --
3 licensed condition, rather.
4 Q
Let me show you a document that I will have 5
marked Minor Exhibit No. 3, which is the affidavit of 6
Matthew C.'Cordaro.
I take it this was another of the 7'
affidavits that you reviewed, is that correct?
8 A
That is correct.
9 Q
I believe you will find the language of LILCO 10 proposed licensed condition on pages 3 and 4 of that 11 affidavit.
12 A
That is right.
13 Q
Could you point out for me the portions of 14 that proposed licensing condition that you have concerns 15 about?
16 A
Well, in general.
If I were writing this 17 licensed condition, I would certainly start out to make 18 it a conditiohal operation
- instead of a legal agreement, 19 as it reads to me.
20 Q
I am sorry.
Maybe you can expand on that a 21 little bit to me.
How are the two different.
22 A
Well, it starts out with a very conditional
13 I
statement:
So long as LILCO shall rely on an offsite 2
emergency response organization consisting entirely or 3
primarily of LILCO employees -- blah, blah, blah, -- and 4
then it goes on, and then at the end it has all these 5
other conditions.
If they agree to do other things, 6
they will agree to do other things and do them.
7 So, it has conditions and caveats that I think 8
are unnecessary for actual licensing condition.
9 The tech spec, for instance, does not have 10 caveats like that.
11 Q
Okay.
Let me explore then some of the specifics 12 of this licensing condition.
Do yq,u have concerns with the 13 fact that the licensing condition proposes to commence 14 bringing the plant to cold shutdown twenty-four hours prior 15 to the commencement of a strike?
16 A
It proposes to do that, but it doesn't say 17 they will.
It says if they can 't, they won't.
I have 18 some concern about that.
19 0
Could you explain that to me?
20 A
It says upon receipt of less than twenty-four 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> notice, which could mean the instant a strike is 22 declared.
If they say somehow they didn't get their notice nsii
14 1
early enough, or the strike occurred, what have you, it 2
could be instantaneous.
There is no guarantee of twenty-
~
3 four hours before a strike shutdown.
4 0
Okay. Let me ask you to hypothesize with me 5
for a minute.
There is a future strike.
A strike vote 6
is taken on Sunday night, and there is an announcement 7
that at eight o' clock on Tuesday morning the workers will 3
go out on strike.
9 Under that condition, the way the proposed 10 licensing condition would operate is that LILCO would begin 11 to bring the plant to cold shutdown by at least eight 12 o' clock on Monday morning.
13 Do you follow me so far on this hypothetical?
14 A
I think I do.
15 Q
Okay.
Now, in that hypothetical situation, do 16 you have a concern about LILCO 's licensing condition, or 17 the operation of this licensing condition?
18 MR. McMURRAY:
I am going to ask for a 19 clarification.
Are you talking about the entire licensing 20 condition, or just about the twenty-four hour time period?
21 MR. ZEUGIN:
The twenty-four hour time period 22 in getting the plant to cold shutdown, and having it
..t
]
15 1
cold shutdown at the time the strike occurs.
2 WITNESS MINOR:
You are talking about a 3
restraining condition here, and a hypothetical.
Let's 4
assume under this idealized condition they had clear 5
and adequate notice, it started immediately, brought the 6
plant to shutdown, and there were no abnormalities or 7
no oddities of the shutdown process, and within the 8
time estbnated in Exhibit 2, they did achieve cold 9
shu tdown.
10 Under those idealized conditions, then this 11 condition would be a nice thing to have written into the 12 license.
13 BY MR. ZEUGIN:
(Continuing) 14 0
Okay.
And under those conditions -- those 15 hypothetical conditions, to you, this would be an acceptable 16 condition?
17 A
Now you are getting into a degree of acceptance 18 here that I am not willing to state right now.
I just don't 19 know at this point whether I could accept that.
20 0
What would you need to consider to determine 21 whether you could accept it or not?
22 A
As I said, all of these views I am getting are
16 1
preliminary.
I have to do some mozq looking myself to 2
figure out what my final position is going to[be on this, 3
and I am just not ready to make that ' statement ye't..
4
-Q What would you look at to determine. whether,
5 twenty-four hours is sufficient advance time to begin 6
to bring the plant to c,old shutdown before a strike 7
occurred?
8 A
I would want to look at three areas that 9
are involved here.
Tha type of accidents that can s
10 occur, tne staffing that is available, and what this 11 licensing condition really means to operation.
12 0
other than your concern with what you have 13 described as the caveat to this licensing condition, do' 14 you have other factual -- what I would consider factual 15 or actual concerns about the way this licensing condition 16 would operate?
3 I7 MR. McMURRAY:
I am going to have to ask for 18 a clarifiction of, ' factual,' or ' actual,' concerns.
II BY MR. ZEUGIN:
(Continuing) 20 Q
I guess what I am trying to do is divorce 21 concerns about the actual language of the condition and 22 the caveat on how it may or may not apply, as compared to
17 1
whether bringing the plant to cold shutdown, keeping it 2
there until proof is made of doing something else to the 3
NRC Staff.
That abstract idea of how the plant will 4
operate -- how the condition will operate creates a 5
problem in Mr. Minor's mind.
6 A
I am sorry.
Can you make that a little 7
narrower question?
8 Q
Okay.
9 A
I may understand what you mean, but I am not 10 certain.
11 O
Okay.
I thought you told me earlier today 12 that one of your concerns for the licensing condition is 13 it is written in legalese instead of as a true operating 14 condition.
15 What I am asking you to do is cut away the 16 legalese from this, and just focus on the way this 17 condition would operate.
18 A
Can you tell me what part of the condition is 19 still in force if I cut that away, and I will try and answer 20 that.
21 Q
Let me ask you to assume that LERO, as it 22 currently exists, will be in existence at the time of a 1
i
.c 18 1
strike.
2 I think that cuts away the first part of this, 3
which is the, 'so long as' clause.
I think you then begin 4
in anticipation of a strike, and that commitment then 5
proceeds and runs through the end of Point 2, and'I think the 6
last paragraph where the condition being terminated because 7
Federal, State or local government has decided to cooperate 8
-- let's ignore that, let's assume they have not 9
A You think that now would cut out the legalese.
10 Are you saying all the way through Point 2?
11 Q
Yes.
12 A
1 would not find that acceptable.
13 Q
Okay.
Why not?
14 A
For the same reason I stated earlier, too Sany 15 uncertainties in it.
For instance, until the end of the 16 strike.
What do you define as the end of the strike?
Is 17 that when somebody says we are going to go back to work 18 soon?
19 Does that mean when all the workers get back N
to work?
Is that when ninety-nine percent of the people that 21 went on strike are now back to work?-
What defines the end 22 of the stri ke.
How do you determine that.
s s
19
\\
1 Conditions 1 and 2, I don't think I would find 2
acceptable.
3 Q
Why don't you find those two acceptable?
4 A
Basically, the condition talks about the safety 5
of the plant in a cold shutdown c idition, and Conditions 1 6
and 2 talk about it in some other mode of operation.
7 And, so, it is not the same condition.
8 Q.
Is part of your concern a concern that you would 9
not want to place in the Staff's hand an ultimate decision 10 of whether or not other conditions than cold shutdown can 11 be gone into during a strike?
Those conditions, I think, 12 are premised on first, proving the ability to go to some 13 other State, to the Staf f, and getting their approval.
14 A
I am not trying to implicate the staff's decision 15 hare at all.
I am just saying those two conditions are beyond 16 what is needed, in my mind, for licensed condition to protect I7 against the strike.
18 0
Okay.
You would merely suggest that it would maka 19 more sense to keep the plant in cold shutdown?
20 A
It would make more sense, yes.
21 Q
You stated earlier, Mr. Minor, that you have look3d 22 at the Chapter 15 analyses of other settings. I take it --
6 20 I'
A Excuse me?
2 Q
You have looked at Chapter 15 analyses that 3
have been done at other pointsv in this proceeding.
I think 4
you :s o tioned the Low Power proceeding, and also the FSAR, 5
is that correct?
6 A
Yes, sir.
7 Q
I take it the reason you looked at those analyses 8
was to compare them to the analyses that are presented in 9
the affidavit of Messrs. Stergakos and Rigert?
10 A
That is correct.
11 Q
Did you draw any conclusions from your comparison 12 of those analyses?
13 A
Well, my preliminary conclusion is that the 14 categorization that has been used by the LILCO analysis 15 into three categories.
Three star categories.
A one 16 star accident doesn't do much; and a two star accident 17 does something, but not too much; and a three star accident 18 can do more, but they still don't think it is a problem.
19 That seems to be a very broad categorization, 20 without much specificity as far as what the actual consequences 21 would be, or what they could be, with other complications.
22 That is my preliminary conclusion.
i 21 1
Q Let me show you a document that I will have
~
2 marked Minor Exhibit No. 4.
That is the affidavit of 3
Messrs. Stergakos and Rigert, and ask you if that is the 4
document that has just been discussed?
5 A
That is correct.
6 Q
Let me have you turn to the Attachment to 7
that particular affidavit, which lists 38 accidents that 8
are presented in the FSAR, and categorizes them into one 9
of three categories.
Are there any particular accidents 10 in that list that cause you more concern in terms of the 11 categories being too general, or the consequences not 12 bei;.g clearly explained, than others?
13 MR. McMURRAY:
I am going to have to object 14 to the form of the question.
I think it is overly, broad 15 and vague.
16 WITNESS MINOR:
I think you are asking if 17 some caused more concern than others?
II BY MR. ZEUGIN:
(Continuing)
I' O
Yes.
You just told me you had a broad concern 20 about the fact that the categories may be too general, 'and 21 not tell you enough.
And I was wondering if there were 22 certain accidents in that listing that created that concern
j 22
]
more than others.
1 2
MR. McMURRAY:
I will repeat my objection.
3 WITNESS MINOR:
I can 't point out specifics at this time that would cause me to identify them immediately 4
5 as an item of more concern than the one below it.
6 But what I would look for in these is the 7
involvement of human interaction, operator involvement in 8
these different accidents.
Potential consequences, for 9
instance, in there were more errors caused by human 10 involvement.
Uncertainties such as the fuel handling 11 accident, which is rated one star with a footnote that 12 says this could be elevated to a higher category.
In 13 essence it said that.
14 I guess that is my preliminary look at that 15 right now.
16 BY MR. ZEUGIN:
(Continuing) 17 Q
The first part of your answer, you said you 18 would look at the involvement of human interaction.
Is 19 what you mean by that you would look at these accidents M
each in turn, and determine the parts of the accident that 21 were attributable to human interactions and use that as a 22 means of identifying ones that could potentially have a
23 I
broader range of potential outcomes than others?
2 A
Yeah.
3 Q
You didn't mean you would look at these accidents 4
and -- assume it is a mechanical accident.
Let's just take 5
an example.
Number 4, MSIV closure, and let's assume it 6
I happened not because of human interaction, but because of 7
a failure in a piece of equipment somewhere.
8 The human interaction you are talking about 9
is not some additional event af ter the MSIV closure that 10 would define the event that is in FSAR 15?
11 A
That is also part of it.
12 Q
Okay.
Which of those two types of hum,an 13 interaction is of more concern to you?
14 A
It is hard to rank those in priority.
You are 15 i
dealing with a situation where either could be important.
16 You are dealing wit h a situation where there is an abnormal 17 situation about to occur with this plant.
A lot of the 18 workers are going to be going on strike.
Supposedly "X"
19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />, up to twenty-four, let's say.
N You are dealing with a staff shif t, where you 21 are going to be dealing now with a group of people who 22 meet the license operator requirements, perhaps, but haven 't
24 1
been shift operators for a while, or what have you, and they 2
are going to be doing functions that they don't normally 3
do, so you have both opportunities available.
That is, 4
for human interactions.
5 Q
I guess what I was getting at is whether you 6
felt the categorization here was not sufficient because 7
you would postulate events beyond the simple defining 8
events.that are presented in the FSAR as the accident 9
sequence.
10 In other words, some additional actions would 11 be taken beyond the accident that is described in the 12 FSAR to conceivably make the accident more severe.
13 MR. McMURRAY:
I am going to object to the 14 question as vague and confusing, at least to me.
Maybe
[
15 the witness can answer it.
16 WITNESS MINOR:
I was stumbling over the same 17 problem.
18 BY MR. ZEUGIN:
(Continuing) 19 Q
Bear with me.
I am doing the best I can in this.
20 area.
As-I understand the FSAR, each of these 38 accidents i
21 has a fairly clearly defined sequence of events that 22 causes it, or that define it.
Is that correct?
25 1
A They are assumed failures to start these 2
accidents, correct.
3 Q
Okay.
Now, I take it there are also limits 4
on the amount of assumptions that are made about subsequent 5
events that have occurred.
6 A
Yes.
They are assumed operable systems, for 7
instance.
8 Q
Now, I guess what I am asking is, do your 9
concerns go beyond simply doing a Chapter 15 analysis, to 10 considering whether or not these other coerable systems 11 may not operate, and what the effect of those would 12 be, or is your concern really limited to the parameters, 13 l
I guess, of Chapter 15's 14 A
Well, what we have been discussing so far 15 are the parameters of Chapter 15 analysis.
What we have 16 been discussing so far is up to that limit.
Now, I don't 17 understand the other part of your question.
18 -
Q, I was just trying to clarify in my own mind 19 what we were talking about.
What the human interactions 20 were.
I think I was a little confused.
I think you just 21 clarified it for me in your answer.
22 Part of your answer earlier about your concerns
26 1
with these three categories was that in some cases the 2
consequences -- it wasn't clear about the uncertainties 3
regarding some of the consequences.
4 Let me have you turn to page 4 of Exhibit 4, 5
Item No. 7.
6 A
Yes.
7 Q
That item provides some description of the 8
consequences of the four events that may produce offsite 9
radiological effects.
Do you have any disagreement with 10 the facts that are presented in that particular item?
11 A
I haven't tried to create any alternate 12 quantification of these events, nor to determine their 13 sensitivity to other failures or anything like that, so 14 I,
at this point, don 't have an opinion on that.
15 C
Okay.
Let me have you look at Item No. 9, which
[U 1-B 16 deals with a fuel handling accident.
I believe earlier 17 you also stated to me that you had reviewed the calculation 18 that was provided in response to discovery that presumably 19 forms the basis for this conclusion, is that correct?
M A
I have reviewed it to the best of my ability.
21 My copy is not exactly readable in all circumstacces, but 22 yes, I have.
Q Okay.
Did your review of that calculation raise
27 I
any concerns in your mind?
2 A
My preliminary review of that sa[d that it is 3
an analysis which shows the uncertainty of the safety of a 4
refueling operation, after operation at full power, during 5
a strike condition.
6 I don't, at this time, have any opinion on 7
the exact quantification.
Number of days.
8 0
I take it you have no problem with the theoretical 9
concept that as time passes following the attainment of 10 cold shutdown, the offsite consequences from a refueling 11 accident -- assuming one would occur -- decreases as the 12 time following the initiation of cold shutdown increases?
13 A
Certainly there are laws of physics which 14 govern the decay or radio active material which would apply 15 here.
16 Q
Mr. Minor, have you performed any analyses on 17 your own to study the likelihood or consequences of accidents 18 that could occur at cold shutdown?
19 A
At this time, I have not performed any analysis 20 of that type.
21 Q
Are you aware in scientific literature if any 22 such analyes have ever been conducted that you are aware of?
28 1
A None come to mind.
2-
.Q Let me ask -- there are probably just one or two 3
more quest' ions. -In your review of the materials that have been provided you, and in your thoughts to present on 4
5 testifying in 'the strike issue, have you identified any 6
conditions under which there would be a need for an offsite-7 response organization, assuming the plant is in cold shutdown f
8 at the start of the strike?
9 l,
MR. McMURRAY:
I am going to object to the l
10 question.
I don't understand what you mean by, 'any 11 conditions.'
12 BY MR. ZEUGIN:
(Continuing) 13 0
By any condition, meaning any accidents.
14 A
That would do what?
15 Q
Require the presence of an offsite response 16 organization.
17 A
That is a difficult question to answer with 18 certainty.
In my opinion, there are events that are described 19
-- for instance Mr. Stergakos and Rigert affidavit, which 20 would require the activation of certain levels of the 21 emergency response plan.
22 I am not saying that I could identify an accident
29 1
that is going to require evacuation, or something like that, 2
at this point.
But it appears to me that some of these 3
events would probably require activation of some of the 4
facilities connected with emergency response plan., and 5
to that extent there would be a requirement for some LERO 6
workers to report to their stations for possible action.
7 0
Let me try and restate your answer in slightly 8
different terms and see if you agree with my statement.
9 Is what you are saying that there are some 10 accidents that are -- that would be one of the 38 that 11 are presented in the Stergakos-Rigert affidavit, that 12 would result in an alert classification at the plant, and 13 thus, in turn, require some actions by LERO under the LILCO 14 Emergency Plan, or even say some could result from site 15 area condition?
16 Is that basically what you are saying?
II A
That is basically what I am saying.
I8 Q
But you have also not identified any accidents I'
which would conceivably lead to the need for an evacuation?
3 MR. McMURRAY:
I am going to object to the 21 question as broad.
I am not sure what you mean by, 'need for 22 evacuation.'
1
30 1
WITNESS MINOR:
I am not sure at this time that 2
I can identify any one that requires that.
You said, ' lead 3
to,' and I don't know what that exactly means, because there 4
are other eventualities that could eventually lead to the 5
requirement for an evacuation.
6 But as far as identifying one that requires it, 7
right now, that I can lay my hands on, I can't identify 8
any at this point.
9 MR. ZEUGIN:
We have no further questions.
10 Thank you, Mr. Minor.
11 MR. McMURRAY:
I think we are going to take 12 a break and --
13 MR. BORDFNICK:
I have a few.
14 MR. McMURRAY:
Oh.
15 CROSS EXAMINATION 16 BY MR. BORDENICK:
17 Q
I wonder if you are aware of any U. S. reactors 18 that have continued to operate at full power after a strike, l'
a labor strike, against the utility that held the operating 20 license?
21 MR. McMURRAY:
I am going to object to the 22 question as being really broad and vague.
31 1
MR. BORDENICK:
Your objection is noted.
If the 2
witness can answer it, I would like an answer.
3 WITNESS MINOR:
I haven't particularly looked for that type of data. But I don't recall any either, 4
5 BY MR. BORDENICK:
(Continuing) 6 Q
Would you be surprised if that data existed?
7 A
I don't know what you mean.
Would I be surprised 8
if some data existed on that subject?
No, I wouldn't be 9
surprised if some data existed on it.
10 0
Maybe data, I think, which I think was your word, 11 is a little ambiguous.
Would you be surprised to learn that 12 nuclear power plants in the United States have continued to 13 operate at full power after a labo: strike called by the 14 unions against the utility that held the operating license?
15 A
I am not sure we are comparing apples and 16 oranges.
I don ' t think I would be overly surprised by that 17 if they have the adequate staffing of licensed operators and 18 support personnel on the site to run the plant.
19 However, the question here is not whether the 20
-- it would be technically possible to run a plant with the 21 strike.
The question is whether if you had an accident during 22 a strike whether it would be protected.
If it was a plant 23 which required a lot of union employees to implement.
24 Q
Well, assuming that there has been one or more 25 jnuclear reactors in the United States that have continued h
f
32 I
to operate at full power, or some power less than full power, 2
after a strike, do you have any -- can you tell me any 3
reasons why an accident at Shoreham would be more likely 4
than an accident at any of those other plants?
5 MR. McMURRAY:
I am going to object to 6
relevance of the question.
7 MR. BORDENICK:
Your objection is noted.
If 8
the witness can answer, I would like an answer.
9 WITNESS MINOR:
That is a very difficult 10 comparison to make, because there are so many uncertainties 11 in the question.
12 First of all, you are talking about the type 13 of plant.
Is it a new plant, and new plants tend to have 14 more accidents than older plants.
Than middle aged plants, 15 let's say.
Older plants might, again, have more problems.
16 Is it a utility that has a lot of operating 17 experience?
Do they have a lot of other reactors?
Do 18 they have a lot of reactors that they can call on, similar l9 type, to have support people come in from those other 20 reactors and help them out.
21 Is it in an area that is not vulnerable to 22 natural phenomena; lightening storms, things like that,
.o 4-33 1.
. that might cause upsets of the grid or the transients, that
.2
.would cause problems.
3
~
And is it a facility that has a firm commitment 4
from support organizations for an emergency response plan 5
if they did have an accident?
6 All of these are variables that are hard to 7
put into the equation you are asking me to make.
But I-8 think, in general, a reactor is safer when it is shut down 9
than when it is operating.
It is probably also relatively 10 unsafe during the period of transition between those two 11 states.
12 BY MR. BORDENICK: '(Continuing) 13 Q
Sc, your testimony is essentially that you 14 have to make e case-by-case analysis.
You couldn't really 15 give abstract answers.
16 A
Absolutely.
17 Q
Assuming -- I posed a series of questions to 18 you based on full power operation, or some amount close 19 to full power.
Suppose I had stated the question in terms 20 of reactors in cold shutdown as opposed to continued operation, 21 Would your answers essentially be the same, or would they 22 change at all?
23 24 25
l I
34 1
1 A
State your hypothesis again?
Cold shutdown 2
being the change --
3 Q
I am sorry.
I didn 't hear.
4
-A I didn't understand the transition you made 5
from your previous hypothesis to this one.
State it for 6
me, please.
7 Q
Well, I just asked you a series of questions 8
which you have answered, and the predicate for my questions 9
was a U. S. operating reactor, oper'ating at full power or 10 some amount less than full power, but close to full power, 11 would your answers have changed if I had said-- used the 12 phrase, ' reactor in cold shutdown,' as opposed to operating 13 reactor?
14 MR. McMURRAY:
I am just going to still have 15 to object to the question.
Is there a simplier way to 16 put it, Mr. Bordenick?
17 BY MR. BORDENICK:
(Continuing) 18 Q
All right.
I will run through the list.
19 A
Would you do that please, so I understand 20 the premise.
1 21 Q
Are you aware of any U. S.
reactors that have 22 been put -- placed into cold shutdown, after a labor I
.35 1
strike by a union, or unions, against the utility which 2
held the operating license for that reactor, which is now 3
in cold shutdown?
4 A
You are testing my recollection of some 5
past events that -- I have this vague recollection of 6
reading articles about utilities that have shut down their 7
plant because of a strike.
Now, I don 't remember where 8
that was or when, but I have this vague recollection.
9 Q
You would then not be surprised, and again 10 to use your word or phrase, you would not be surprised 11 if data existed, or there was a history of one or more 12 U. S.
reactors being put in cold shutdown during a strike.
13 Would you be surprised if I pulled out a list and said 14 here is a list of reactors, one or more reactors?
15 A
No, I don't think I would be surprised.
16 Q
Specifically, if I in an attempt to try to 17 refresh your recollection, and I realize you are not a 18 walking fount of historical events such as strikes against 19 nuclear reactors, but if I were to mention, for example, 20 Indian Point, would that refresh your recollection?
21 A
Yes, it does trigger two thoughts together that 22 could go together.
Indian Point and some sort of a shutdown
36 1
for a strike, but I can 't recall whether that was the 2
incident I am thinking of or not.
3 Q
Okay, are you saying that you remember looking 4
at that sort of a situation, but you just don't remember 5
the details?
6 A
I remember reading about an event of that type, 7
but I don ' t remember when or where.
8 Q
Reading where? Newspapers?
9 A
Could have been anywhere.
Newspapers, --
10 Q
Trade publications.
II A
Yes.
12 Q
Engineering journals, that sort of thi,ng.
13 A
Yes.
14 MR. BORDENICK:
Okay.
I have no further 15 questions.
16 MR. McMURRAY:
I think what we ought to do is I7 take a break.
I don't think we have any redirect, but if 18 we do it is not going to be much.
I9 So, why don't we take a break.
20 (Short recess taken at 10:00 a.m.)
21 (10:10 a.m.)
22 MR. McMURRAY:
We have no redirect i
i 37 c.-
1 examination.
2 (Whereupon, at 10:10 a.m.,
the taking of the 3
deposition was concluded.)
4
$94
!GbGORYMINOR 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22
I CERTIFICATE OF COURT REPORTER 2
3 I, GARRETT J. WALSH, JR., Court Reporter, do 4
hereby certify that I reported in Stenomask the deposition 5
of Gregory Minor.
6 I further certify that said transcript contains 7
a true and correct transcription of the answers given to 8
the questions herein asked.
9 I further certify that said transcription was 10 done either by me or under my supervision.
11 I further certify that I have no interest, 12 financial or otherwise, in the outcome of this litigation.
13 Given under my hand this 24th day of August, 14 1984.
15 JD
/
GagrdttJ.Walsh,Nr.
j 18 19 20 21 22 i
1-COMMONWEALTH OF VIRGINIA:
STATE AT LARGE 2
I, MYRTLE H. TRAYLOR, a Notary Public in and 3
for the State of Virginia at Large, do hereby certify that 4
the witness whose testimony appears herein was duly sworn 5
by me.
-6 7
rvuss N.ao,,fM 8
~
(
9 My Commission Expires:
10 June 1, 1985 11 12 13 14 15 16 l
17 18 19 20 21 22
k $$Ve 8 h Nl NON-UNION MANPOWER AVAILABLE TO BRING PLANT TO COLD SHUTDOWN AND MAINTAIN IT IN THAT CONDITION In the event of a threatened or actual strike of union operators at the Shoreham Nuclear Power Station, actions will be eimmediately commenced to bring the plant to a cold shutdown condi-tion.
Three management staff members, the Watch Engineer, the Watch Supervisor -- each of which hold an SRO License -- and the Shift Technical Advisor, are stationed in the Control acom or onsite at all times during " Power Operation."
These individuals alone could commence and accomplish bringing the plant to a shut-down condition.
The emergency card dialer telephone could be used to notify and mobilize additional licensed reactor operators.
Within one hour from the time of a work stoppage, sufficient licensed Senior Reactor Operators can arrive onsite to assist the above individuals and man indefinitely, if necessary, four rotating shifts with five licensed Senior Reactor Operators on each shift.
There are presently twenty non-union LILCO employees who are licensed Senior Reactor Operators.
The job titles of these non-union licensed operators are:
TITLE NUMBER Watch Engineer 6
Watch Supervisor 6
-Operating Engineer 1
Operations Division Manager 1
Plant Manager 1
Outage / Modification Manager 1
Training Manager 1
Training Supervisor 1
Training Specialist 1
Compliance Engineer 1
TOTAL 20
In accordance with Shoreham Technical Specifications (Table 6.2.2-1), only two licensed reactor operators are required during a " Cold Shutdown" condition, while five licensed operators will be acailable on each shift during any perceived work stoppage.
Suf-ficient non-union licensed operators theref' ore exist to bring and maintain the plant in a " Cold Shutdown" condition indefinitely.
In addition to these licensed non-union personnel, six Shift Technical Advisors and over 75 non-licensed Shoreham management employees are available to conduct the necessary, day-to-day plant activities should a strike occur.
4 4
em^ Ex L
LILCO, August 3, 1984 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-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
)
AFFIDAVIT OF JOHN A.
SCALICE JOHN A.
SCALICE, being duly sworn, deposes and says as follows:
1.
My name is John A. Scalice.
I am Operations Manager at the Long Island Lighting Company Shoreham Nuclear Power Station.
My business address is North Country Road, Wading River, New York, 11792.
2.
I make this affidavit in response to the July 24, 1984
" Memorandum and Order' Determining that a Serious Safety Matter Exists" of the NRC Licensing Board in the Shoreham emergency planning hearings.
This affidavit has two primary purposes.
The first is to describe the actions that the operations Division would typically take to bring the Shoreham plant to cold shutdown using normal station operating procedures, and the time required to complete those actions.
The second is to discuss briefly the obligations of licensed reactor operators regarding operator relief and the turnover of reactor operations.
- 3.
The initiation of a controlled plant shutdown is con-trolled by procedures SP22.004.01, " Operation Between 20 Percent and 100 Percent Power," and SP22.005.01, " Shutdown From 20 Percent Power."
(Attachments 1 and 2).
These procedures detail the steps and supplementary activities needed to bring the plant from " Power Operation" through " Hot Shutdown" to a " Cold Shutdown" condition.
4.
The Shoreham Technical Specifications ($ 1, Table 1.2:
Definitions) define the pertinent operational conditions as follows:
Power Operation - Reactor Mode Switch in "Run" position with the average reactor coolant at any temperature.
Hot Shutdown - Reactor Mode Switch in
" Shutdown" position with the average reactor coolant temperature greater than 200*F.
Cold Shutdown - Reactor Mode Switch in
" Shutdown" position with the average reactor coolant temperature at less than or equal to 200*F.
Refueling - Reactor Mode Switch in " Shutdown" or " Refuel" position, fuel in reactor vessel with the reactor head closure bolts less than fully tensioned or with the head removed; average reactor coolant temperature less than or equal to 140*F.
5.
Briefly, the operator actions required by procedures SP22.004.01 and SP22.005.01 to bring the plant to cold shutdown are as follows:
Reactor power is reduced by lowering recircu-a.
lation flow utilising Reactor Recirculation pumps.
b.
The main steam is aligned to the Radwaste Steam Generator below 90% power.
N 3-
)
c.
Power is further reduced using the Reactor Recirculation pumps until the flow-biased rod.
blocks are reached.
d.
Existing control rod movement sheets are then utilized to insert the control rods until both recirculations pumps can be removed from Ma' ster Manual Control.
e.
Power reduction continues by the insertion of s
control rods and by the reduction of recircu-lation flow until both recirculation pumps reach minimum flow, f.
Plant auxiliaries are aligned in preparation for Turbine-Generator de-energization.
q.
At approximately 15% to 20% power, the neutron level instrumentation is activated, tested and then utilized to monitor reactor power.
h.
The control rods continue to be inserted and at'approximately 5-10% power the reactor mode switch is placed in the next condition of operation:
Start / Hot Standby".
n 1.
Generator load is reduced and the Turbine-Generator.is removed from service by opening the uain generator output breakers.
j.
Control rod insertion continues until the reactor is suberitical and then an "all-rods-in" configuration is achieved.
k.
The Reactor Moda' Switch is then placed in the
" Shutdown" position.
Ls 1.
Reactor pressure is reduced by using the 4
turbine bypass valves to maintain a cooldown rate below the allowable Technical t
Specification rate.
m.
Reactor water level is maintained using the low flow feedwater controller, and the auxiliary boiler is used to transfer auxiliary loads to auxiliary steam.,
i
^ When reactor pressure has moved below 109 n.
psig, the; P.esidual Heat Removal System is 4
s s.
}
(
i t %
s
+y r4 '
or
,e
y--
m--------c---
-.-n----
_4 l
aligned in the " Shutdown Cooling Mode" of operation and one recirculation pump is removed from service, o.
This mode of cooling is continued until the reactor coolant temperature is below 200*F at which time the remaining recirculation pump is removed from service.
At this point, the reactor is in a " Cold Shutdown" condition.
6.
The time needed to perform the entire sequence of activities described in Paragraph 5 is approximately 12 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
7.
While not desirable, power reduction can be achieved more quickly by first reducing recirculation flow and then manually scramming the reactor.
The scramming action inserts the control rods and takes the reactor to a subcritical condition in approxi-mately 5 seconds.
The time.from full power to "all-rods-in" is therefore on the order of minutes.
Subsequent pressure reduction and cooldown would follow the path described in items k to o of Paragraph 5.
Using this method of power reduction, the total time to Cold Shutdown is approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or one operations shift.
l 8.
Based on the preceding discussions, if a postulated work stoppage provided twenty-four hours of advance notification, then ample time would exist for the planned operations complement to place the reacter in a Cold Shutdown condition.
9.
My observations of those Shoreham licensed operators who are union members uniformly confirm a mature and dedicated
t l
.S.
^
e attitude on the part of these operators toward the performance of their duties, obligations and requirements of their"iicenses.
Theyarefullytrainedin;theprpgerproceduresforoperator relief and turnover, and are aware of the provisions of 10 CFR Part 55 which govern their" licenses and outline possible causes for revocation including "any donduct deter; mined by the Commission to be a hazard"to safe operation of the facility."
10.
This responsible attitude was abundantly apparent at the onset of the current work stoppage'.
'The ope $ating crew on shift provided an excellent shift turnover, which included the placement of new chart paper in all recorders, the preparation of operator t
log sheets, and even the cleaning of the control room facilities.
Even though I am~ confident of the participation of licensed union-member react'or operators in bringing the plant to cold shutdown, their participa. tion is not necessary to effectuate shutdown, following the procedures outlined in Paragraphs 5 through 7 of this Affidavit, in the times stated.
Management-level plant staff employees al.one can also perform these operations without further assistance, if necessary.
. 1 11.
Once the reactor has been brought to cold shutdown, it can be main,tained in that condition indefinitely, by management-level plant staff employees alone if necessary.
J i
a 9
4 12.
To conduct fuel handling activities the reactor must be brought to an operational level below cold shutdown:
" Refueling Mode."
Man;gement-level plant staff employees alone could also take the reactor to this mode of operation and maintain 1.t in that state.
M v
JOIDI A.
SCALICE COUNTY OF SUFFOLK)
STATE OF NEW YORK)
Subscribed and sworn tj,before me this 7 day of
~fluA M 1984.
J
,,, W~
Q)u.A. O NOTARY PUBLIC My Commission Expires on (dA c4. 30, / 9ES t;0NMIE44AAtA rANW MTARY PU8UC, State of F4w Test Me. 524615&10 m
os as 3), t9%
-=-
&4t#nt Ex 3
-LILCO, August 3, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Eefore the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
)
AFFIDAVIT OF MATTHEW C. CORDARO Matthew C. Cordaro, being duly sworn, deposes and says as follows:
1.
My name is Matthew C. Cordaro.
I am Vice President, Engineering, for LILCO.
My business address is Long Island Lighting Company, 175 East Old Country Rcad, Hicksville, New York 11801.
I make this affidavit in support of LILCO's motion for summary resolution of issues involving the effect of a strike against LILCO under circumstances where, as now, a substantial proportion of LERO members are also unionized LILCO employees.
2.
The Local Emergency Resp'onse Organization (LERO) for Shoreham Nuclear Power Station is composed largely though not entirely of LILCO employees.
Approximately two-thirds of the LILCO employees in,LERO belong to one or another of two unions.
Absent the occurrence of events not being relied on as a basis for this license application, the composition of LERO will remain roughly in its present form for the foreseeable future.
3.
In the current configuration of LERO it cannot be demon-strated that a strike against LILCO involving all of the union e
--s-,,,
l i.
members of LERO would not, under any circumstances, impair the functioning of LERO in the event of a radiological event requiring offsite response.
4.
The recently expired contracts with LILCO's unions contain no-strike clauses prohibiting strikes during their term.
Such clauses, or other clauses prohibiting strikes without notice, are typical of union contracts and are expected to be included in future contracts between LILCO and unions.
5.
Strikes of any significant proportion, generally do not begin without at least several days' notice established by either the contract expiration date, the subsequent failure of negotia-tions, or reports of unrest among union members.
Further, the mechanics of strike commencement, including membership meetings and votes, build significant time, generally several days, into the process.
The strike which began in July 1984 did not begin before the expiration date of the contract.
Union leadership worked with LILCO management to provide ample notice of the actual start of the strike and to assure a smooth transition.
I would expect, should a strike against LILCO ever occur in the future, that for the reasons outlined in this paragraph, LILCO management would have at least several days' advance notice of its imminence.
6.
LILCO management understands, on the basis outlined in the accompanying affidavits of Dr. Stergakos and Messrs. Rigert and Scalice, that the Shoreham plant can be brought to cold shut-down in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, by management employees alone, and main-tained in that status indefinitely thereafter by management
4 employees alone; and that from attainment of cold shutdown on, as long as the reactor is maintained in cold shutdown, no credible accident sequences can lead to offsite doses requiring the avail-ability of an offsite emergency r,esponse capability, i.e.,
1 rem or more to the whole body or 5 rems or more to the thyroid.
LILCO management also understands, on the basis of these affidavits, that fuel handling and other operations requiring access to the reactor core would not result in accidents having offsite conse-quences requiring the availability of an offsite emergency response capability provided sufficient time has passed following the attainment of cold shutdown.
7.
On the basis of the facts outlined in this affidavit and those set forth in the affidavits of Dr. Stergakos and Messrs.
Rigert and Scalice, LILCO would be willing to accept the following condition on an operating license at Shoreham:
' PROPOSED LICENSE CONDITION So long as LILCO shall rely on an offsite emergency response organization consisting entirely or pri-marily of LILCO employees, then in anticipation of the commencement of a strike by a union repre-senting LILCO employees, LILCO shall bring the Shoreham Nuclear Power Station (SNPS) to cold shut-down condition using normal operating procedures.
LILCO shall commence bringing SNPS to cold shutdown condition 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the commenecment of such strike, or immediately upon receipt of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />' notice of the impending commencement of a strike, with the goal of having the plant in cold shutdown condition by the time the strike com-mences.
LILCO shall maintain SNPS in cold shutdown condition until the end of the strike except that, with.the prior approval of the NRC Staff upon re-view of written application by LILCO, LILCO shall be permitted:
(1) to take the reactor to a refueling mode to conduct refueling or other operations requiring access to the reactor core if it is shown that such operations cannot result in the occurrence of any events requiring offsite emergency response capability; and (2) to conduct such other operations as the Staff shall approve if it is shown that the strike does not, in fact, impair LILCO's ability to implement its offsite emergency preparedness plan.
This condition shall terminate at such time as any or any combination of agencies of the Federal, New York State, or Suffolk County governments shall provide to the NRC written notice of its or their agreement, under terms and conditions approved by FEMA, to assume legal responsibility for effectua-tion of offsite emergency response for Shoreham Nuclear Power Station.
W Matthew C.
Cordaro COUNTY OF NASSAU )
STATE OF NEW YORK)
Subscribed and sworn Ao before me this /-#L' day of (H(//ttd F 1984 J
GRACEANN POWERS Netsty Puedic state of New York No. 304721199 d8f LM Qualifted in Nessau County
/
NOTARY PUBLIC f^
^^M e$res W.30,19 3/b/<le My Commission Expires on I
i
/}/W/A hN
. LILCO, August 3, 1984 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-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1)
)
AFFIDAVIT OF ELIAS P.
STERGAKOS AND JOHN A.
RIGERT ELIAS P. STERGAKOS and JOHN A. RIGERT, being duly sworn, depose and say as follows:
1.
[Stargakos only]
My name is Elias P.
Stergskos.
I am employed by the Long Island Lighting Company as Manager of the Radiation Protection Division; I report directly to the Manager of l
Nuclear Engineering Department.
I have the overall responsibility for the Corporate overview and technical direction of all aspects of radiological protection and the design of radwaste systems.
My i
business address is Long Island Lighting Company, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, 11792.
i l
2.
[Rigert only]
My name is John A. Rigert.
I am employed by Long Island Lighting Company as Manager, Nuclear Systems Engineering Division of the Nuclear Engineering Department.
My business address is Long Island Lighting Company, Shoreham Nuclear i
Power Station, North Country. Road, Wading River, New York, 11792.
4
[Both affiants declare Paragraphs 3 through 9, as follows:]
--.-.--,ee-u-,
w-e----,e-,-.-e----
,r,-
y,4.,..-,
t
- 3.
We make this affidavit in response to the July 24, 1984
" Memorandum and Order Determining that a Serious Safety Matter Exists" of the NRC Licensing Board in the Shoreham emergency planning hearings.
The purpose of this Affidavit is to provide support for the proposition that 24 or more hours after initiation of the descent to cold shutdown from full power following normal operating procedures -- a process which takes less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -- there is no postulated abnormal event that could result in radiological consequences in excess of EPA's Protective Action Guidelines of 1 rem to the whole body and 5 rem to the thyroid.
This conclusion is based upon a review of the events described in Chapter 15 of'the Shoreham ESAR.
The EPA PACS have been utilized in NRC licensing proceedings to help determine the need for off-site radiological emergency response capability.
4.
Chapter 15 of the Shoreham FSAR provides the results of analyses for the spectrum of accident and transient events that must be accommodated by the Shoreham plant to demonstrate compli-ance with the NRC's regulations.
This portion of the safety analysis is performed to evaluate the ability of the plant to operate without-undue risk to the health and safety of the public.
The Shoreham FSAR was submitted to the NRC Staff for its review and was approved in the Staff's Safety Evaluation Report for Shoreha. (NUREG-0420).
E
_.._m_-_
-O 5.
A numb,er of the Chapter 15 events need no longer be postulated because of the different plant configuration and system lineup under cold shutdown versus operating conditions.
In particular, the MSIVs would be closed; the reactor would be fully depressurized; and only low level decay heat would be produced.
As a result of these plant conditions, even events which are theoretically possible are of little concern since they are unlikely to occur.
Should they nonetheless occur, the available time for automatic or manual mitigation of the event would be greatly increased; the capacity requirements of the mitigation systems would be greatly reduced; and the radioactive inventory of the core and plant systems would be reduced thus reducing the potential radiological consequences.
6.
The review of the Chapter 15 analysis revealed that of J
the 38 accident or transient events addressed in Chapter 15, 21 of the events could not occur physically during cold shutdown because of the operating conditions of the plant.
An additional 14 events could physically occur, but the offsite radiological consequences would be inconsequential or non-existent.
The remaining 3 events are possible at cold shutdown but have offsite radiological 4
consequences below the PAG limits.
One of the 21 events which could not occur during cold shutdown could, however, occur during the refueling mode.
This event is the fuel handling accident that is discussed separately in Paragraph 9 below.
identifies the category into which each Chapter 15 event falls.
4' 4
7.
Of the four events which may produce an offsite radiolog-ical effect three produce doses which are at least an order of 1
magnitude below the PAG limits even at full power operations.
Event 29 represents occasional miscellaneous spills and leaks which may occur outside the primary containment.
The offsite i
consequences are described in.FSAR li 11.2 and 11.3 and are trivial (approximately 0.001 rem / year).
Event 31 is postulated to occur due to the failure of one of the off-gas system charcoal absorber tanks during system operation.
The offsite consequences are described in FSAR I 15.1.31 and the whole-body dose is l
approximately 0.02 rem.
The consequences during cold shutdown would be significantly reduced since the off-gas system would be l
out of service.
Event 32 entails the simultaneous failure of all liquid radwaste tanks as described in FSAR 5 11.2.3.4.2 and results in a whole-body dose of less than 0.0004 rem and a thyroid dose of less than 0.5 rem.
i 8.
Our review of Chapter 15, described above, confirms that no accident could occur during a cold shutdown condition which i
wculd result in any undue risk to the public health and safety.
j 9.
If fuel handling operations or other operations requiring access to the core are conducted following cold shutdown, a fuel i
l handling accident (Event 36), not possible during cold shutdown, l
may occur.
The offsite consequences of this type of accident vary depending on fuel burnup and on the time that has passed since the i
attainment of cold shutdown.
As time passes following cold i
I 5
2
.. ~
L l
shutdown, all such consequences would diminish to levels below EPA l
PAG limits.
/$u SY+
Elias P. S gakos John A.
RigdPt COUNTY OF SUFFOLK)
STATE OF NEW YORK)
Subscribed and swer to before me
. this I
day of ut 1984.
C Y0hift
'. ~
NOTARY PUBLIC My Commission Expires on R OA d 3d, / k8d' GOMMIE MARfA PARDU 40TARY PUBLIC. State of New Tert No. 52461410 Ousiified in suffem Centy Commsman Empires MtucJ 30, f Q l
l 1
ATTACHMENT 1 s
FSAR CHAPTER 15 ACCIDENT CONSEQUENCES REACTOR AT COLD SHUTDOWN, 24 HOURS OR MORZ AFTER INITIATION OF DESCENT FROM OPERATION.AT 100% POWER Chapter 15 Event Event Category 1.
Generator Load Rejection 2.
Turbine Trip 3.
Turbine Trip with Failure of Generator Breakers to Open 4.
MSIV Closure 5.
Pressure Regulator Failure - Open 6.
Pressure Regulator Failure - Closed 7.
Feedwater Controller Failure -
1 Maximum Demand 8.
Loss of Feedwater Heating 9.
Shutdown Cooling (RHR) Malfunction -
Decreasing Temperature 10.
Inadvertent HPCI Pump Start 11.
Continuous Control Rod Withdrawal 1
During Power Range Operation 12.
Continuous Rod Withdrawal During Reactor Startup 13.
Control Rod Removal Error During Refueling 14.
Fuel Assembly Insertion Error During Refueling 4
Event not possible.
Event possible but offsite radiological consequences are inconsequentiaqi or non-existent.
Event possible but consequence below PAC limits.
o
. 15.
Off-Design Operational Transients Due to Inadvertent Loading of a Fuel Assembly into an Improper Location 16.
Inadvertent Loading and Operation of a Fuel Assembly in Improper Location 17.
Inadvertent Opening of a Safety / Relief Valve 18.
Loss of Feedwater Flow 19.
Loss of AC Power 20.
Recirculation Pump Trip 21.
Recirculation Pump Seizure 23.
Recirculation Flow Control Failure -
With Decreasing Flow 24.
Recirculation Flow Control Failure -
With Increasing Flow 25.
Abnormal Startup of Idle Recirculation Pump 26.
Core Coolant Temperature Increase 27.
Anticipated Transients Without SCRAM (ATWS) 28.
Cask Drop Accident 29.
Miscellaneous Small Releases Outside Primary Containment 30.
Off-Design Operational Transient as a Consequence of Instrument Line Failure 31.
Main Condenser Gas Treatment System Failure 32.
Liquid Radwaste Tank Rupture
o 3-33.
Control Rod Drop Accident 34.
Pipe Breaks Inside the Primary Containment (Loss of Coolant Accident) l 35.
Pipe Breaks outside Primary Containment (Steam Line Break Accident) 36.
Fuel Handling Accident 1/
37.
Feedwater System Piping Break j
38.
Failure of Air Ejector Lines 1/
Event not possible during cold shutdown.
If fuel handling operations were conducted following cold shutdown and an accident were to occur, the consequences at the Shoreham site boundary would be below PAG limits if sufficient time had passed following the attainment of cold shutdown.
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e 1
4 i
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