ML20099E706

Stipulation of Agreement Re Evidence Presented by Witnesses Concerning Restart Mgt Remand.Certificate of Svc & Svc List Encl.Related Correspondence

ML20099E706
Person / Time
Site:	Three Mile Island
Issue date:	11/19/1984
From:	Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20099E690	List: ML20099E688 ML20099E706
References
SP, NUDOCS 8411260033
Download: ML20099E706 (14)

Text

_ _ _ _ _ _ _ _ _. _ _ ____ __- ______ __________ _ ___ ___ ___ _. _ ._ _ _ __-_ .

> o- IIC 11/19/84 gpoBDG@

(OkkDb D(($[0 LNITED STATES OF MERICA NUCLEAR REGUT.A'IORY 03 MISSION

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EEFORE TIE A'IQiIC SAFEN AND LICENSING BOdRD In the Matter of 1

)

METFOPOIITAN EDISON CmPANY )

) Docket No. 50-289 SP

('Ihree Mile Island Nuclear ) (Restart-Management Remand)

Station, thiit No.1) )

_STIPUIATIO! CN'MAIIGR;M EVIDENCE In accordance with the Licensing Board's rulings and suggestions during its Prehearing Cbnference on November 13, 1984, and in order to obviate the asserted need for IMIA to call a number of witnesses, Licensee hereby stipulates as follows:

1. Licensee will not object to the admission into evidence of that portien of Julien D. Abramovici's October 15, 1984 deposi'dc." starting on page 43, .

line 10, and ending on page 44, line 15 (Attachment 1) . See Prehearing Conference Tr. at 28,064 to 28,076. Licensee agrees that if called as a witness, Mr. Abramovici would w testify; homver, Licensee dces not stipulate tc the factual accuracy of Mr. Terc7evici's responses in that portion of the deposition.

2. Licensee sill not object to the admission into evidence of lines 6 to-i 25 on page 16 of Walter J. Marshall's October 2,1984 depositinn (Attachment 2) .

See Prenearing Conference Tr. at 27,949 - 27,964. Licensee agrees that if called as a witness, Mr. Marshall would so testif i; however, Licensee does not stipulate to the factual accuracy of Mr. Marshall's responso', in that portion of the deposition.

3. Licensee will nct object to the admission into evidence of lines 4 to 25 on page 55 of Ivan 0. Porter's September 27, 1984 deposition (Attachment 3).

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See Prehearing Conference Tr. 27,988 - 28,000. . Licensee agrees that if' called as a witness, Mr. Porter would so testify; however, Licensee does not stipulate to the factual accuracy of Mr. Porter's responses in that portion of the deposition. ,

4. Licensee will not object to the admission into evidence of lines 6 to

.10 on page 27 of Richard W. Bensel's October 5,1984 deposition (Attachment 4) .

See Prehearing Conference Tr. at 28,061 - 28,064. Licensee agrees that if called as - (

a witness, Mr. Bensel would so testify; however, Licensee does not stipulate to the factual accuracy of Mr. Bensel's responses in that portion of the deposition.

5. Licensee will not object to the admission into evidence of the letter from @xxnas M. Crimnins to John L. W.orpe (November 1,1984) discussing the March 29, 1979 meeting at 'IMI at 3:30 p.m. (Attachment 5). See Prehearing Conference Tr. at 28,077 - 28,083. Licensee carees that if called as a witnass, Mr. Crimnins would so testify; however, Licensee does not stipulate to the factual f

accuracy of Mr. Crimnins' staterrants in that letter.

6. Licensee will not object to the admission into evidence of a one-page i

excerpt frem a doc =cnt entitled, "3/28/79 - 3/30/79 Icgs frcm Unit 1 Centrol i

Poom (ECS) of Offsite and Onsite Fonitoring Team Survey Results" (Attach: rent 6) .

4 See Prehearing Conference Tr. 27,802 - 27,819. Licensee does not stipulata that

! any radiation ruadings were taken in response to the pressure spike.

J l 7. Licensee will not object to the admission into evidence cf Licensee's Responses to 'IMIA's Fourth Set of Interrogatories, Nurrbers 14 and 15 (October 15, 1984) (Attachment 7). See Tr. at 27,800 - 27,802.

4 i

Resrectfully subnitted SIIAN, PITI'4AN, POITS & TPGBRIDC}

l Ga d/Actg 8 Ernest L. Blake, Jr. , P.C.

Cc".nsel for Licensee Dated: Noverroer 19, 1984

Attachment 1 (Paco 1 of 2)-

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I think there was Bill Lowe from Pickard, Lowe &

,. 1 A  :

2 Garrick.

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3 0 Anybody else that you can remember? fJ.

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ta 4 A There was a room full of people, I just don't Q .

5 remember who they were. George Lehmann was there, I know (pf

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6 that.

' , ' " 99 Q How about the other people you had come down with; .$ - /

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- " V' 8 Mr. Moore, Mr. Broughton, Mr. Lentz? '.

9 A I -- probably they werf there, but I do not remember. -

lo O t'het was discussed at the meeting other than Mr. i t

11 Kunder triefir.g Mr. Wilson?

12 ,

A Or.e thing that did cc::.e up was the fact thst there was a concern for hydrogen inside the Reactor Eui1 ding, and

~

13 14 the installation of the hydrogen recombiners was discussed. l 15 Q If I'm correct, the hydrogen recombiners at that 16 - point, there was no requirement that they be hooked up?

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A That's correct. I 9dd?*1..  ?,.$@@.P:,17 .N' e-

, M;318 ..se . ;. r Q .The concern expressed for hydrogen, who expressed ,

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that concern?

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A George Eunder.

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. .c;.c a 21 ri: 0 Lic he state the basis for his cor.cern?

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A To the best of my recollection, he indicated they L .-

22 l took Reactor EuildinE sample and he was reading sonswhere in i

23 : .

f 24 f the vicinity of four percent hydrogen.

23 Q Any other bases that stated for his concern?

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-A I do not recall.

2 Q Now, was there any discussion as to haw the hydrogen !

might have been produced?

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4 A I don't recall.

I 5 0 What other discussion was there on the possible  :

' 6 presence of hydrogen?

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7 A 'I don't remember.

8 0 Was there a discussion as to what to do with the C 9 hydrogen combiner? l 10 A To the beat of my recollection, the decisio:. was to yeec 6 neVS 11 get somebody from Atomics International who made the -r-lirers, D you know, to help u out since there was a potertfal~for ,

( higher than design limit on hydragen.

13 -

14 ,

O What was the design limit at that time? I 1

IE A I think it was four percent.  !

i 16 Q So, there was a decision to get adv ce from Atomics I

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l8 A Rockwell International and Atomics International. '

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/w .@ l9 One is a division of the'other. I'm not exactly sure who is i*

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,6aa.. 21 Q Was. someone in fact :,ons 11ted from Rockwell or 1; . . '

. ' ' 22 , Atomics International?

1 23 ' A Yes.

24 Q Who?

lleArte-2.; A There was a gentleman named Jim He.m:re, with whom l

L crictn a tonia acroRTING SERVICL INC. 1000 M ARKET ST.. HEG. P A '7101 HBG 2342104 P A 1 6 20 l

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Attachment 2 1G i __

1 aware of them.

2 Q How about Mr. Frederick and Mr. Faust?

3 A I'm not Fit re that they were aware. I mean they could 4 have been or they couldn't have been. That was -- I just --

5 I don't know what they knew.

6 But I am asking you now today. Ilave you had Q

7 occasion to discuss this with Gary Miller since that time?

8 I am talking @out the whole thing now, the pressurization, 9 containment sprays.

10 A I prcbably have had occasion to do that. I don't 11 remember discussing that particular part of it brt --

12 O WeII, from those discussions or anything in regard 13 to aft (r the accident, do you believe that Gary Miller knew I  :

II l about the acquisition of the containment sprays today? I am o 15l not asking if you remember from that day but through your Iti conversations and all the documents you have probably reviewed 17 over the last five years, do you have any belief as to whether I8 Gary Miller knew about the actuation of the containment l9 sprays on March 28th? I am asking --

T A I would think he did.

91 Q And why do you think that?

1 99 a Because I believe Gary was in the vicinity of the D panel at ihe time. The conversation that I remember having l

og would have been c.' one side of the panel with Gary on the M o t he r .s i.de o f the panel. That's my recol1eetion.

- Cii6ER & LORIA REPORTING JZRVICE. INC.. 1000 M ARKET ST.. HOG. PA 17101 HOG. 234 2109 PA 1800 222 GLRS U s

' Attachnent 3

-f, 'Q .Anything else?

A I don't recal1~what else he did, becaus9., as I'say, he left in the morning when they. evacuated the unit.-

Q Now, it's true that at the time on March 30th when you

. reviewed:the pressure spike, you believed it looked like a real spike--

A 1Miat's true. N Q --and not an-electrical malfunction; is that correct?

A On March 30th, yes.

, That's the first time I saw it.

I think everybody believed it then.

Q And let me ask you why is it that you judged at that time that it was, and I think your words were something to the effect it looked like a real spike te me.in prior testimony?

u A Well, I believed that this was in my prior testimony that I'd also looksd at the reactor coolant system, the pressure chart to see if it indicated a dip since the building pressure's a reference.

Q So you're saying based on your view of the pressure i spike as well as the reactor coolant system pressure which had a complementary decrease, you believed the spike was real; is that correct?

A Yes.

Q Was there any other basis on which you judged from dewing the spike that it was real?

A I don't think, no.

MS. BERNABEI: I have no other questions.

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lAttachmdnt 4

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.O And what,-if anything, did he do with th'c-information?

2 .A I think I remember him saying it' 1cchs like thera's 3

a hydrogen burn.

4 Q He said~this to you?

A Yes.

5 6 -Q M w, let me ask you a question about the alarm printout .

7 If someone with the proper experience such as yourself. nad 8 reviewed the alare printout on its oun, could he have or she g have determined that the containment sprays had been actuated?

- 10 A Yes.

ii -Q Anyone, in other words, with the proper background 12 could have understood that?

T 13 A Yes.

(

g4 Q Uow, to your knowledge,-had anyone lached at the alarm 15 printout. prior to the time you looked at it on I: arch 29th?

16 I'm talking about now .the alarm printout Scr that period of 37 1:50 p.m. or so on liarch 2Pth.

18 A I'd be speculating. I don't know.

ig Q You have nc knowledge?

7.

20 A NU*

21 Q It was certainly available to anyone who had access to i

22 the Unit Two Contro] P.com and had reason to look at it?

23 A- Yes. I'm not sure how available it uns. I may have 21 had to ask concbody for it.

25 C But it uas not something that would have not been i

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- GElGER & LOHA REPORTING aERVICC, INC 1000 MAPTET ST-.HBG. PA 17108 HBG. 234 2109 PA t.800 222 GLRS -

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Attachment 5 November to 1984

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Direct ceasing & Regulatory Affaire GPU Noelaar Corporationy;; . :. . .. .. m 100 Interpace Parkway Parsippany, Nof Jersey 07054-1149 I

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Dear Jack:

This morning I received a call from Mr. John Wilson of GPU Nuclear asking if I would respond to a question about the first day's activities after the THI-2 ac,cident. I agreed to 40 so. The question ad my response ars:

guestion:

Describe in as much detail as possible the substance of any discussions of hydrogen production which occurred during an afternoon meeting for discussion on March 29, 1579 at the THI-2 site which conmienced around 3:30 PM.

Resoonses.

T I believe the meeting referred to was the initial briefing on-site for senior B

tednical personnel sent from GPU, JCP&L, Met Ed and other sources to assist

> in assessing the plant conditions and. recovering the plant. The meeting was held in what I believe was a TMI-1 Suilding (office building at the north and of the plant structures) not in TMI-2 as suggested by the question.

As I recall, the subject of hydrogen production was not discussed or mentioned at that meeting. I distinctly resember seeing and discussing the containment pressure trace and the spike in the trace. The sesessment at that time was that it must have been a spurious in:trumentation probles. I resember discussing that, but do not recall at:y mention of hydrogen until later in the evening or early morning of March 30, 1979.

hry t ly yours,

, 1 y -- -- -

Thomas M. Crimmins, Jr.

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c C Attachment- 7 Resoonse to'THI-1 Alert's f '

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Fourth Sct of Interroaatories j Numbers M and 15 N

INTERROGATORY 14 Based on a review of the design documents, there appears ~to be no electrical-(or mechanical) malfur. tion that would cause both containment pressure-recorders, i.e.; BS-FR-1412 and BS-PR-4388, to indicate a pressure spike on the wide-range and narrow-range scales.

This conclusion is based only on a drawing review'. No physical inspection or investigation was made to verify that the drawings represent the configuration of the plant at the time of the accident. This review does not exclude the possibility of physical arrangements not apparent from the drawings which could have lead to the conditions describec in the-interrogatory.

The design documents indicate that:

(a) There are two (2) Reactor Building Pressure Recorders identified by~

tag numbers BS-PR-1412 and BS-PR-4388. Each recorder provides two measurement recordings, one for wide-range measurement (0 to 100 PSIG) and another for narrow-range measurement (-5 to 10 PSIG).. Each <

- measurement signal to the two recorders is originated by a different pressure sensing device (transmitter) than the other three s

measurements.

1 (b) The pcwer supplies tor each recorder's associated transmitters are energized from independent power sources, i.e.;

BS-PR-1412 is powered from Power Panel l'P2-31C which is fed from 480V Hotor Control Center 2-31C while BS-PR-4388 is powered from Powcr

! Panel 2-12R which is fed from 480V substation ESF Bus 2-12E.

(c) The instrument signal cables to each recorder, from transmitter to 1

control room, are physically routed in different cable trays.

(d) The wide-range and narrow range transaitter pairs, whose signals are recor;ed on the subject recorders, sense the containment pressure at physically separate locations, f.e.

BS-PR-1412 via penetration R-545A and BS-PR-4388 via penetration R-554C.

INTERROGATORY 15 Based upon a review of the design documents, there a; pears to be no electrical (or mechanical) malfunction which could lead to the simultaneous occurrence of the recording of a reactor building pressure spi b and the i

initiation of containment spray.

~ l' l

l.

ll r This conclusion is based only on a drawing review. No physical inspection (A or investigation was made to verify that the drawings represent the configuration of the niant at the tire of the accident. This review does not exclude the possiisility of physical arrangements not apparent from the uawings which could have lead to the conditions described in the interrogatory.

The design documents indicate that:

(a) There are redundant spray actuation channels which do not. electcically interface with the instrument circuitr" for that of the pres::uru recordars.

(b) The instrument signal cables for the spray actuation are physically routed in different conduits than those cables sssociated with the pressure recorders.

(c) The actuation of containment spray and the recording of reactor building pressure are implemented by diverse means, i.e.; pressure switches (see Table below) are used to actuate containment spray while p essure transmitters (see Table below) are used for recording. This re;, resents different measurement techniques and manufacturing designs for each occurrence.

, Pressure Switches BS-PS-3253 Train A Ch. 1 BS-PS-3254 Train A Ch. 2 BS-PS-3255 Train A Ch. 3 BS-PS-3256 Train B Ch. 1 BS-PS-3257 Train B Ch. 2 BS-PS-3258 Traia B Ch. 3 Pressure Transmitters BS-PT-1412-1 Recorder BS-PR-1412 flarrow Range BS-PT-1412-2 Recorder BS-PR-1412 Wide Range BS-PT-4388-1 Recorder BS-PR-4388 ilarrow Range BS-PT-4388-2 Recorder BS-PR-4388 Wide Range (d) Each redundant containment spray actuation channel is comprised of three pressure measuring sensors in a two-out-of-three voting logic.

Each sensor measures containment pressure at a physically different location from the remaining two. When at least two of the thr?e sensors are above the actuation point, then containment spray will be

ctuated on that ESF channel. Two of the three aforecentioned sensors ceasure reactor building pressure frca a phyrically different location j than that of either recorder measurement.

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.'ML g -Novmber 20, 1984

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f Y DE* - g. yy ua WIE EN OF MERICA 4 137 23 ND36 NUCLEAR REGUIATOIE C2 MISSION c f f., _# Oc dEGt ,

~

y. ? C ;p gll .b BEEDRE THE ATQ4IC SAFETI AND LICENSING BOARD SRA' 5'C In.the Matter of )

.)

METROPOLITAN EDISON CMPMPI

)

) Docket No. 50-289 SP (Three Mile Island Nuclear ) (Restart Nanagement Remand)

Station, Unit No. 1) )

CERTIFICATE OF SERVICE A copy of two stipulations, both entitled, " Stipulation of Mailgram Evidence", were served this 20th day of November, 1984, by hand delivery to the parties identified with an asterisk and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List. '

Respectfully sutmittec SHAW, PITIMAN, PCTITS & TROWBRIDGE '

N b Ernest L. Blake, Jr. , P.C.

Counsel for Licensee

. . i; '

UNITED STATES or AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter )

)

METROPOLITAN ED.TSON CCMPANY ) Occket No. 50-289 SP

) (Restart Remand on Management)

(Three Mile Island Nuclear )

Station, Cnit No. 1) )

l 1

\

SERVICE LIST Nunzio J. Palladino, Chairman

' U.S. Nuclear Regulatory Cc= mission Administrative Judge j Washington, D.C. John H. Buck 20555 l Acc= c Safety & Licensing Appea; j -

Thcmas M. Rc'c erts, Ccer.issioner Scard U.S. Nucles: Regulatorv Cce,=iss l U.S. Nuclear Regulatcry Commission Washincton, D.C. t Wasnington, D.C. 20555 ' 20555 i James K. Asselstine, Cc=missioner Administrative Judge l Christine N. Kohl U.S. Nuclear Regulatory Ccmmission

,da shington , D. C. 20555 Atomic Safety & Licensing Accea,'

Board

Frederick Bernthal, Commissioner U.S. Nuclear Regulatcrv Cer2.:.s s:.

U.S. Nuclear Regulatory Commission Washingeca, D.C. 20555 Washingten, D.C. 20555

• Administrative Judce Lando W. Zeck, Jr., commissioner .. T. van W. Smith, Chai.rman U.S. Nuclear Regulatory Commission Atomic Safety & Licens:.nq Scard Washington, D.C. 20555 U.S.

Washington, Nuclear Reculaterv Cc:~~ ss-^

D.C.' 20555

' Administrative Judge ,

Jary J. Edles, Chairman

• Administrativa Judge Atomic Safety & Licensing Appeal Shelden J. Wolfe scard Atomic Safetv & Licensinc 3 card U.S. Nuclear negulatery Cerr.ission U.S. Nuclear Regulaterv Cerr.:.ss .

Washington, D.C. 20555 Washington, D.C. 20555 t

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_ _ . _ _ _ _ _ _ _ - _ - - - - - - - - - - - - - - - - - - - - - - - - " - - - - - - ' - ~ - - - - - - - - ~

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• Administrative Judge Mr. Hanry D. Hukill Gustave A. Linenberger, Jr. Vice President

-lI Atomic Safety & Licensing Board GPU Nuclear Corporaticn '

( U.S. Nuclear Regulatory Commissicn P.O. Box 480 Washington, D.C. 20555 Middletcwn, PA 17057 Docketing and Service Section (3) l Office of the Secretary Mr. and Mrs. Norman Aamodt R.D. 5 i

U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C. 20535 Atomic Safety & Licensing Board

• Ms . Louise Bradforn Panel TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street Washington, D.C.

Harrisburg, PA 17102 20555 Atomic Safety & Licensing Appeal

• Joanne Doroshow, Esquire Board Panel The Cnristic Inst 1 tate U.S. Nuclear Regulatory Commission 1324 North Capitol Ctreet Washington , D. C. Washington, D.C. 20002 20555

• Lynne Bernabei. Esq.

• Jack R. Goldberg, Esq. (4) Government Accountability Office a:. the -xecutive Legal Projec.. -

Directer 1555 Connecticut Avenue -

U.S. Nuclear Regulatory Cc==ission Washington, D.C. 20036 Washingten, D.C. 20555

.- Ellyn R. Weiss, Esq. -

• Th0 mas Y. Au, Esq. Harmen, Weiss & Jordan 2001 S Street, N.W.,

s Office of Chief Ccunsel Suite 43.)

Cepart=ent of Environmental Wash ngton, D.C. 20003 Resources 505 Executive Heure Michael F. McBride, Esq.

P.O. Ecx 2357 LeSceuf, Lamb, Leiby & MacRae Harrisburg, PA 17120 13 3 3 New Hart.pshire Avenue , N.W.

+

Suite 1100 Washington, D.C. 20036' William T. Russell

Deputy Director, Division Michael W. Maupin, Esc.

of Human Factors Safety Hunten & Williams

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Of fice of NRA Mail Stop AR5200 707 East Main Street l

.i ~ P.O. Box 1535 '

U.S. Nuclesr Regulatory Richmond, VA 23212 Commission Washington, D.C. 20555 l

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