ML20126D394
| ML20126D394 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/01/1980 |
| From: | PENNSYLVANIA, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20126D389 | List: |
| References | |
| NUDOCS 8004290095 | |
| Download: ML20126D394 (141) | |
Text
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ed TUS PENNSU.NANIA FUBLIC UTI.LITY UOED:SS1011 i
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- In re:
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I-79070318 - Commission Im est13ation -into the
-, il Extended Cataget. of the ac:.wer 7ac.loy 1 da': lear Generating Station (Pennsylvanie Power 0;alany.-
Hearing.
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P-79040173 - Commission Trial Staff Petition to 1
. Il modify the not energy clauca of Duquosne Light l
Company.
Scaring.
J 5
P-79040174 - City of Pittsburgh arid Ma?i'.v Richard
- i S. Caliguiri Petitica to modify the not oncrgy clause of ruquecne Light Company.
Hearing li,
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Hv rieburg, Pennsylw.nio l
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,I MOFREACH & M!Jif'HAL,..:MC.
77 Morth Lockwi]ica t.;c.ite
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1 PUBLIC l'TILIT2' COMMISSION 2
COMMONWEALTH OF PENNSYLVANIA 3'
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4 I-79070314 Commission Investidation into the Extended Outages of the Beaver Valley 1 Nuclear Generating Station (Duquesne 3
Light Contpany. )
Hearing.
,I-79070318, Commission ' Investigation into the Extended Outa688 6
of the Beaver Valley 1 Nuclear Generating Station 7
(Pennsylvanin Powe'r Company. )
Hearing 0
P-79040173 Commission Trici Staff Petition.to modify the net energy clause of Duquesne Light Company.
Hearing g
P-79040174 City of Pittsburgh and Mayor Richard S. Caliguiri 10 Petition to modify the net energy clause of Duquesne Light t
Company.
Hearing
--ooo--
g O
Stenegre.ph1 e report of hearing held in g
Hearing Roca No. 2; North Office Building, Harristurg, Pennsylvania, g,
Tuesday g
April 1, 1980 at 10:00 o' clock a.m.
16
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HARRY G. BAN 7HOFI', ADMINISTRATIVE LAW JULGE
--oCo--
. APPEAHANCES:
20;-
'J THOMAS & THOMAS N.
P. O. Box 999,. Harrisburg, Pennsylvania 17108 1
By
~
22 L
CHARLES E. THOMAS, SR., ESQUIRE PATRICIA L. ARMSTRONG, ESQUIRE 23 For:
Duquesne Light Company f
4 Pennsylvania Power Comceny
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GREGG c. SAYRE, ESQUIRE p.
JOHN A. LEVIN, ESQUIR4 g
North Office Building, Harrisburg, Pennsylvania For:' Commission Trial Staff 3
IRWIN POPOWSKY, ESQUIRE 1425 Strawberry Square, Harrisburg, Pennsylvania 4
For:
Office of Consumer Advocate 5'
MARVIN A. FEIN, ESQUIRE 6
313 city-county Building Pittsburgh, Pennsylvania 15219 7
For:
City of Pittsburgh Mayor Richard S. Caliguiri 0
9 0
10, 11 12 0
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.I.NDEX TO WITNESSES I'N.D_UO,UES t!E DIRECT
.C..R.__OS S O
7 3 ); Clifford N. Dunn.
6 13 I
4!
5 INDEX TO STATEMENT i
6l Iy' DUQUESNE IDENTIFIED ADMITTED No. 1 - Document entitled Direct' Testimony S.
l of Clifford N. Dunn.
6 I
9i i
10 !
t El I INDEX TO EXHIBITS U
DUQUESNE 13,1 A
- Memorandum dated October 13, 1978 to O
J. A. Worling from J. J. Healy.
7 j,
,,,, ' B - Lettor dated Octobcr 27, 197,0 ho B.
"l H. Grier from J. A. Werling
-7 N;
C Lette.r with attachments dated December l,l 6, 1978 to B. P. Grier from J. A.
)
'l Worling T
l M I D - Lotter with attachments dated March m:
13, 1979 to c. H.
Dunn from
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Harold R. Denton 7
.0 i E - Letter with attachments dated March 37., 1979 to Harold R. Denton From Stanley G. Schaffer 7'
t U
i F - Lotter with attachmento dated August 8,1979 to C. N. Dunn from Harold.
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R. Denton 7
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IFDEX TO EXHIDITS (Continued D
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DUQUESNE IDENTIFIED ADMITTED 4
G - Letter with attachments dated January 3, 1980 to William F. Thierfelder from S
Charles E. Thomas 8
0 H - Letter with attachments dated February 8, l
1979 to C. N. Dunn from Boyce H. Grier 8
7 I - Graph entitled Estimated Cycle 1 S
Burn Schedule
'8
?
J - Document dated August 1,1978 entitled July 28,1978 - Beever Valley No. 1 10 Main Unit Transformer Failure 8
7.1 K - Doc.uments conciatin6 of diagrams and I
outage summary bar charts 8
12 10A - Docwnent entitled Responses to PUC 13 Trial Staff Interrogatotles.
11 14 f,.C_O_U. SUMER ADVOCATE 41 15' No. 1 - Photocopy of letter dated January 3, 1980 to Director of Nuc1 car Reactor 1
- i6 Regulation from J. J. Carey 41 l'i 13 i
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0 THE AD11NISTRATIVE LAW JUDGE:
This is the time 1
p J.
2 set for the initial evidentiary hearing with respect to four 3
dhekets, which I understand the parties have agreed to 4
consolidate for hearing purposes.
The initial one is 5
I-79070314, Investigation upon the. commission's own motion 6
into the extended outage of the Beaver Valley 1 Nuclear.
7 cenerating Station as it relates to Duquesne Light Company; i
8 Docket I-79070318, the Investigation on the Commission's own 9
mo, tion into the extended outage at Beaver Valley 1 Nuclear 10 Generating Station that relates to Fennsylvania Power 11 Company.; P-79040173, the petition of the Commission Trial 12 < Staff to modify the net energy clause of Duquesne Light, O
13 and P-79040174, the petition of the City of-Pittsburgh and l
14
! liayor Richard S. Caliguiri to modi {y the net energy clause 15 of Duquesne Light.
16 Do any counsel present wish to make an opening,
17 statement with respect to this matter 7 ig (No response.)
19 THE ADiiINISTRATIVE LAW JUDGE:
Commission 20 Trial Staff?
21 MR. SAYRE:
No, your Honor.
f 2/. !
THE AD11INISTRATIVE LAW JUDGE:
Mr. Thomas?
23 MR. THOMAS:
We have no statement.
O 24 THE ADifINISTRATIVE LAU' JIT03E:
It is rey 25
. understanding that Mr. Thomas and Mr.. Levin.were going to t a'.tt!".t?Ac** a Wi*t;;AL. *20. = lt1 N. I.OCrX"LLCW A*r". = ttT.'?'UCU":Ct. P.% 5 "11;1 z
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g reach.some understanding with respect to precentation of 2,
witnesses at this set of hearings.
g MR. THOMAS:
We have testimony to Dresent at 4
your direction and that testimony has been served.
5 THE ADMINISTRATIVE IAW JUDGE:
I see you have 6
Mr. Dunn here.
7 MR. THOMAS:
We have.
8 THE ADMINISTRATIVE IAW JUDGE:
He is now 9
available?
MR. THOMAS:
Before I put Mr. Dunn on the 10 [
17, stand, you directed that each party file a statement of the 12 issues as they perceive the issues and we tere to file a O
13 reply to those statenients of issues by March 21.
That'has 14 been don?.
JS I'm going to put Mr. Dunn on the stand because 1(j you directed or requested that we do so..
We reserve the 17 right to call.other witnesses and request an opportunity for 73 such time as required once the issues are resolved or i
19 determined in the proceeding.
1 30 Some of the material that is in Mr. Dunn's 21 testimony pertains to outages at Beaver Valley prior to 23 March 9,.1979 We do not believe the commission's 23 investigation goes to outages prior to March 9 We believe gy the issues are restricted to the outage of March 9 arid' the 25 current outage.
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We have agreed to provide. evidence on outages 2
prior to March 9.at the request of the Consumer Advocate and 3
subject to our right to object to relevancy.
4 I do not want to be bound by.the rules that 5
decause I put that evidence in then I am bo.und by that 6
evidence.
We are submitting it only in an effort to cooperate 7
and we will object to relevancy at a later time.
Mr. Dunn.
i
.8 9
CLIFFORD N. DUNN, called as sa witness on i
10 behalf of Duquesne Light Company, having been duly sworn 11 according to law, was examined and testified as follows:
12 O
13 DIRECT EXAMINATION 14 MR. THOMAS:
If your Honor pleases, I ask 2
15 that there be marked for identification c. statement of direct 16 testimony of Duquesne Light Company as Duquesne Statement 17 No. 1.
It is the direct testimony of C. N. Dunn in this 10 proceeding and the other two dockets to which you referred.
19; THE ADMINISTRATIVE IAW JUDGb:Granted.
20 21 (Duquesne Statement No. 1, document entitled Direct Testimony of Clifford 22 N. Dunn, was produced and marked for identification.)
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r 24 25]
MR. THOMAS:
I also request there be marked b
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for identification Duquesne Exhibits A through K attached to D
2 Duquesne Statement No. 1.
3 THE ADiINISTRATIVE LAW JUDGE:
Granted.
4 5
(Duquesne Exhibit A, nhotoccoy of memorandum dated October 13, 1978 6
to J. A. Werling from J. J..Healy was produced and marked for...
7 identification.
8 Duquesne Exhibit B, chotocony of letter dated October 27, 1978 to.
9 Mr. B. H. Grier from J. A. Herling was produced and marked for 10 identification.
11 Duquesne Exhibit C, chotocony of letter with attachments dated 12 December 6, 1978 to Mr. B. H. Grier (as from J. A. Werling was nroduced 13 and marked for identification.
14 Duquesne Exhibit D,,chotocony of letter with attachments dated 15 Msrch 13, 1979 to Mr. C. N. Dunn-from Harold R. Denton was nroduced 16 and marked for identification.
17 Duquesne Exhibit E, nhotocony of letter wi th attachments dnted 10 March 31, 1979 to Harold R. Denton from Stanley G. Schaffer was-19 nroduced and marked for identification.
20 Duquesne Exhibit F, chotocony of.
21 letter with attachments dated August 8, 1979 to Mr. C. N. Dunn 22' from Harold R. Denton was oroduced and marked 'for identification.
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Duquesne Exhibit G, chotocony of I
letter with attachments dated 2
January 3, 1980 to William P.
Thierfelder from Charles E.
3 Thomas was oroduced and marked for identification.
4 Duquesne Exhibit H, chotocony of I
letter with attachments dated February 8, 1979 to C. N. Dunn 0
from Boyce H. Grier was oroduced and marked for identification.
7 Duquesne Exhibit I, graoh entitled 0
Estimated Cycle 1 Burn Schedule was oroduced and marked for E
identification.
10 Duquesne Exhibit J, photoccoy of, document dated August 1,1978 11 entitled July 28, 1978 - Beaver Valley No.1 Main Unit Transformer 12-Failure was oroduced and marked
("5 for identification.
o lo.
Duquesne Exhibit K, thotocony of 4
documents consisting of diagrams and outage summary barcharts was 15 oroduced and marked for identification.)
17 10 BY MR. THOMAS:
19 Q
Mr. Dunn, I show you a Statement of Frenared 20 Testimony which has been marked for identifi. cation ~as 21 Duquesne Statement No.1 and a'sk if this is the testimony 27, which you creoared for the ourcose of this nroceeding.
2Ti A
It is.
2(
Q Do you have any corrections to make at this 25 time in that testimony? -
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A No.
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Q If. I were to ask you the questions contained g
3 in Duquesne Statement No. 1, would you give.the an.swered contained therein?
A Y'8:
5 g
Q Are those answers true and correct to the best
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7 of your knowledge, information and belief?
g A
Yes.
i 9
MR. THOMAS:
If your Honor cleases, I offer 10 in evidence Duquesne Statement No. 1, subjec,t to the right of 1
77 Duquesne Light Comoany to object to relevancy as to outages 12 prior to March 9, 1979 i
O 13 THE AEMINISTRATIVE IAW JUDGES Any objection?
yg MR. POF0WSKY:
No, your Honor.
3 THE ADMINISTRATIVE LAW JUDGE:. Admitted, g
MR. SAYRE:
Does that also apply to the c:chibits?
77 g
MR. THOMAS:
I will get to.those in just a gg moment.
20 BY MR. THOMAS:
77 Q
.Mr. 'Dunn, I direct your attention to Duquesne Exhibits A through K attached to your testimony and ask if 33 those exhibits were prepared by you or under-your suoer vision f
,q a.nd direction, or were communice.tions and bulletins received g by Duquesne Light Company in respect to Beaver Valley No.1-ei -
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2 Power Station and the outages of Mar.ch 9, 1979 and in some O
2 instances outages prior to that date?
I A
These exhibits are basically. copies of certain 3
4 documents in my files which in one way or another support my 5
direct testimony.
In some cases they are correspondence' 6
within the cor.pany, and in some cases they are correspondence 7
between NRC and Duquesne Light Company, or vfrom Duquesne 8-Light Company back to the NRC.
Various corresoondence of that 9
nature.
10 Q.
Do I understand that these exhibits are 11 necessary for an understanding of your testimony?
12 A
Yes, and I refer to these exhibits at 13 appropriate points in my testimony.
14 Q
They are materials which were in the files of 15 Duquesne Light company?
16 A
Yes.
17 MR. THOMAS:
If your Honor pleases, l
10 consistent with past practice I am not going-to offer 19 Cuquesne Exhibits A through K at this time,r There is 20 information in Exhibits A through K, and'some of the exhibits, 21 which pertains to outages other than the. outages of Harch 9 22 and November'30.
At that time I may, when I offer them, 2S object to relevancy as to the outages priorato that time.
I D
24 I ask that there be marked for identification 25 as Duquesne Exhibit 10A responses to the PUC Trial Staff-nmmacn c. nw.nc., me. -a n. s.acanu.ow w.:..- nm.wa. v m n - --
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interrogatories dated August. 20, 1979.
May it be so g
ide ntified?
?
3 THE AININISTRATIVE IAW JUDGES. Granted.
4 g ;
(Duquesne Exhibit No. 10A, bound.
volume entitled Responses to.PUC g
Trial Staff Interrogatories dated August 20, 1979, was produced and 7
marked for identification.)
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BY MR. THOMAS:
10:
Q Mr. Dunn, I show you what has-been marked for g identificatien as Duques.ne Light Company Exhibit No. 10A and 12 ask if the responses to the Commission Trial-Staff I
O 13 interrogatories dated August 20, 1979 contained therein were
~
14 prepared by you or under your supervision and direction?
15 A
Yes, they were.
16 Q
Are you responsible for those responses?
grj A
Yes, I am.,
gg Q
'Are the responses.true and correct to the best gg. of your knowledge, information and belief?
l 20 A
They are.
l gg MR.. THOMAS :
We ask. that today's date, of 22 identification be inserted on the Duquesne Staternent of Direct l
23. Testimony No.1 and on the exhibits by the reporter, b
24-1THE ADMINISTRATIVE LAW JUDGE:
Granted.
25 MR. THOMAS:
Copies of Duquesne Statement No. 1 r.:: memen a tanswa me. - ar st. f.ocnent.:.ow err:. - m2mico:::tc. en, m:n
12 g
and Exhibito A through K have been served upon the C'
2 Administrative Law Judge and all counsel of record.
Duquesne 3
Exhibit No. 10A, which contains the responses to Trial Staff 4 iinterrogatories dated August 20, 1979, were served several I
3 months ago upon the Administrative Law Judge.,and cou'nsel for 6
the various parties.
7 The witness is available for cross examination.
i 8
MR. SAYRE:
Your Honor, because Mr. Levin 9
cannot be here today but will be here tomorrow,'we would 10 prefer the Consumer Advocate to cross examine first.
1,1 THE ADMINISTRATIVE LAW JUDGE:. That is
(
12 satisfactory.
I 13 MR. POPOWSKY:
Thank you, your Honor.
14 Mr. Thomas, can I initially point out there are also four 15 tables attached to Mr. Dunn's testimony, uhich I just thought 16, perhaps.you would want to identify and verify while he is on 17 the stand.
18 MR. THOMAS:
I treat those tables as a part 19
- of the tastimony and had not intended to identify them as an 20 exhibit.
I will if you --
t 21 MR..POPOWSKY:
No, as long as it is clear 23 that is part of what has, be.en identified.
?al MR.. THOMAS:
All right, let me ask a couple
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questions..
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BY MR. THOMAS:
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Q Mr. Dunn, are there certain tables attached 3
- to your Statement of Direct Testimony, Duquesne Statement No. 17 4
A Yes, there are four tables.
g g
Q Are they an integral part of-the testimony 7
and referred to in your testimony?
g A
Yes, they are.
i 9
MR. THOMAS:
Thank you, j
MR. POPOWSKY:
Thank you.
J.0 4
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11
)
12 CROSS EXAMINATION I
f,3 BY MR. POPOWSKY:'
y Q
Good morning, Mr. Dunn.
fl g
A Good morning..
16 Q
My name is Irwin Popowsky.
I.am an Assistant p_
17 Consumer Advocate.
Could you tell me approximately when gg Beaver Valley was granted its construction permit?
gg A
I would be making a very approximate es.timate.
i I don't know procisely.
It would have been early 1970's, y
20 '
1 21' maybe 1970, 1971,. somewhere in that time per.iod.
b p
Q Approximately when did Beaven Valley raceive
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- g. its operating license?
b 2.1 A
It would have received its overating license I
l 25 on the. day, very close to the day.it initially loaded the
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g fuel which would have been in early 1976.
p, Q
During the period between those approximate 3
dates, who was responsible for insuring the technical 4
adequacy of the design and construction of Beaver Valley 5
Unit No. 17 0
A Duquesne Light Company.
7 Q
what was the role of Stone & webster in
,8 insuring that technical adequacy as architect /enginecr?
9, MR. THOMAS:
If your Honor pleases, we object 1(L, to this line of cross examination on the grounds that it goes 11 to material prior to the outages of March 9r 1979 and 12 Noveraber 30, 1979.
D ul MR. Por0WSKY:
Your Honor, the outage of March 1979, as I understand it, was a response by the Nuclear 14L 15 Regulatory commission to certain design techniques that were 161 utilized during the initial design and construction of the 17 plant.
I think we have to analyze those.
10 THE ADMINISTRATIVE IAW JUEGE:
The' objection 19-is overruled.
20, MR. F0F0WSKY:
Thank you.
21 THE WITNESS:
Would you repeat the question?
1 22' BY MR. P0F0WSKY:
23{
Q
,could.you tell me what was the role'in the O
24{ process ue described,,that is the process of insuring the 25 technicci adequacy of the design and conctruction of remnr.e o www n.-c: n.i.cesem..m e s.- nem::r:n. n rnin
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g Beaver Valley, what was the role in that process of Stone &
O g
Webster Corporation?
A' Let's go back to 1971-74 which is the period g
4 we are talking about.
+
5 First of all, the responsibility for the g.
construction of that plant would have been vested not in me ej but in the Vice' President of Engineering and-Construction for
.a Duquesne Light Company.
p I, personally, although I was involved, had no 10 direct participation in terms of overseeing the design or the 11 work of Stone & Webster,in general.
g
.I. can only answer your questions in the. context O
13.
of.that type of background, that is, having,no direct i
1 1<}
responsibility, and my involvement is primary from the 15 standpoint of taking that plan, once it is constructed, into 16 its operating phase.
77:
The best answer I can give you is that Stone
.g & Webster was retained by Duquesne Li$ht Company as the y[ architect / engineer with the prime responsibility for the 7,g design atid the construction of that project..
7,7 Of course, along.with those responsibilities p
would.be adequate professional people who were technically 23g qualified to do the design and the. engineering work, O
g THE ' ADMINISTRATIVE LAW JUDGE:
Off the record 2.c for a motent.
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. (Discussion off the record. )
2 BY MR. THOMAS:
3 Q
Mr..Dunn, according to.your direct testimony 4
you are the Vice-President of Operations of Duquesne Light 5
Company?.
g u A
'That is correct.
7, Q
Vnen did you have r'esponsibility for Beaver 3
Valley No.1 in respect to operations?
On what date, if you p, recall?
10' A
There is no specific date.
respon-n sibilities bsgan toward the latter stage ofcconstruction' n
where you begin to put together an operating organization, O
D you begin to write your procedures, you do your training, 14 ' and essentially get ready for that, point'in-time,where a g.. nystem in the plant is now constructed from the standpoint i
16 that everything is ready to go, and 'then the. operating I
y' department must take over that system, test.it, and assure gg
. itself that, yes, indeed, tha system is constructed as it is y
supposed to have been fro:n the standpoint of the physical 7,9 hardware,, in other words,' all the pipes are in,, all the s
3 21 valves are in, all the hardware is in, so tor speak.
From there it is a gradual increase in 73 responsibility as more'and more systems are transferred frort O
g,l a construction _ type rssponsibility to an coerating type
.t 33! retponsibility'.
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I gl The net result is that at tha time we receive 2
our operating license, the plant has demonstrated through l
3 this start-up test program that it is indeed-ready for 4
operation and the people are ready for operations.
1 5
Q when was this plant synchronized?
I recall 6
May --
f, 7
A May 30 or 31st 1976.
a Q
You would be responsible at that point?
p A
I would assume complete responsibility from 10 t.ie standpoint of operations, but as is usual in the case 11 with any power plant, be it nuclear or fossil., construction 11L is not necessarily one hundred percent complete at the point 3
p 13llof time when you initially synchronize because you normally lI 14 still ha're a period, depending upon the unit, of anywhere 15' from three to six months where you essentially put the plant 16.through a test program involving' power type operttions, which
- 37) is another step toward ultimate commercial operations.
6 73{
q Are you responsible for those power type 19 operations?
l F
A Yes, I am.
20 t
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31; Q
Then is it reasonable to say that at least
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22i from May 30 or 31 1976 when the plant was cynchronized, frem f.-J L
33j that._ point on you were'recponsible for the operation of the i
O 2
plant?
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)
I 25?
A
- Yes, b
uumcn a ~emaw., ::w. -rn. s.c=mm.1.n x:n. ~ :<mmmr.c. er amn I
r
..,--.w,.-,
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18 g
MR. THOMAS:
Thank you.
2 BY MR. POPOWSKY:
3 Q
Then perhaps we could just go back and clarify 4
a matter that was raised off the record, if I could restate 5
this -- correct me if I am wrong -- Duquesne Light Company 6
maintained the ultimate responsibility for the technical 7
adequacy of the design and c.onstruction.of the plant?
8 A
We are the company who has the operating 9
license.
There is no way you can divorce yourscir from that 10 responsibility at least in the eyes of NRC and within the eyes 11 of the company.
It is our responsibility.
We have the 12 operating; license.
O U
Q You mentioned anothe:c officer who may have 14 also had familiarity with the events that transoired before 15 the operating license was granted.
Could you tell me the 16 name of that officer?
L l'j A
Mr. Earl Woolever.
He is Vice President of 10 Engineering Construction'.
19 Q
That is his current position with Duquesne?
20' A
Yes, it is.
21 Q
Getting back to your own knowledge of those i
gg events -
33 A
Which events?
O
'2 Q
I am-sorry, the evente that tranacired prior 25!- to 1976, could you tell me who was responcible for the I-nomemi o i :mm me.- n n. secree:u.ew nm. - :vm:::a:me, r.? m:-
.-m--
- ,**w+ve
--,-=w.ree"*
- 'wes. "
e**'*.""^'
"'"' i "Y '
^]'"*".""""~
I 1o g
seismic analysis of piping at Beaver Valley Unit 17 2
A Danica11y the calculations were made by 3
Stone & Webster.
Of course, we have the overall 4 responsibility of reviewing thein either on a-, total basis -or 5 on some statistical basis.
I'm not sure exactly what was 6 done at that period in time.
7 Q
Who at Duquesne would have been responsible for
,8 auditing the precedures used by Stone & Webster in the 9 seismie calculations?
10 A
It would fall under the general responsibility 1
11 of Mr. Woolever.
Who, specifically in his organization, I do 12 not know.
There could be one of two, either-our Manager of D
13 Quality Assurance or an Audit committee formed by the various 14 Engineering Departments, one of the two, most likely, but 15 there may.be other organizations could have performed such 16 audits.
17 i Q
Was there a formal review process as to this i
18 specific area that you know of?
4 19 A
I don't know.
q 20 Q
Do you know whether' anyone ate Duquesne Light i
21 Company v.ttempted to verify the methods that Stone & Webster I
22 used to calculate seismic stress?
23.
A I* don't know.
1 O
24j Q
In reviewing the seismic stress analysis do you 25l know whether Duquesne employed a particular safety factor such I
r:e:r cr.=n ecc.nem.s m:. - e7 N.1.0c2W8..OW 40m. = UA:Zm:n#:Ce P". W1*".
m.
,,...m-..-
~.- ymw,
- 7. v -.
.- nN_. v e-em
,r "J+-~
- -*7WJwS77"'--
20 i
y as 15 times allowable stress, two times allowable stress?
Do 2
you know if a general cafety factor such as that was used?
3 A
I don't know what safety factor in the context 4
you have phrased in your questions may have-been used in the 5
calculation.
I do have general knowledge from the standpoint 6
of what the NRC does in their various regulatory requirements 7
in terms of conservative type calculations as a policy.
6 Whether the conservatism'is in safety factors 9
such as you have enumerated or whether the conservatism takes 10 other forms in assumptions used or things of this. nature, I 11 do not know.
12 But I do know that the calculations as a 13 I general rule which are made to support a nuclear plant do have if a high degree of conservatism in them.
15 Q
can you tell me why the seismic stress analysis 16 is so important?
Perhaps that is an obvious question, but it 3,7 has played an important role in these proceedings.
Could you Ig describe why that is?
79 A
Again, you have to go through the evolution of 2d: regulatory requirements as they affect nuclear uower plants.
21 Considerr>,1on of earthquakes became a part o.f this 22f regu'atory. process and I do not know at what. point in time, t
?' E but at the time Beaver Valley wea being designed. there were -
2(
requirements which were imposed upon the architect / engineer, 2h{if you will, as well tis the. operating company, to consider r.:mmeren e rnunv mn - n u. t.ocran.:.w en:. ~ nrzw.wsnc, rn. rma
_,. e% s ee.
- 7 e
.Y--
p.
~*
- y9 1d**e* Nas-W* rv e f *-
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voy
21 g
how that plant would respond in terms of an earthquake of.a-2 given intensity, so to speak.
3
- So you had to take into consF;eration in terms 4
of design and construction of what they call, Category One and 5
Systems, the effects of an earthquake'on pipes, on valves, 6
on hardware in general.
7 Q
Are those safety related systems?
8 A
Category One are safety related systems, yes.
i 9
Q What is the danger that the NRC is trying to 10 prevent there?
11 A
What they are trying to prevent is the 12 failure '-- and failure does not necessarily mean break -- the-O 13 failure of the component to perform its safety. function.
14 Q
Such as cooling?
Well, such as what?
]
15 A
Such as instruments not working, flows being 1
1 16p interrupted, valves not operating, controls,-not operating, h
17 pipes coming off the wall.
L?
Q In a scismic analysis is_that analysis JS nite specific, to your knowledge?
Do you consider the i
20 particular seismic problems in the area where the plant is 2?,
built?
a 17.
A It is now.
I' don't know what.it was at the 25 timo the calculations were made, which would have been seme-O 2(
time prior to.1974, at least initially.
25 MR. THOMAS:
I wonder if I could ' have - the rmm:r.=s n:awm: snc.~ wr u. tocam.tx.w::. - umnmu=n, n. nnn
.-.-..,,e-.
y, c,.m..,,,,,,
.yy g,3
22 l
~
g question read back..
1 2:
(Question read.)
3' MR. THOMAS:
Thank you..
4 BY MR. POPOWSKY:
5 [
Q Returning to the analysis done at. Beaver 6
Valley 1 -- and could we turn to your Exhibit C, and also 7-your testimony at page 4 -- first ' f all, could you inform o
8 me who is the author of the attachments to. Exhibit C?
There i
9 is a letter signed by Mr. Werling and attached to that is a 10 Licensee Event Report and an attachment to that report.
Were 11 those also written by Mr. Werling, to your knowledge?
i 12 A
The letter is signed by Mr. Werling.
I can O
13 only asnume he wrote it..
The attachment in terms of LER lt would have been prepared probably py some member of 15 p Mr. Wer11ng's staff.
16
.The attachment itself would have been prepared y'l by Mr. Werling based upon information supplied to him by 10 Stono a '!ebster plus whatever other information and JS
,. evaluation he or members of his staff would have made.
20 4
In your. test many at page 4 you refer to this 21 report as stating that in 1974 two.,of. the six. safety 22 injection lines were coded into a computer code called 23 PSTRESS Shock II which, according to.the report,iwas an 2,}f acceptabla. technique.at that time and was the-basis for all 23l t computerized Category I pipe stress analysis calculations.
I
. t:cmmacn ta reAnszw my:. - er n t.octovitt.ow Aam. - w,=tsmnitty, PA. 37312
,m.
,y 7
,9 g.
y 7
77 c
..g,
23-y Do you believe.that PSTRESS Shocl: II was an D
2 acceptable technique for measuring seismic, stress at that time?
And I presume you mean 1974.
3 4
A That is my understanding.
It is Stone &
5 Webster's' evaluation,,it is their posi, tion..
6 Q
That is your understanding of Stone & Webster's 7 Position?
,8 A
That. is right.
9
.Q Do you have any view to the. contrary?
10 A
I have no reason to disbelieve it at this 11 point in time.
12 Q
When you say this was an acceptable technique, O
D
. acceptable to whom?
i 14 A
Acceptable generally to the industry and 15 acceptable to the NRC at that particular point in time.
That-16
- is my understanding.
17 Q
Do you know whether the NRC ever specifically y
approved that technique?
1p A
I don't know whether.they specifically approved 7D that technique.
It is my understanding they have allowed 21 other plants to.come. into ' operation.who essentially use the 22 same type of a computer program.
33 It is my understanding that there' were O
2,g somewhere 20 to s 22 plants who.were ' designed either,tti bh that 29' snecific program or_ programs which had.the'same tyre of' netn:r.newx.mm :xa. a n. u=ms.cw.vm.-:macw.n. n. m:n -
.,7.
,- y.
7.,- y gy m,.,7 s y,.ge--y
1,.
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subroutino in them which come under, shall we say, 2,
controversy as a result of the show cause order, f'
3 It is my understanding that this was an,
t 4
acceptable technique at.the time and there were come 20 to.22 g
other plants which were operating in addition to the five 6
which were shut'down which were designed with the same type I
7 of a program, same or similar.,
S Q
With reference to that show cause order which i
I 91 is your Exhibit D, does not that show cause. order r-tate that 10 this treatment -- and I am referring to page 2 of t.se show 11l cause order which is Exhibit D -- does that-not state that i
12 "this incorrect treatment of such loads was~ not recognized O
13 at that time"?
14 A
I am not sure as to, what time se are referring IS' to.
Perhaps you' can help me.
'(6 Q
Well, at the beginning of that paragraph it
- 7 refers to a meeting which states that. differences between two gg computer codes -- that is the one that was being used to 19 verify the. technique and dhe one that was used at the time, 20p I'm just trying to find out what that time was -- it says 1
[
21 is attributable to the fact that the piping analysis code r
l 2.2 specified in the application for an operating license uses
]
7J an algebraic summation.nf~1oads predicted separately.by the
-24 computer code.
25 Then'it says:
'thisLincorrech treatment of.
t-d-
nen.sen a numns ne.-e n. t.oaan.:.ew av::.- twerxin6. m. tys t:
1
-n
- sq,;wyny
>my
.. ~
y*~
3;?
-3 3r,
" qy~s y p,
ym;-
yy-
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25 11 t
1 such loads was not recognized'at that time.?
2 A
The time then is.the. time we-got our operating 3
license which would have been 1976, yet the. codes we are
.g.
talking about, the computer's technology at-that particular 5
time is 1974.
They may have been not recognized in 1976 and 6 I thiiik that is a correct statement.
e 7
But what we are talking about, is not what was
.B applicable when we got our operating license but what were the 9
applicable codes when the plant was designed,and built.
10 Now you are talking about codes and the state 11' of the art, if you will, which existed in 1974 or earlier.
1 12 Q
When was the application forman operating O
D license made?
1 A.
I don' b know precisely.
Sometime shortly
)
i M
before we received the license, but I don't -know.
l 16 Q
Do you know whether the NRC has ever' changed 17 its position as to whether that code uns acceptable at any 10 time?
E A
Which code?
20 l Q
The FSTRESS. Shock II.
1 21 A
It is.tay understanding that it was,an 27, acceptable code, at least prior to 1974, since there,were DL 22.opere. ting plants which were designed either using that i.:
p 2<}
code or one of a very similar nature.
p 21 Q
Can you,, Mr. Dunn, provide us with.ai b
uc:::=ncu c, um:xt... rr::. -a s..ce: re:u.evi e.m -: rsexe, : r-wnn ----
l-
, y.n
..H ;
/.
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- . _,,.,. 7
,y, y,
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4
..%..,,y 4,,,
26
}
k g! chronology of how the seismic analysis on Beaver Valley was C
l 2
performed?
For example, in this Exhibit C there is a 3
reference to certain hand calculations that were done in the 4
original design and then a review in 1974 utilizing a computer 3
code.
6 Do you know exactly when those events occurred 7:
or if that is a proper chronology?
,8 A
I don't know what I could give you in the way 9
of response to chronology.
In doing your design work you use 10 both computer codes reflecting the current state of the art 3
11 at the time you are doing the design, including any 12 consideration for regulatory requirements in terms of those O
13 codes, and you also use simplified methods, chart methods, 14 for simpler type, static type configurations.
15 If you are going to put a piece of pipe on a 16 wall, it is so long, so thick, such and such a weight, and 1
17 you can go to a chart, it is a straight line of pipe, and 1G find out exactly what supports you need or what considerations:
19 'you have to make from the standpoint of seismic ~ design.
r 20i It ic a technique used by engineers for simple l'
21 type problems.
gg',
Q Do you know whether the original design of the 23l.piping at Beaver Valley 1 was done using a combination of j
I l
p 2d hand calculations and computer code or was the origiret 33f design done just by hand calculations?
t rtosemnen a mn::n;.L. m::.-::: it t.oensten rt::. -nrn.r = unn, m, c.ns..
]
i
27 A
It is iny understanding it was done using both, g
1 2
depending upon the size of the pipe.
3:
Q Do you when this 'particular computer codei 4
PSTRESS Shock II, was first used on Beaver Valley Unit 17 y-A I don't know when it was first used.
Based on
~
6 information in my testimony I believe there was an indication 7
it was used about 1974.
I refer specifically to Exhibit C,
, 13 the Attachment to the LER, Item 3 9
Q And that states?
10 A
I am reading into the body of Item No. 3:
1 g1 while the review was, continuing, Duquesns ght Company i
yy, reported the initial findings to the NRC on October 27, 1978.
r 13 During the evaluation, it was determined that these safety P
if injection lines were subjected to en as-built review in 1974 15 and, at that time, two of the six lines were coded into PSTRESS.
That is PSTRESS Shock II.
16 37 So there is one indication it was used as in early as 1974 during the coarse of a review of the as-built 7,9 conditions.
f gg Q
Did Stone & Webster inform Duquesne Light 31 Company that it had developed a new method of seismic stress 22 calculations as early as'1972 and that this new method did t5 73 not use the' algebraic summation technique?
24 A
I do not know.
I was not involved in the 25 seismic cenign of Beaver' Valley No.1 unit.
1 i
- e.:r.e :.w m.-a.u :: e.-::7 n. wemm.:.w me.- nr.:r =m 3. m. m:=
.. ~
~ rr -
3.-.,,,,.--.7.,,
1
2B y-Q Have you since learned that to be the case?
r 2
A I have asked no such question.
3
. Q Whether or not you asked.the question, have 1
4 you learned of that fact from any source?
5 A
No.
6 Q
There is some reference in the exhibito to a 7
pipe stre.cs Shock III Method, which I believe was used during
,8 the reanalysis of the seismic piping problem.
Do you know 9
who developed the pipe stress Shock III Method?
10 A
I don't know for sure.
I can only assume 11 Stone & Uebster but I.~ don't know for sure.
12 Q
Do you know when that method was developed?
O 13 A
Not offhand, no.
14;l Q
Do you know whetherithe pipe stress Shock III 15l Method is considered acceptable today by the NRC?
16 A
It is.
l'[
Q Why is it considered acceptable?
ggj A
Because the difference between PSTRESS, and I
19 the difference between the code identified as PSTRESS Shock pf)j II and PSTRESS Shock III is the fact that PdTRESS Shock III, t
21l uses the square root method of summing the forces as opposed I
pyy to using a straight algebraic: summation technique, j
?g A
Is it your understanding that if the oicing D
2.}
cnalysis at Beaver. Valley had been done using PSTRESS Shoch III rather than PSTRESS Shoch II, that there would not have 7.5 N
r=:s cn a :msm.:.. : re. -er n. :.cc wr.um e - w=mune, n, m en -
J 8
e n.1
~
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29 I
g been an NRC shutdown order?.
~
2' A
Your question presumes that PSTRESS Shock III 3
was a code available at the time Beayer Valley was desigiled 4
and I don't know whether that! is a fact or not.
But as a 3
hypothetical question, if PSTRESS Shock III-had been used in 6
the design of Beaver Valley initially, then, yes, it would 7
have been an acceptable technique 'today.
a But that does not say that PSTRESS Shock II, 1
9 which. is the computer program used during the design, was not 10.
acceptable at the time the design was made.-
11 It is my understanding that it was an 12 acceptable technique and had been used on a number of p
13 different nuclear operating clants, not only plants designed 14-by Stone & Webster but plants designed by other architect /
15
. engineers who are in the business.
1G ;
Q Do you know whether that technique was used
,trj to the same extent in plants other than the five Stone &
16 Webster plants?
A JS I have no idea to what extent any pro 6 ram may 20 have been used in the design of 22 other plants.
21 Q
Perhaps it would be helpful if we could,just 22 run through an example for _ the record of th'e difference l
g.i between the algebraic summation method and methods which D
gji might now be termed acceptable.
Can I give you'the examole, l
23l then, of two stresses in opposite directions, let's.eay p
nw u.: n n.we..v. :e. - n n. tec:mterr arx.- n n men, : s men -
p w -.
---,,g.e-
. nm ~ ~ ~
~
~r, y
p ;apmy, y-
?.m, ~ w y~., -
0 9
4 J
30 l
1' i
1 north and south, one sith a force of 4 and one with a force of p
t 2
3.
Am I correct that if those forces were in opposite j
3 directions, that one would be assigned a negative value and l
s}
one would be assigned a positive value?
5 MR. THOMAS:
I object to the question, your i
6 Honor.
I don't see how the detail of the math calculation 7: reall.y adds anthing to this procee'ing.
There is a PSTRESS d
8
. Shock II which was used and which we have information 1
1 9
indicate-s was acceptable at the time, and there 'is a PSTRESS 10
.. Shock III which is a later code.
11 Now when you get into these codes they become 17 so technical, I don't know what advantage they are.
O 13 MR. FOPOWSKY:
I think we can use a simple 14 exauple Just to say the difference,betweenr what is ruant by 15 algebraic summation, what is meant by absolute sum, what is L
16 meant by square root of the sum of the squares, if we could i
17 just run through a mathematical example, a simple one, 18
- without IP i
MR. THOIMS:
What does it;, do for thin e
20j proceedi.9g?
How does it help the Judge?
?
21 MR. P020WSKY:
What we are talking about here 22fis a shutdown for five and a half months in which the reason i
23i given for the shutdown was that the seismic en lysis was done O
pf}
using an algebraic summation method.
According to the show 25 cause order that was not a proper method; the procer methods
- mern=n m exwnt r:c.-a n. :.ccreew.r um. - r=xmm w mm
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,,,,,.,,y y.
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~
are either absolute sum or square root of the sum of the g
2 squares.
3-I thought if we could,just have a simple 4
mathematical example on the record it would,be helpful.
1 5
MR. THOMAS:
I am not sure that the show cause 6'
order says that was not'a proper method.-
That show cause 7' order will speak for itself.
.O But my point is I don't think the Judge is a 9
mathematical expert that is required for these codes and I 10 don't know what good it is going to be for the record to put 11[ it in.
I think it is a. waste of time.
12 THE AIHINISTRATIVE IAW JUIXiE:
I am inclined l
O 13 to agree with Mr. Thomas, but if you feel that:you want to do i
14 1.t as fundamental bcckground material, I will allow you to 15 continue with this line of questioning.
16 But at this point in time I am hard pressed to 17 see what relevance it does have.
13 101. F0F0WSKY:
I hope it won't take more than 10 a minute.
2f)
BY MR. FOPOWSnY:
21 QL Can you,tell me what'the algebraic summation of g
plus 4 and negative 3 is?
I
^
23
.A From a mathematical standpoint,it is a plus.'l.
2,j Q'
What is the absolute sum of plus l.and i
23; negative 37
-l 1
== 1 tem::Actf 3 MAltCIL% WC. = W M. LOC 2mfE!.T*/ 4.W.
- E7:Tt:1Dt;na % *T1*C.
_._..,..~_,-,._n j._,_,..
,y,
.g g
y m g.7 ~
=,.
. 2,.:
~-
32 1
g 'I I
.lematically it is 'T.
O 2
Q What in the square root of the sum of the 3
squares of those two figures?
4 A
If.you have a calculator --.-
g Q
I picked an easy one, you will see.
4 squared 6
plus 3 squared --
7 A
16 plus 9 is 25, the answer is 5
.S Q
So you do achieve three different results by 9
using those three different calculations? -
10 A
- Mathema.tically they are different operations, t
11 therefore the answers should be different
- mathema.tically.
12 Q
Can you tell me, based on four understanding, 13 why the algebraic summation technique is sot the proper one,.
24 if that is your unflerstanding?
15 A
That is not my understanding.
It.is my i
16 understanding at this. point in time at least.it was a proper 17 technique at the time Beaver Valley was designed.
10 Q
' With our present state of knowledge, why would' 19 you think that it would produce improper results, 20, insufficiently conservative results?
27.
A As. I ur.derste.nd ' it -- and again I am not a 4..
t 22, seismic expert -- but as I understand it, the' two codes can
.i 23; produce different resnitsLfor different type problems.
One n
24l mt.y be mere conservative than the other,. given 'a certain.
)
j 25
. specific fact situation.
I
- t. wrme:2 e wx.mi., rm.-r: r :.or.nne.or err.-==w.w. rr, m2n -
t j
,.m g.
g m,n-qp
- y
l 33 On the other hand, the second may be more D
g. conservative than the first, given a different fact situation.
j The general consensus seems to be that for the full spectrum of problems tlie ' technique which uses the 4
3 square root technique tends to give more conservative results g
over the full spectrum of probfems,:but that does not 7
necessarily mean that the other program is. wrong.
~
3 In fact, if you go back and review plants which g
were designed using these type techniques - arid let's tcke 7.0 it out of the realm of nuclear, let's put it in the area of 7p chemical plants or other power plants which have been built
~
12 at various locations, for which there have..been earthquakes --
O 13 it is my understanding that these power plants, these chemical y
plants successfully rode through these earthquakes with little, 15 if any, damage to the plant equipment.
gg So in my opin on they are two techniques, they 77 have a little different g11Ech, shall I say, in the method 7g of calculations, but they both seem to produce results which 3
are conservative and which at some point in time were 20
- acceptable to the NRC.
37 Q
Isn't it correct, though, that conservatism in i
a piping system might come from other sources other than the g
23.
seismic stress technique used?
O h
A Yes, there are other factorn which go into the 2S calculation of how you.put in a support, how you put in a 1
r :e mu-n a r.m:w.. ne. -.n n. s.oarmu.= vs. - nr. m:,mme. r. n: n l
---~r-7 -
- p -- - vp f " &'
.1,?m "r g *"
- ~ *
~
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_r T;..
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=.,
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)
hanger,andthereareotherfsItorswhichhavemorebearing
.y 2
on the answer -- the answer being whether that support is y
3 adequate or not -- than the seismic calculations themselves.
The deadw ighit of the pipe,+ the operating e
1 4
5 pressure of the fluid, the thermal expansion of the. line '--
6 e.11 of these are additional forces which are in operation 7
on that particular section of pipe or that valve or that
.8 elbow during the course of the operation of that plant,.and 9' e.11 these must be taken in consideration when you design a 10 hanger or design a support.
11f Q
Might that not' explain why the plant you 12 mentioned might be able to withstand certain seismic stresses 1
13 even if the algebraic summation method as to the seismic if components is used?
15 A
That may be one reason but-also the calculation 16 itself.
There may be enough conservatism-in both calculations..
l 1'y Q
Isn't it possible that the-algebraic summation'
)
-1 10' method-can result in ::ero stress if the figuren that are 1p being summed are. equal.but opposite?
20 A
No, because -you don't understand how the l
j.
21 summation is made.
Your assumption 'it is -plus A in the north ~
1 22 and minus 3 in. the south, it is a ' net' 1, that is not' the way i
l 23 the calculation is made..'It is not that type of summation.
-24 Q-I.was.Just trying to give a simplified 25. example.
Can you give a better explanation of thett.
(-
n,mm om.v.m _n.mmm.
m-.mm,m,;r.
i l
._, %g q,,
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If A
I,will try.
An earthquake is sort of D
2 simulated as really being.three earthquakes.
The pipe can 3
move east and west, north and south, up and down, as well'as 4
in and out of a plane, so it can move in three different 5
directions.
6 On top of that you also assume that in each 7
of these three directions there can be other forces due to the S' earthquake in three dimensions.
9 So you end 'up with essentially nine potential 10 force vectors which then have to be summed.
What you are 11 talking about in the summation, in this whole technique, is 12 summing two of those three vectors and the two you sum are the D
two which are in the same plane ac the ground, shall we say, 1/t as opposed to being up and down; you sum those two either 15 using an algebraic summation or a square root summation.
16 What you are summing is the two forces which 17 nre, shall we say, east, or the two whi'ch -are out from the 10
. plane.
So you are summing forces which are esuentially in 19
' the same general plane reference as opposed to summing as you f
20 indicated.
2 I
21; Q
Could you go on to explain +then what results '
[
22} you would get using the algebraic s'ummation as opposed to the 23 absolute sum or square root of the sum of+the squares?
f 20 A.
Well, you can get different answerc as we.
1 25j developed ecrlier when you went through the strict 2
E
- t.*Em3Ac 4 3 f4AF:5EAL, 'MC. - s':P H.LocrmLc7J 1.*f4 = U.*.*"ttcotmc. Plb 17f tt',
em y.
g77
- - -~ s,~.- -
77 p cm--,,, y
--cyc-
,.,. - - ~ ~
36-I mathematics.
If I add something algebraically.I can get a 2
different answer than if I add something with the absolute 3, value.
l 4
By the same token, I can get the same answer, 5'
too, depending upon the signs.
6 Q
Tha in right, it depends on the signs.
7' A
Yes.
6 Q
Is it possible to get a zero result making the S
summation that you just described?
10 A
Yes.
11 Q
Using the algebraic summation of it?
12 A
Yes.
You can also get it the other way, too.
O 13 You can get it algebraically, you can get it from the sum of if the squares, depending upon the nutabers involved.
If they.
15' are all zero, the answer is going to be zero, obvibusly.
16 Q
Dut they don't have to be all zero to get it 17 using tho algebraic summation?
i 18 A
That in right.
19 (Testimony continues on Page 37.)
20 21 22l
~
t 201 a
p 24 t
M$
i i
I
!*MWCH o 24?.nst:% !*!c. = 27,f.1.ocityrt,t.cy; t.'t2. -!;;f-mrx.7r, M. ::7 :3
.,7_
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Dunn-cross 37 l
I Q,
Referring again to E: hibit C there is t
9 p
reference made to a Regulatory Guide 1 92, that is in 2
Paragraph 4 of the attachment to Exhibit C, and that Regulatory Guide it says was published in December.1974.
Can you tell me, to your knowledge, what that Regulatory g
Guide says about acceptable methods of the. seismic atress 6
summation?
7 A
No, I cannot tell you what specifically it g
says.
It provides guidance to thoce' people who are doing'this p
type of design work no to what are acceptable methods to make 10l gl such calculations, or, if you elect not to follow the guide, then ; justify any other technique which you may wish to use.
p, O
That is a general type description of what g
74 is in regulatory guides as a whole.
Q Then you don't know what specifically that 15 t
guide had to say about methods?
g 7,7 A
No, I do not.
Q Was it Duquesne's policy to reevaluate its g
design practices on.Boaver Valley 1, for example, in light of l
the issuance of a regulatory guide that might have come out s.O during construction?
A This would have been a general practico not only unique to Duquesne Light Company.
The people who are in
~
3 O
the business of' designing reactors or any pcwer plant, so to g
g speak, have to be continuously aware of what the regulatory i
I' TTWE14E A MAft3"L?1. "ffa = 27 ft, LOC 3:WfLLOW A It'. = fCJIti lPJ'JMC. T'A. f */113
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,. w. _
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~
,e Dunn-cross 38' g
requirements are and what the requiremento could be in the D
i g
future.
3 But they have got to design to whatever the i
4 requirements are at the time they are doing their design.
5 You can't be changing your design criteria during the course 6
of the construction of a plant.
7 Q
Do you know whether Duquesne was ever 8
specifically informed by Stone & Webster concerning the 9
contents of Regulatory Guide 1 927 10 A
I don't know.
11' Q
In Exhibit H, which is a fairly lengthy 12 exhibit, in connection with IE Bulletin 79-14, which deals, O
13 I believe, with ceismic piping analysis --
14 MR. THOMAS:
Wha,t page of the bullebin?
15 MR. POPOWSKY:
.I am talking about 16 specifically Appendix A.
17 MR. THOMAS:
To 79-147 13 MR. POPOWSKY:
Right.
19.
BY MR. POPOWSKY:
20; Q
Do you have that reference, Mr. Dunn?
l 21 l A
Yes, I do.
22 Q
There is a reference there to-Beaver Valley 3
,?3 and the~ appendix is' entitled Plants With Significant Differ-t O
4f ences Between Original Design and As-Built Condition of Piping g
i 25j Systems, and then for Beaver Valley there is a statement that I
' m w.nen a suamm rm. - n n. s.ec :m.t.ew xrr. - ne:moma vio m sn 1
,y g.
- y..
Dunn-cross 39 1
.the licensee reported "as-built conditions differ significant1 r 3
from original design."
'S Do you know what the source of those s
4 differences was?
5 A
You said the licensee reported significant 6
d'iff erence.
I don't know if that,is a fact.
It is my 7
reco31ection, and Beaver Valley is included in Appendix-A 8
because of the valve weight question which was developed 9
durin5 the course'of the redesign of the safety injection
~
10 system.
11
'In the original seismic analysis the valve 12 was factored into the calculation on the basis it had a 250 3
1 O
O pound weight, when in actuality, based upon information which 14 became available in early'1979, at least to stone & Webster, j
15 the valve weights were 1450 pounds.
4 10 Therefore, yes, there was a significant i
17 differcree in terms o'f the valve weights as used in the 18 original seismic analysis and what the actual, shall we say, i
r 39 as-built condition of the plants were.
.Now that is my_ recollection.of-what was in j.
I 21 thero, and let's.continucion through.other. parts of that 3l 1
l 22 exhibit.
For instance, let's take'Duquesne. Light's reply 23 to that bulletin dated October 30,-1979.-
l p
y
+
- 2fh, MR.. THOMAS :. What - exhibit in that?
25 }I
~
' It is still in Exhibit; H.-
THE WITNESS:
q
.,. - ~. - ~.
. - - - = -, -.,. - - - -
I
.- w,-
-we-w, p
l-Dunn-cross 40 It is my letter to Mr. Grier of the NRC which is our 120-day g
response to the bulletin, and on page 3 -- and I am not going 3
to'go through the whole letter, the letter will speak for 3
4 itself-- it says: "Since no. modifications have been determinert
~
5 t
be necessary as a result of the relatively small number of f
discrepancies found on over 50 percent of the safety related 7
Piping systems."
8 I am under the general impression that
-l p
based upon a review of our as-built conditions and specifical:.y 10 the review as a result of Bulletin 79-14 and 79-02, that 11 there are not a significant number of differences between the 12 as-built condition as used in the seismic analysis or on 13 some dic. gram and what the plant actual conditions are.
14 BY MR. POPOWSKY:
)
15L Q
Is that Appendix A then, that I referred 16 to originally, in error as you understand it?
A I don't know if it is in error.
It was y,rj 18 written by the NRC.
It may be some NRC's man's interpretatier gg of what the problem may be based upon insufficient information.
2()
Q Isn't it correct that you have had tio 21 revise your final report on which the. termination of the show i
cause order was based?
22 23 I
.A What do you mean, revise?
~
O 24 4
Wells specifically I would like to refer i
you to n. letter which I trould like to have marked for 25 1
i r n..nmu a un.,,r nc. a n. wawn.uw re:. - ww-mov:. n. swe sn
Dunn-cross 14 1 1
identification.
1 0
2 A.
This is a revised letter signed by Mr.
1 3
Carey to the NRC indicating we have new information available 4
to us.
5 MR. POPOWSKY:
Before I go on, could we 6
have this marked as Office of Consumer Advocate Exhibit No. 1
?
7 THE ADMINISTRATIVE LAW JUDGE:
Granted.
8 9
(OCA Exhibit No. 1, photocopy of letter dated January 3, 1980 to Director of 10 Nuclear Reactor Regulation from J. J.
Carey, was produced and marked for 11 identification.)
12 O
13 BY MR. POPOWSKY:
l'i Q
This is a letter', Mr. Dunn, if I am correct; 15 dated January 3, 19807 1
16 A
That is correct.
17 Q
S16ned by Mr. Carey of Duquesne?
18 A
- Yes, i
19 Q
I am sorry I interrupted'you.
You were 20 describing the contento of this letter, I believe.
21 A
Well, the letter speaks for itself.
l 22 Basically,'what_is says, the information.we originally j
i 23 submitted to the Commission on August 3, 1979 we now find-D 24 is not entirely correct, there are some other pipes which 25 should have been ane.1:rzed which were not, and therefore we
]
m: mum a mamw. r e.
u r mm.r.w aw.. :,.r::mmm. ea. mva 7.,,
p
,,....., q
i Dunn-cross
- 42 i
-I are going to proceed to do the reanalysis on these pipes j
based upon new information availabic to us.
Q Is this reanalysis being donc during the current outage?
'A 5
Q Can you estimate what effect this reanalysis g
will have on the length of the current outage?
7 A
None.
,g Q
Why is that?
p A
Bccause it is'not the controlling factor 10 in the outage.
It is really part of our response to NRC gg Bulletin 79-14 in which we made commitments to complete a 12 O
13 review of all systems, all systems being that defined in the gg, bulletin, in response, so this bec,omes just another system 15 which we would look at anyhow.
Q Arc you confident now that you have located 16 all the piping systems that have to be reanalyzed?
g A
I am reasonably sure.
I am never 100 percer t' g
confidenb.
g g
BY MR. THOMAS:
J Q
Confident, did you say?
21 A,
Confident.
MR. THOMAS:
Can we have a five-minute g,;
O recess?-
24 25 MR. POPOW5KY:
This wou3.d be a good time, f-ronrmscu 2 mantur ce. - e n. t.cct:rnu.ow ent. -:mwanuna, en. tri:n
._gs=p-**-e etwe $q w,-
. qqp.:
m9,
Dunn-cross 43 THE ADMINISTRATIVE LAW JUDGE:
We will take 1
g O
1 2
a ten-minute recess.
j
\\
3 (Short recess.)
l 4
5 CLIFFORD N. DUNN,. resumed.
l 6
BY MR. POPOWSKY:
7 Q,
We were referring earlier to the show cause 8
order in Exhibit D and there was an attempt to clarify the 9
time frame which was being referred to there.
10 I believe that show cauce order was signed 11 by Mr. Harold Denton of the NRC.
Are you familiar with other 12 statements by Mr. Denton, for example, before Congressional O
13 committeos, in which he ctated that the a16ebraic curamation 1
14 techniqu.3 was not a method accepted by the NRC at any time?
15 A
No, I am not aware of such statements.
I 16 am aware of a statement by another member of the NRC which 17[ basically said there was no requirement, in about 1974, which says it was not accep'abic technique, and by it I mean the c
gg.
19 PSTRESS Shock II type treatment, and again the fact that the 20 NRC had licensed something like 20, 22 or more other reactor 21 plants which were designed using either this code or one 22 very similar to it in terms of the method of summing.the 23 [ forces.
O i
2,[
4 With your permission I would read from a 25i statement by Mr. Denton --
l tt x~.newn anan me. - a n. we.:.www an - rwm :mm, n nm --
44 Dunn-cross i
MR. THOMAS:
I am going to object, Your g
Honor.
Tho witness says he is not familiar with it so why 2
j read frem it? We don't have Denton to cross-examine.
THE ADMINISTRATIVE LAW JUDGE:
The objection 4
g is sustained.
6 BY MR. FOPOWSKY:
j Q
Is it possible to change the design criteria 8
for a nuclear plant during the course of construction?
p A
Yes.
10 Q,
When Beaver valley 1 was planned by Duquesne and I suspect also by CAPCO -- what was the anticipated 11 12 capacity factor for the unit?
O 13 MR. THOMAS :
Can I have the question read I
14 back, please?
I 15 (Question read.)
16 THE WITNESS:
Your suspicions are wrong.
17 It was not planned by CAPCO per se.
Duquocne Light was the yg
~
gp company which had the operating responsibility, construction 20 ; responsibility.
But I do not know what capacity factor, if any, was used to justify the nuclear' unit.
21 BY MR. POPOWSKY:
22 i 1 23 Q
Do you know if any particular. outage rate O
was anticipated?
29 15 A
I do noi: know.
1
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45 Dunn-crona -
Q Do you know what the total capacity factor i
y D
3 of Beaver Valley Unit 1 has been?
3 A
Well, at different points in time it is 4
different numbers.
I know approximately where it is..
5 Q
Is it correct that the cumulative capacity 6-factor as of the end of 1979 was 27.6 percent?
7 A
I don't know if that is the number or not.
8 Q
Do you know approximately if it was less 9
than 30 percent?
i 10 A
My impression is that it is greater than 11 30 percent but I don't know specifically.
I haven't looked 12 for that number for some period of-time, and I am not too O
13 sure what your source of data may be.
14 Q
The source for that is the NRC Gray Book, 15' January 1980.
16 A
That is a very poor number to use because I'l the Gray Book, when you use the data cumulatively, you are 18 essentially going back and picking up data since the unit 19' was initially synchronized on May 30 or 31,1976, so you are 20 penalizing the unit in terms of capacity factor for the 21 problems it experienced during its initial period of start-up 22 That is not realistic.
23j Q
Can we use the capacity factors at least O
7,4l for 1976, 1977 and 1978 that have been given in the CAPCo.
25I croceedings?
Are you familiar with thone fi6ures?.
b CWrmACH & LTAliS*?AL. "JC, = ;'7 M. *.cc*'" lit'.f..OW sW*:. ~ fif/E:cDur:0, PS. 1711J1 -
,.. - 4 l.
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Dunn-cross '
46 MR. THOMAS: 'If Your Honor pleaseo, to g
2 preserve my position.on the record, 'anything prior to the 3
utage of March 9, 1979 we object to.
BY MR. POPOWSKY:
- {
4 5
4
, Can we just get a rough. estimate? 'I believe 6
you did indicate that you thought it was somewhat more than 7
30 percent.
.S A
My ' recollection is it is somewhere in the y
area of 35 percent roughly.
It will vary from time to. time.
10 As I have indicated in my direct testimony, there are periods 11
-- I am not using capacity factors, I am using availability 12 factors, which are far more indicative of the unit!s performanc e --
13 the availability factors in late 1979 were running something-14 like 95 percent over a three or four-month period.
15 MR. TEOMAS:
The availability factors are-
?
16 shown in answer to' Item No. 9, page.2 of 6 of Duquesne 17 Exhibit 10A in' response to a staff interrogatory.
ig BY MR. POPOWSKY:
1p Q
Do you know'approximately what the cumulatit es 20f availability factor has been for Beaver Valley?-
l 21 A
Somewhere'around_40, 45 percent excluding i
22
.the time it was.in preliminary operation, that is excluding 23 time-prior.to October 1, 1976.
24 Q-In your. testimony you refer to.the cost
.25 benefits of large units.
Do you know what capacity factors wmu,um n n.wna me.- xi n. s.ome:m.:.w av=. - ".ncacme. n. tmn uM, -,A4 y.
,.4-
,p,...
_., m-.7,,, y L.,., q r-+*..r--
5.
r y m.)gejg,.,
g,,,..,,
y,
g m -
,ts.
,m f.gygg3,p 7g
Dunn-cross 47 l'
yt you have to achieve before those cost benefits start to be-
. i D
realized?
2 A.
I have.never made such a calculation and 3
I don't think you can base your evaluation strictly upon-4 5
capacity factors because that unit providea more than. simple f
capacity in terms of generating capacity, in terms of benefits 7
to the customer.
It also provides' backup whenever you need i
8 it.
o I may not be running a unit at a 100 percent 10 capacity factor fbr one reason or' another, including the fact 11 that the customers' demands are such that I don't need the 12 unit to supply the load.
Therefore, to say the unit is a i
13 good performer or bad performer strictly on the basis of-14 capacity factor is wrong.
15 Q
Isn't it true that Boaver Valley is.the r
g first plant on your loading order?
17 A
Yes, it is.
i g
Q What does that mean?
3 A
It means it has the lowect fuel cost,.
go thereforo, all other things being equal, it should run at' 21 or near whatever its rated-capacity is for that particular.
g day.
However, there is no guarantee that that will'be so 3
23 because you still have to operate a cystem, supply the j
i b
O 24 customers' instantaneous needs out of several units -- nuclea2
)
. 25!
fossile.what have you..
L
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.Dunn-cross-48 s
You cannot put all your eggs in'one basket, p.
2 so to speak,.and simply. supply the customers' load on a 4:00 3
o' clock Sunday morning summer day when the load is down to 4
something less than a thousand megawatts in the case of j
l 5
Duquesne Light Company.
You have got to have some diversity 6
in supplying a load, therefore you may back off a nuclear I
unit in order to maintain your generating load to match that 4
of the customers and keep the unit still in service.
9 Q
.Is it correct, though, it is generally the 10 goal to keep the plant which has the cheapest. fuel' cost on 11 line a maximum percentage of the time?
12 A
That is a sub-goal.
Your main goal'is to O
r 13 supply the customer reliable service in-th's most cost effective 14 The two arc not necessarib.y compatibic under all manner.
j operating conditions.
0 Q
Are they compatible under most operating N
conditions?
10 A
In terms of nuclear units, yes.
Q You referred to that period during the N
latter p2rt of 1979, I believe it was approximately three and 21 a half manths, during,which Beaver Valley Unit 1 was available I
k 94.5 por:ent of the time.
I A'
Yeo, that is in my testimony.
3 O
2*}I
~Q-You refarred to this period as evidence h that the unit has supplied! energy to the publiclin a reliable r
manmi a mene inc. - a n. t.a.:wa.:
- x m. - nmu:amne m m :s -
- w ms-,.-, n.,w
..m.,.,.
m m,.
~-.r
-Dunn-crocs 49 manner, is that' correct?
D A
No, I think you miccharccterize my testimony 2
I believe what I am saying is that it has the capability of g
doing it in a reliable manner.
Q During this period is it correct that g
Beaver Valloy was operating at approximately 30 percent of 6
full power?
,j.
A Yes, for very good technical reasons.
It
,g was near the end of the core life.
The boron concentration p
was m y lw.
In order to ma M ain adequate W ee of conh ol 10 over thE.t reactor and still operate within our technical 77 specification it was absolutely required that we operate that g
O plant at a lower capecity than what is established by full 73 j
y rating.
Q Is it also true that it was during that 3
I period that you learned of the possible turbine problems g
involving the Westinghouse turbine and that that discovery g
may havo led to a shutdown of the plant, if you had not g
already planned the current shutdown?
g A
That is not entirely true.
We became aware g
that Wentinghouse. had a problem in terms of cracks on disks 3
for certain units, we became afare of this about October 30:,
1979, an-I indicate in ny testimony.
p O
'W became aware.of it because'onc member g
f my staff attended a meetin6 sponsored by Westinghouse 25 v.eu w.ex a esans re., se e.
cf n. ne::: cent.ovi avic :fnat:2:ina, a. :,ssa
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7
.,,,. p.w -
z:.
- =.
=
a-Dunn-cross
'50 which included representativos from other utilitics.
At that y
D 2
seminar Uestinghouse presented the problem, presented their 3
evaluation of it, and indicated what efforts they are doing 4
to try to minimize the problem.
5 At that point in time we did not know 6
there were any cracks on the Beaver Valley No. 1 unit low 7
Pressure spindles.
8 Q
But since that time you have discovered --
9 MR. THOMAS:
Are ycu finished?
10 THE WITNESS:
He is going to ask the 11 question which I -= do you want me to finish it?
12
- 18. THOMAS:
Go ahead and finish if you 13 were not finished.
14 THE WITNESS:
We,did not become aware 15, that Beaver Valley had cracks until January 5, 1980.
16 BY MR. POPOWSKY:
17 Q
Is it also true that during this period gg.
we are talkin6 about, the end of 1979,'Duquesne was cited 19 for a safety violation at Beaver Valley?
20 A
You will have to be more specific than 21 that.
22 Q-Specifically.on November 27, 1979 a safety 2,3 violation conderning the emergency core cooling system.
O 24 A
Yes,~I am aware of that one.-
4 25 4
Referring to page!11 of your testimony, if
- 1911n21*H D MARSHAL. !!id. = 27 IL LOC!t"WILLOVf AVE. - N!J*nf0Dtin?. PN 17f 12 -
+
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tw, ec.
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Dunn-cross 51 I could quote from your statement approximately five lincs 7
f1 down, you state that to alter Duquesne's base rates would be-2 to penalize Duquesne for precautionary action'taken in the 3
public's interest and would require Duquesne to become an 4
5 absolute guarantor in its electric operation even during a f
period of transition in standards applicable to nuclear stations such as now exist out of hhe Three Mile Island 7
8 nuclear accident.
pi It is correct, isn't it, that the chow 10 cause order involving the seismic shutdown was issued before 11 the accident at Three Mile Island?
12 A
The show cause order is dated March 13, D
13 1979 The accident was March 28, 1979 M
Q Was this shutdown based on the need for new 15 safety standards, or rather was it en the basis of a failure 1
l 16 to apply the correct standards at the time the plant was 17 built?
A It was based upon the concern for public j
gg 19, safety.
20 4
I am not sure if that is responsive.
Is l
21 it your understanding that the shutdown was based on the t
27 need for new safety standards or on the basis of the failure j
33 to apply the correct standards at the time the plant was O
b'uilt ?
24 25
. A '.
.Neither.
i vomi.c:< umnim me. - m uceu.m m. - mem:::un.,r. m u
._~.,_#,_._..._,,_.%,.
Dunn-cross-52~
(.
Q Can you explain that? -
1 D
A I will take them one at a time.. Ask me 3
)
the first one a6ain and I.will say why it doesn't apply.
g Q
Was the shutdown based on the. need for new 4
l safety standards?
g A
The answer is no.
We had. safety standards 4
which existed at the time the plant was designed.
To the 7
best of my knowledge at this point in time the plant was y
designed to those standards.
g Now something may come up in the future to
.;g change that but as of right now that is my understanding.
I What is the second question?
g O
Q I think you might have answered the second g3 g,4 Was it based on the failure to apply the correct stand-one.
15 ards at the time the plant was built?
A The answer.to that question is also no..
.g The shutdown was based upon an uncertainty as to whether or g
not the questions you have raised truly existed.
It was in g
the interest of public cafety, conservatism In terms of g
g public safety, that.the NRC took a precautionary action and shut down five nuclear reactors until such time as the' safety g
1 question'could be resolved.
22.
i
.Again, the. shutdown from my standpoint was.
g f
totallyjin the' interest of public safety.
Q In your opinion, ishould Duquesne: ever he 33 I
mamucn a remsm nes - a n. wems.:.cw AvM, - W.T sCUno, rti. PM t3 -
1 1
1
-w v.,
v.
ny
-e n
_. m er
. p;,...,,,.
ny,
~--
Dunn-cross 53.
(.
held financially responsible for the cost of a nuclcer plant 1
. outage?
2 A
Ever?
3 Q,
Yes.
A That could c wer a multitude of various 3
areas.
Even before you could think of such a conte:ct you 6
would have to prove some form of absolute negligence on the 7
part of, at least, corporate officers in terms of what was
,g i
done.
p Q
Do you feel the ratepayers should pay for 10 i
outages caused by an error, if not made directly by corporate g
officers of Duquesne, then an error made by the contractors g
O 73 for Duquesne?
MR. THOMAS:
I c)het to this question, j
g I d n't want this witness' opinion on this type of regulation 15 and a presumption of an error.
We have, in my opinion, a 16 specific outage involved here and --
y MR. POPOWSKY:
Well, he states similar g
opinions in the testimony '--
g MR.' THOMAS:
In response to'a Commission
,gg question, I think.
21 THE AINIFISTRATIVE LAW JUDGE:
Will the.
l g
l g
reporter read the question?
O 24 (The following was read by the reporter:
j l
~25 question:
Do you feel the ratepayers should
<cimam a musw.c te.- a n. i.oexvm. w c :.- num::mnw. m s::
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Dunn-croso I
pay for outagcc caused by an error, if not made g
b directly by corporate officers of Duquenne, then 3
an error made by the contractors for Duquesne?)
3 i
MR. THOMAS:
Your Honor, I believo a 5
question like that has to be put in some factual context.
6 THE ADMINISTRATIVE LAW JUDGE:
The objectior is sustained.
. 8 MR. POPOWSKY:
Well, can I put it into the o
factual context of this proceeding,?
If an error was made by 10 Stone & Webster by applying a computational technique which 11 was not either the current state of the art,' or was not even 12 p
the current state of Stone & Webstcr:s art, in calculating i
13 acismic :: tress for the Beaver Valloy plant, and if the NRC 14 subsequently, several years later,' upon discovery of that 15 fact, shut down the plant for five and a half months at a
'M cost of approximately $20 million to the ratepayers, are the 17 ratepayers to be, held responsible for that outage, for that 18 amount?
19 MR. THOMAS:
I object to that question 20 unicas Mr. Popowsky will lay a fcundation by calling a witnost 21l from Stene & Webster and proving the facts, because this ic 27' not a hycothetical question, that 1.n based on this case.
23, Now if he wants to call Stone & Webster, p
i
~s I would be delighted.
25' MR. P0F0ifSKY:
I as sorry, the first r :emuen o nr.r. rat.. me... a n. ec::.w_wri u.v. -. mnrannunc. n.
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Duun-cross 55 e
1 objection was that I-didn't put it in the factual context of
~
D 2
the case --
3 MR. THOMAS:
You still aren't putting it in 4
the factual context of the facts proven in thic case.
There 5
is absolutely no evidence here that there is an error on the 6
part of Stone & Webster, and with everything that has gone on 7
with respect to these five stations the NRC did shut down 4
there has been no evidence -- and we have searched for it --
9 that Stone & Wobster was in error.
10 Now if you can come in c.nd cho11 that they 11, wero, we would have no problem with that.
But in the context 12 that you are putting it now I think it is objectionable.
O 13 Further, I don't think this is the witness II that can answer that question.
Yo'u cre Setting into a mix of 15 legal contentions.
I don't want my witness answering legal 16 position 3.
17 MR. POPOWSKY:
I think he takes certain 18 positions in his direct testimony.
19 FIR. THOMAS:
In recponse to a Commincien' 20 question.
Somebody had to.
21 THE ADMINISTRATIVE LAU JUDGE:
The objection l
22, is sustained.
l 2?i EY MR. P]POUSIN:
O 24 4
At page 12 of your testimony you atate 25 thc.t Bearer Valley would have been shut down for refueling I
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Dunn-cross 56 t
7_ _
e and modification work starting in mid-May,1979, and there-1}
0 fore any additional costs experienecd cubsequent to May 1979 2
would have occurred even if the show cause order had not been 3
issued.
It is rre t, isn't it, tha.that refuel W 5
did not, however, take place during.the outage for the show 6'
cause order?
7 A
It could not take place.
,g Q
But it did not?
g A
It could not so therefore it did not.
10 Q
You also state at pa5e 12 that during this g
period the ratepayers did not bear increasing energy costs.
g O
Isn't it true that the ratcpayers8 energy costs would.have g
been lower if Beaver Valley had bepn in operation at that time
'?
~
74 A
All other thingo being equal, that would 3
be true, and that is what I also imply in my testimony.
.g Q
Yes, in fact at page 14 you estimate the p
increased generating and purchased power costs for the 162 g
' days of the outage to s. mount to $19,880,000, is that correct?
gg A
That is correct.
That estimate was made by 20 g' a member of my staff on a day-by-day basis during the cource 1
of the outage.
p Q
Can you tell.us hcw that figure was j
j e
O calculated?
24 A
Basically the answer indientes at least ocme 25 C DHrCACH e Mt.!:'TMt.b iMC.== O' N. Loc:C*."1tLLOW WI* - f'A.t.;tt attac, rg. T/11:2 -.
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Dunn-cross 57 assumptions used.
Reading Answer 15:
Daily estimates were 1
O made using actual after-the-fact conditions but assuming (2'
Beaver Valley would have generated 8400 megawatt hours each 3-day of the 162-day peried.
The 8400 megawatt hours are 4
equivalent to operating at a 91 percent capacity factor.
The first assumption is that it would operato 162 days at a 91 percent capacity factor.
The calculation also looked at the actual 8
after-the-fact condition, both on-peak and off-peak and made rough estimates as to what the differential fuel coats were off-peak and what the differential fuel and purchase pouer costs were on-peak, and made an estimate as to what the cost O
of the cutage was in terms of Beaver Valloy not operating g
for the 162-day period.
g, 1# "" **"** D
""** 3 " "
"I *#
.15 may or may not operate at a 91 percent capacity factor during that period.
It may operate a littic higher.
It may operate i,t a little loucr, but it is the best estimate uc have.
20 at g
Q You calculate 6/the bottom of page 14 the cotimated effcet per month per recidential customer.
Have you done similar calculations for conmercial and industrial 2,
,1 customers?
- 27. -
^
2[
i Q
Is it correct that commercica and industr:.2.1 O
24[gj customers would have made up more than 80 percent of the ccta3
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Dunn-cross 58 I
cales baned on your statement in anawer to A-16 that 2
residential sales is 19 77 percent?
3 A
Yes.
4 Q,
When asked about the effect of Beaver 5
valley on base rates at page 15 you state that it is impossib]
e 6
to determine which cocts associated with Beaver Valley are 7
included in your current settlement rates.
Do you know that 4
costs are being calculated for Beaver Valley to be included 9
in the upcoming Duquenne :aate case?
10 A
Yes, I know, and yes, they are.
11 Q
Do you know when those figuros could be 12 made available?
O 13 A
I assume when we file our rate increase 14 including the exhibita and testimchy.
15 Q
Am I correct you anticipate doing that at 16 the end of this month, April?
17 A
I will defer to councel.
~
18
- 18. TH0ifAS :
We will file within the time 19 period required by Cocmisalon regulations using December 31, 20 1979 as the test year.
21
- 12. POPOWSKY:
Thank you.
22 MR. THOMAS:
I might point out, though, 23 to you that there is no wa,7 that filing is going to shew shat O
24 part of Beavor Valley was'in the $58 million settlement.
]
25' That is unkneen.
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i Dunn-cross 59 MR.'POF0WSKY:. I don't want to get into a I
]
b legal argument, but there is also a question of e, prospective 2
1 adjustment to base rates that might be --
3 MR. THOMAS:
You people keep asking what 4
was in the settlement and there is no way on earth that any -
body can tell.
MR. POPOWSKY:
That was not my question, 7
sir.
8 BY MR. POPOWSKY:
e
- I i
Q On page 16 you refer to the energy costs 10 associated with the current outage and you refer us to Table I.
Can you explain why the $18,139,000 figure, which O
is the last figure on Table I, is your projection of e::tra
.g energy costs arising from the pres,ent outage?
A Do you mean why it is?
g Q
Well, let me ask more specifically:
why y
+7j did you compare the two columns, one and tuo, that'is, Beaver j
Valley being out of service January 1, 1980 through July 20, i
1980 to the second column which ic Ecaver 'lalley out of 193i 20{ service from January 1, 1980 through February 24, 1980?
IThy is it that the difference between thoce tuo figures is the total amount of excens energy coats?
A The data, of course, was submitted in.
p response to a specific question in the PUC order.
No one was quite sure what type of. comparison.the PUC was asking for.
25
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Dunn-cross.
60 So for the sake of responding I made the 7
2 assumptions in one case, which is the first column, Beaver 3
Valley off 1-1-80 through 7-20-80 reficcts whatue expect to 4
occur in 1980 if and when Beaver valley returns to operation 5
as indicated.
6 The seccnd column is based on the assumptior 7:
that Beaver Valley had to shut dowil on December 1 in order. to
,8 refuel, that the refueling would have lasted December, January,
9 and the unit was eventually synchronized in late February, and thorefore would have returned to service on or about 10 l
11 October 25, 1980 and essentially run for the rest of the year.
12 The difference really reflects the cost to O
13 the customer because the plant is shut down to satisfy the 14 many NRO requirements which are imposed in the interest of j
15 public safety.
BY MS. ARMSTROIG:
16 i
17 Q
Excuse me, Mr. Dunn.
I believe you said 1
10
' return to servico October 25, 1980.
Did ycu mean February 25, 19 1980?
20 A
February 25, 1980, I am sorry.
21 BY IG. POPOUSKY:
22 Q
So then if I understand it, you are using 2,$ '
the expected refueling outage as an offset then to the total O
24};
ceste of the current outage?
25 A
The-second column assumes that Beaver Valley l
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l Dunn-cross 61 would have been shut down December 1, 1979 for a normal F
7 2
refueling, maintenance, those type of activitics, which normally occur during the first refueling.
3 The other column headed Beaver Valley Off 4
g' January 1, 1980 Through July 20, 1980 reticcts a projection 6
of costs which are associated with the net energy clause duc not only to the refueling outage r'equirements but also to the 7
,8 cost of the modifications, inspections, testing we must do in 9f crder to satisfy HRC requirements, which again translatec, 7.0 as far a:3 I am concerned, into public safety.
11' Q
Can you tell me what is the basis for your 12 statement at page 17 that the major problems which caused JJ !
outoges in 1976 and 1978 should not occur again?
14 A
PaSe 17 also refers to Table II, so let's 15 turn to Table II attached to my dii. rect statement.
Table II y I essentially shows the major outages which have occurred to 17l Beaver Va.11cy since its initial period of operation.
The first itom under Major Oubages-Deficiency Corrected indicates 73 }.
39) e,foedwater pipe vibration prob 1cm.
That is a problem uo i
20 (mperien:cd very earlJ in operation, rou6hly November-December,
21l 1976 and early in January or February 1977.
The problem was 22) attribut1d to the fact that we had a tuned hydraulic. circuit, 4
23 so to spcak, in the way the plant was constructed, that is, I
O there was a natural f.requency induced by the flow of the nator 24 25 which, because of the frequency of the piping, lod to a ff *.4f? DAc!! a f3,,Rrf1A:.. ::10. = r710 t.Oct*WIL1,OVf Nfit. ~ liEi?.fSut?W.C, PA, f ?1 fft
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Dunn-cross 62 resonance, a method of amplifying the force, which resulted g
O 2
under certain operating conditions in vibrations to the piping and dQDage to the control valves.
3 We experienced that twice.
We than went 4
5 into an extensive program to determino the cause and to g
determine what the corrective action should be.
7 There were essentially two major changes
,g made in order to correct the problem permanently, and that g
is why I say it should not occur again.
Number one, we 10 changed the number of steges on the water feed pumps so as to' gg-detune the circuit in terms of the frequencies being generatet 12 by the flow of water.
O 13 Number two, we changed the trim on a
)
14 control valve so as to also help cetune the circuit.
15 So with those two changes the problem 16 associated with the feedwater pipe vibration -- and this is 17 ct Icu 1cado, about 20 percent power -- has gone away, we have never seen it since.
gg gg The second item is identified as main 20 Generator hydrogren -- that should be H2 instead of H g
[
, 21 bydrogren duct failure.
It in a probica which is apparently 22 generic to Westinghouse turbines, at least of this design, 23 nhereby a ductuork inside tha generator which conducts f
hydrogen gas from the discharge of the Generator back to 2,.
l-23!
the cooler collapsed.
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Dunn-cross 63
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- L When I say collapacd, I don't mean a total b
2 collapse, it became dented, so to speak, and the flow was 3
. restricted, therefore there was a rattling noise and an' 1
4 increase in terms of temperature of the gas because flo;t was 5
restricted.
6 Westinghouse came in, they anticipated the 7
problem, they really felt they knew what it was before we
.8 called them in, and we did make a design modification by 9
changing the ductwork from a square type cross section design 10 to a round duct type design.
11 This has corrected the problem.
We_have 12 never had a recurrence of it since 1977, and incidentally, D
13 this work was done under the' warranty of the generator.
The 14 generator was still under the warranty at that particular 15 point in time.
16 The low head safety injection pump problem, 17 which is identified as item one under the heading Major Outages-18 Deficiency Correction Scheduled for First Refueling-1979 --
19 this is a requirement of the NRC that we must make certain 20 modifications to our safety injection system in order to 21 improve design margins in terms of safety.
22 It was deternined that.our design under 23 certain operating conditions could'be. marginal and threfore 24 we shou]d make some modifications.
25;
.On top of that, there was some information
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Dunn-cross 64.
which came out of testing at Northanna where certain pumps g
b were experiencing excessive wear in bearings because of the 2
i design of the pump.
3 They did a lot of extensive testing at 4
5 Northanna, they made modifications to these pumps, at least 6
in terms of installing cavitating ventuYis so as to minimize 7
.the cavitation problem.
3 They made changes to the bearing surfaces g
so as to increase the bearing surface on the pump and there-10 fore minimi:o the wecr, and particularly at the bottom of the 11 pump because these pumps have roughly 30 to 40-foot uhafts 12 on them, they are deep well pumps, and modifications of this O
13 nature.
14 These modifications are being done right f
13 now and we have every reason to believe that when these 16 modifications are made, the cavitating venturis installed, 17 changen bo decign of the pump, the problems associated with gg these particular puups and with thic cystem will be removed -
y,9 any quostions of a prob 1cm will be removed.
20 4
And ths.t work is presently going on now, 31 is~that correct?
22 A
Toa.
23 l Q
Io there a deadline for that work, an NRC -- -
O A
Yes., we have to complete it before the 24 i
25 plant goas back into oceration.
As you will note in other wmomo > uww w - =~ ::. t.c: nu.m avx. - w.r.r.wone,a, en. :: ua.
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Dunn-cross 65 4
y parts of my. tcstimony this seemed to be the critical path 1
D I
job going into the outage.
2 The last major problem is that associated-g, with the main transformer failure.
Again I can't guarantee ue will never ave a tranaf rmer failw e f this nature again 5
at the plant but it is highly romoto.
It is not expected.
4 Transformer fail'ures do happen but they 7
are rather infrequent.
.g Q
Has your optimism concerning the future g
reliability of the plant been affected by the discovery of l
10 the turbine problems, turbine cracks?
,l g
A It is of concern to me but it is also of g
O concern to about ten other utilities who know they.'have g3 a
g4 cracks in their turbines, and perhaps other utilities who 15' have yet to make the inspection.
i Westinghouse certainly is concerned.
There g
are a number of organizations who are trying to delve into I
y,j the problems, to determine the ccuses, including Westinghouse, g
1
-3.ncluding the NRC, including the utilities as a group, becaust the utilities have formed a users group in order to evaluate g
just what happened, why the cracks, uhat are th'e causes, what 2,r we should do.to prevent them.
27, In terms of.this specific outage this 2s O
problem should.not impact the overall schedule because,.
p
-25 fortunately, as I indicated in-my testimony, we were able to
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Dunn-cross 66 fl obtain the two low pressure spindles which were built and in 1[
O storage for the Beaver Valley No. 2 unit.
We have brought 2
those to the site.
3 We have made preliminary inspections,.about 4
half the inspection is complete as of the last time I asked, b,
6l and there is 'no indication of cracks, so to speak, but somo indication of surface defect, as I understand it, but no
,t major problems.
g.
Q Is that as to the new spindles?
A New spindles.
No cracks in the new spindlet So it is our intent during the outa6e that we would simply
,, l A
put in the two 1 car pressore spindles which were designed and f
built fo: the No. 2 unit into the No.1 unit and therefore g
g.
ret, urn No.1 unit to service when phe rest of the work is complete.
.g g
In the meantime, the two spindles which are 1,t.
damaged 11111 be returned to Westinghouse, I believe at North Carolina, where they will be repaired and returned to the station.
4 19{
Q For use at No. 2?
A.
Or No. 1, capitalized spares, or if somebods wants to buy them, we may be willing to sell them.
Q If those two spindles from Beaver Valley 2.,a p
Unit No. 2 had not been available, would you have been required to shut down for approximately the 18 month period that you
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Dunn-cross 67 cuG5 cot would be needed for repairs of the turbine?
g b
A No.
2 Q
You would have been permitted. to operate?
3 A
We'would have operated perhaps with some m dificati n t the turbines which would have allowed us to 5
6 60 back on line, but at perhaps reduced capacity.
This type of an alternate solution to the 7
,g problem is being pursued by other utilitics.
In other words, they are not going to take an 18-month out36e to repair them.
g They are willing to take off one or two rows of blades in 10
~
order to got the unit back in service at some reduced 77 capacity.
12 O
Q Can you tell me why, if you know, according g3i g
to the documents which you have included in Exhibit H in thei 3
15 Inf rmation Notice No. 79-37, the information concerning the g
turbine cracks at Westinghouso plants was transmitted to the
! URC by means of an anonymous letter and not reported by the p.
ut111 tics, including Duquesne?
g A.
Duquesne had no knculedge of cracko.in the gg 20 turbino, therefore it could not report any.
Q Hadn't you attended a meeting on Oct ber 21 30, or a Duqueano representative attended a meeting on 3
g October 30 concerning potentici prob 1 cms?
p A
Yes, and the NRC was aware of that.
p,;
25 Q
If ;fou look at Information Notice Ho. 79-37 f.lCHftDACH C MA~tSMAf. UC. = 17 N. LDCl*Vitt.LOVt AVE = 11A*tnin1UNS. Pi 871d
-s m
Dunn-cross 68 1
it states - do you ho.ve that, Mr. Dunn?
7 O
A Yes, I do.
2 Q
It states in the very first paragraph that 3
an anonymous letter was ' received by the Director of the 4
5 Office o" Inspection and Enforcement on November 17, 1979 6
concerning the Westine; house turbine prob 1cm and then it goes 7-on to say that a meeting had been field on October 30, 1979
,8 A
The letter recognizes that the utility had p
met on October 30th when Westinghouse made their presentation:
10 but until such time as I know I have cracks in my turbine I 11: would have no reason to make such a notification.
l 12 On top of that, the plant is designed to O
protect the nuclear portion of the plant against turbine type i
j U
t 14 missiles, so it was a type of accident which was recognized j
i 15 when the plant was decigned, appropriate design consideration I
gl was made when the plant was constructed to minimize the effect 17 f such an accident if indeed it occurs.
g.
Really, the answer to your question is if yj I an a responsible corporate offiocr had any real reeson to i
20 believe that that unit was in significant problems in terms 21 of cracka, I would have shut it doun regardless of what the 22 IGC said.
?,3 l Ue had planned, even before this letter was i
O 2f issue, ta ms.ke the inspection of the turbine.
It was our 25 full intent to do that.
i
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.Dunn-cross 69
^
i i
j 1
Q At page 18 of.your testimony you quote a 2
passage from the'Kemony Commission. report concerning the rate-
)
I 3
making treatment for safety measures at nuclear plants.
Do.
4 you interpret this recommendation that you cite here to mean:
j I
5' that all costs of safoty-related changen, no matter what.
6 standard of utility management is applied, should be pasced-t 7
on to ratepayers?
'O A
You are coming right back to the same' 9
questions you asked earlier, in terms of who should bear l
10 the costs for what type of an outage or what type of an error 11[
and my answer would be the same.
12 Unless you can demonstrate come gross error O
0 on the part of corporate management in terms of deciolons they 14 made, based upon information availabla at the time they made 15! the decision, I' don't think such thing should be even con-
.l 16
- cidered, 1?
If'we, a utility, nahe a decision to put 18 in a generating facility, whatever type -- oil, coal, nuclear 19 it is based upon information available at the time the l
20 decision is made.
It is anticipated customers will ge,t 21 certain benefits out of it.
1 22 There is also recognition that there are
.k 2
risks involved with any piece of operating equipment.. 'It p
21 may be c good performer,.it may be~a bad performer.. It is 3
s 251 a risk of Ldoing business which I think is reccgnized by all t
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Dunn-cross 70 1
people involved.
O 2
THE ADMINISTRATIVE LAW JUDGE:
We will 3
recess until 2:00 o' clock.
4 5
(The hearing recessed at 12:30 o' clock p.m.)
6 7
8 AFTERNOON SESSION O
10' (The hearing resumed at 2:00 o'c1cck p.m.)
11 12 O
i 1.3 CLIFFORD N. DUNN, resumed.
1 14 BY MR. POPOWSIN:
15 Q
Good afternoon.
Would you please refer to 16 page 20 of your testimony, and,in ancwer to Question No. 22 Ul you give a ' list of se'/ oral tasks which are to be accomplished 18 due to safety requirements establiched by the NRC.
Do you 19 have any disagreen at that each of those tasks is necessary 20 for safety purposes?
21 A
I would agree with that.
They are all 22 related one way or.another to safe operation of the plant.
I 23 Q
Cculd any of theso tasks be accomplished O
2c} u while the plant is in operation rather 'then shut den?
25 A
A few of them could'.
Most of them cannet.
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l j
Q Could you specify which could be performed y
2 while the plant is in operation?
3 A
The additional alarms,on the emergency 4
diesel generators could possibly be donc then.
5 Chlorine detectors for the control room.
6 Security systems improvements.
7-And some parts of the work associated with
. 8 complying with NRC Bulletin 79-14.
l 9
Q Could the present outage be shortened if 10 any of these tasks were put off until the plant was back in i
11, operation?
12 MR. THOMAS:
Do you mean the ones he D
13 mentioned?
14 BY MR. POPOUSKY:
i l
15 Q
I am sorry, the ones you just mentioned.
16 A
The ones I just mentioned are really not 17 l the controlling factors on the outagc.
What is controlling, la at least at this point in time, ic that involved with the 19 second item, autcmatic low head safety injection system pumps 20 recirculation modification, and as part of that overal1 job, 21:
the one identified as modifications to the refueling water 22, storage tank, and the one identified an modifications to 21 increase. the net positive sucticn hea$ of the Quench Recirculttion O
24 Spray Praps.
25
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i Dunn-cross 72 BY MR. THOMAS:
1
'S Q
Mr. Dunn, on page 20 that says positive 2
section.
Should that be suction?.
3 A-Suction, yes.
4 BY HR. POPOWSKY:
Q Those last factors that you mentioned, those last tasks, is that what you would' classify as the critical 7
path of the outage or am I using the term incorrectly?
.g A
The critical path during any outage is 9'
g..
somethin3 which can change in time.
I believe I indicated in my testimony that going into the outage this seemed to be g
the controlling task.
I will see if I can find that reference 3,7 O
Q Is that at page 397 g
^
14 Q
Could you go ca to describe what you mean g
by the critical path?
g A.
Critical path is normally defined and interpreted to mean that series of work cetivities which governs the length of the outage time.
g Q
Could you use manpower from taska' that are -
g l
not on the critical path or are not related to that task 21 which you described,. if uw.npower from other tasks were 2,.4 utilized on the critical path tasks could the outage as a g
i l
O
-g whole be shortened?
A No, because basically when you plan' your f
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y4 Dunn-cross
- 73 outage and identify what is a critical path job you put a y
maximum effort into that particular activity, maximum in 2:
terms of the number of people you assign to it and maximum.
3 in terms of the number of working hours which you may schedule 4
g during the course of a week.
Lot's take your question to the extreme.
6 I have a task that is critical path and it takes, let's say, 7
g.
100,000 man-hours to complete; why don't I put a thousand men 9
on it and do it in a hundred hours?
The answer to the question is obvious:
10 11 there is a physical limitation on how many people you can 12 effectively work in a given area to accomplish a given O
13 uctivity.
You just overwhelm it with manpower.
14 So you knov what your critical path is, p
15 you know what work is available to you, you work a maximum -
16 number cf people on that task consistent with getting that work done in a cost effective and a time effective manner.
17 18 Q
Would that include working on weekends
,tg during tiie outage?
20 A
Yes, it includes working two or three shifts.
21 Q
Is w rk being done every weekend on the 22 33 critical path tasks and in two or three' shifts?
O A
To the best'of my; knowledge -- and this 2
(
- 25 changes from time. to time -- but the last time I aaked that b
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Dunn-cross 74 I
I question we were working six days a ucek, two 10-hour shifts -
l
.g O
2 on what 9as then the critical path job, which is tho one we l
3.
had just been talking about.
1 4
Q
. Does that. appear on your Exhibit K, the
]
5; final page?
6 A
No, these schedules are not man loaded on 7
this exhibit.
8 Q
I am sorry, I didn't hear.
9 A
This schedule does not show man loadin6, 8
10 these schedules.
Those are Level 3 schedules, not Level 4.
11 Q
I don't know what that i: leans.
12 ;
A You normally develop what is interpreted to i
13 nean four levels of scheduling, levels reflecting the various 4
14 degrees of detail in time.
15 A Level 1 schedule would be basically a 7
16 bar chart, so to speak, simplified, which would cover the 17 total outage time, be very general, as to the major task 16 being accomplished.
19 You then step down from that. type of 20 simplification to the most detailed, most complex, which 21 is sometimes referred to as a Schedule 4, which will show
- 17..
basic' daily ~ crew assignments in. terms of the number of
(
( il 23 crafts cuch as boilermakers, steamfitters, electricians,
-[
O 24i ilhat have you, who are going to perforta.the functions.
25 Tha schedule which I have shown in Exhibit j
ii I -
uommen a wen ve...: n. ecwm.r.er ex. -:nmeccuam. n. me t
.,, 7 p.,..., _
4' e. 7 + wpg.
Dunn-cross 75 3
K, such as page 3 of Exhibit K is a Level 3, which basically 2
shows in great detail the various tasks associated with, in 3
this particular case, the design change package 189, which 4
again is the one we have been talking about.
5 Q
Pese 13 of Exhibit K, what does that show?
6 A
Pese 13 is a computer printout of our 7
schedule which is used in the daily plan of the day meetings,
.6 and perhaps I should expand on that.
9 In reviewing the outage we have monthly 10 meetin6s at the Vico-President level involving myself as well i
11l as the Vice-President of Engineering and all the higher level 12 responsible supervisors.
O
.3 In addition to that there 'are weekly A
14.
meetings conducted at the station,'again with top lovel 15 I engineering type, construction type operating people who 16 get into more of the details.
17 On top of that, another level, we have 18 daily scheduling meetings in which they review not only 19 what is going to be done today and tomorrow but what is
't l
201 planned perhaps one week in advance in a very detailed 21 breakdown.
If you wa.nt to take it one step further, there 2't ere daily meetings at the forecan level where the foreman or i
6 23; the supervisor will go over with the craft people exactly p
what they cre to accomplish during that particular shift.
24:
t i
25l But to answer your question, on page 13 is t
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Dunn-cross.
76-a typical schedule for a one-week period of time which is g
D discussed on a daily basis at the plant.
2 1
Q Is there any reason why there are no x's,
,,a which I believe would be work scheduled in the column for 4
March 22 and March 23, 1980, which I believe were last g
4 Saturday and Sunday?
Is this an incomplete schedule or was there no work scheduled for that? '
7
.8 A
There is no work scheduled for these p
particular items on the weekend.
These are not critical path 10 items.
11 Q
But there might be more pages to this 12 schedule which might show such tasks performod, is that O
13-correct?
14 A
Yes, this is only page 1 as indicated in 15.
the upper left-hand corner.
16 Q
Which of the teoks listed on page 20 would l
17 y u clasaify as an outgrowth of the scismic problems which wero concerned with in the first outage?
gg A
The very last one, pipe modifications and yp 20[ as-built drawings as required by NRC IE Bulletin lio. 79-14.
I i
21 Q
Would it be your testimony, then, that that also doca not affect the length of the current outage?
p[
23l A
At this particular point in time that is O
tho judgnent of those' people who are closest to the uork.
g 25{ That does not say that at some later point in timo because of I
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somothing; we don't know today that this cannot become critical y
2 path.
My offhand judgment is it will not, but l
3 4
there is no guarantee.
5 Q
Are you aware that this list of tasks goes 6
on to the next page, page 217 y
A Yes, I am aware of it.
You have been 8
talking about page 20, though.
p Q
Let me ask, then, for the list which 10 includes page 21, are there any other tasks, first of all, i
11 that arise from the seismic outage?
12' A
Yes, the very first one identified as f
O 13 base plate and bolt tests and inspections as required by 3
1 4^
14 NRC IE Eulletin No. 79-02.
15 Q
Again, would your answer be the same, that 16 that does not affect the length of this outage?
17 A
As of this particular point in time the 18' answer to that would be no.
This is not critical path.
19 Q
Now that we are including the group of 20 tasks on page 21, are there any other tasks triat are included 21,in my first question, which I believe was could any of these 7;z tasks be completed while the plant is in operation?
l r
23 A
Certain parts of the work associated with O
the first one, that is, NRC IE Eulletin 79-02 could.be done 24 25 with the plant operating.
We did-that.
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Dunn-cross
'(8 q
Certain parts of the work involved with g
]
NRC IE Bulletin 79-17 could be done with the plant operating.
j 2
i Certain safety improvements deemed necessary 3
from the lessons learned from the Three Mile Island accident, 4,
3' as required by NUREG 0578 can be done with the plant operating.
6 Q
Can any of these tasks -- and I am referring to all the tasks age.in on pages 20' and 21 -- be deferred until 7
,8 the next refuel 1ng?
p A
No.
10 Q
On page 21 you refer to various reasons 11 why -- this is in answer to Question 23 -- the current 12 schedule may vary, and these include availability of craft O
13 personnel, definition of work, et cetera.
Has Duquesne-14 obtained any outside assistance to, assisb it in insuring 15' that the length of the outage is kept to a minimum?
j 1(i A
Yes, sir.
17 Q
What type of outside assistance?
gg A
Well, first of all, we are using craft 19 people to do a ma,ior part of this work.
The last time I 20 checked there were something like 460 craft type union workert gy, involved with the modifications in addition to our own 22 raintenance people.
23l We have retained outsido consultants who y
O have expertise in certain specialized areas such'as helping 24 25 with scheduling, helping with design chansec.
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Dunn-cross 79 Need1cas.to say, Stone & Webster, again, 2
I nsider to be an outside source, at 1 cast in terms of 2
Duquesne Light organisation, and they are doing an anful 3
lot of work associated with this outage.
4 5
Q of the factors you include in answer to 6
Question No. 23 as to varying reasons, these factors, do you 7
feel they are not within your control?
3 l
8 A
When you say within your control, let me p
go through the factors and briefly discuss each of them.
10 The availability of craft personnel -- you 11 have some degree of control over it and by the same token you 12 do not have degree of control because you have no way of O
i 13 forcing a craft person to work on a given day if he does l
14 not want to work.
If he wants to y,o hunting or go fishing l
15 or take a vacation or go to another ; Job where there is more 16 overtimo, he is not available, j
I 17 So, yes, you have control over the avail-l I
10 ability of craft personnel in terms of your ability to at 19 least schedule or ask for them but you don't have a hundred 20 percent control over them because they can always take off j
)
31 for the reasons I have alluded to.
I i
r 22l BY MR. THOMAS:
j 1-23[
Q Are these craft personnel you refer to non-O 34l Duquesne employees?
r 25!
A They are non-Duqueune employees, yes.
I l
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80 Dunn-cross j
y* These are union type, steamfitters, electricians, welders,.
C 2
b oilormakers, carp enters, lab orer s.
3 The next item is a better definition of 4
work involved than is presently known.
To a degree we have i some control of this but it is scmething we are always working I
5 6.
on and this comment particularly applios to the Three Milo 7
Island loscons learned, since this is a new development
-l
'8 tthich has essentially hit us just before we got into the 9
outage, October, November, December; new NRC requirements 10 which in some cases must be implemented before we return to 11 power, in othcr cases they must be impicmented on or before
- l 12 January 1, 1981.
O
~
13 So ue do have some degree of contro1 over i
14 the definition ofwork but again within limitations because l
15 there is not an infinite amount of engineering talent avail-16 able to do all the work which has to be done in the time I'l available.
13 Space end equipment limitations are not 19 within the control of mana5ement.
The equipment is what is 20, there, the space is what is there.
It is a physical constrair t i
7.1 dictated by the way the plant is built.
4 22 There is only one polar crane, therefore d
23 you can only use the. polar crano to support.one activity at O
24 a.particular timo, as a typical example.
l 25 You have to do some'of this work incide
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Dunn-crosa 81 t
containment.
Containment is a very specifically defined g
l D
3 volume of space.
The equipment is in there.
You can only I
physically get so many. people tiho can work on a given valve l
3 at a given time so there are space -limitations beyond the j
4 g
control of management.
6 Material de11verlos is something which j
- /
canagement does have control over,' once the materials are J
identified and the necessary documentation including the p
quality assurance requirements are ectabliched.
Documentation.of all work on safety-related l
10 11{
systems is something which we definitely have control over 12 and we do this, but it takes time, it. takes effort.
D 13-NRC inspections of documentation egain is 14 a review by the NRC of the work urtich we have done.
We 15 don't have any control over NRC inspections, but, of course, Inlt the results of the inspections are a function of hou good a 17
- Job ue do in the first place.
la BY MR. F0POUSIU:
.lo[
Q Can you give me the source of the figures 20l. you uno on page 22 as to the mean outage time?
27, A
The source is a document entitled Statistica.1 1
Evaluation of the First Refueling Outages, dated October 1979 q
37.j l
pj and was issued by the company called Nuclear Assurance d
2f Corporation, i
O d
25-
- Q What is the source of the figures on f.*014CBAcit o ?AA't3M/I.. Ifitc. - g*/ N, t.oc::vlt:.7 ac.y A1.%
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i Dunn-cross 82 g
capacity factors and availability factors included en pa6e 18 2
of your testimony?
t 3
A The Gray Book, as you kncra, NRC Gray Book.
4 BY MR. THOMAS:
i i
5 Q
This Gray Book has been mentioned both by 6
counsel and the witness.
I wonder if you would say what the 7
Gray Book is.
8 A
The Gray Book is a monthly report issued 9
by the NRC for each reactor which has a license, whether it 10 operates or not.
It includos the statistical in' formation 11 which each reactor reports to the IGC on a monthly basis.
12 There is a page devoted in there to each O
43 specific reactor and then there eye some statistics gathered 14 and reported essentially in the fi'rst couple pages for the 15 combined number of reactors which have a license.
16" It is reported each month and then they.
17 have a year to date figure.
18 Q
Why do you call it the Gray Book?
Does 19 it have a gray cover?
20 A
It has a gray cover as opposed to the U4 21 Yellow Book which is a comparablo document but it is for 22 reactors which are still under construction stage.
The 23' document has an identification number of NUREG 0020.
Q But do you call it the Grey Book?'
- 24j t:
25 F A-I call it the Gray 3ook.
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Q Well, Mr. Popowsky did, too.
D-7, '
A Because it has a gray cover.
3 BY MR. POPOWSKY:
4 4
In response to Question 35 on page 28 you-5 state that immediately following the transformer failure which 6
is referred to in ycur tectimony a meeting was held to determias 1
7 what could be done and who' would do it.
Was a similar meeting S
held at the discovery of the piping analysis problem?
9 A
There were similar planning meetings, knowing 10 ve did havo the show cause order.
I do not have the documenta -
1 11 tion for that meeting as I did in this particular case, 12 But, yes, there were planning meetings.
O 13 We knew what work we could do.
There were schedules developed 14 an a result of that and subsequent meetings.
15 Was the problem turned over to Stone a 16 l Webster for their analysis or did Duquesno conduct any of 17 the reanalysis iteq1f?
2P, A
What problem?
19 Q
The seismic reenalysis problem.
20 A
Most of it was done by Stone & Webster.
3 11 However, it is my understanding that some of this uork of
{
'T 22 roanalysis.has been assic:ned to other contractors.
{
23 Q
Did Duquesne attempt to verify the reanalysi a 24 that vac dono by Stone & Webster to ensure that no other error 4
1 25 occurred?.'
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Dunn-cross 84-1' A
We did have people who visited Stone &
^
D 2
Webster's office and did review in sone detail, and I can't i
3 testify as to what detail, what Stone & Webster was doing, s}
Q.
Could you say who those individuals were 5
frcm Duquesne?
6 A
No, I cannot..
7 Q
At the top of page 31 you refer to a
.8 Westinghouse turbine generator' overhaul.
New was that 9
performed during the 1978 outage?
10 A
Yes.
11 Q
on page 23 you refer at the top to the 12 warranty inspection of the turbine.
Are you indicating at O
13 page 23 that the warranty inspection is boing done during the 14 current outage?
15 A
No, the warranty inspection was done during 16f the outage of the transformer failure.
Item A on top of t
n' page 31 of my direct statement, which cays the Westinghouse 18 turbine / generator overhaul,is the warranty inspection.
So 19 ue did the warranty inspection ahead of the refueling because 20 we had the opportunity 'to do it.
i 23 4
So then your' general answer to Question 27, 22' which was why are the first refueling outages so long, and 23 included in that answer you state it is the period for O
,?,,}.
warranty inspection of tho' turbine, you are reforring then 25 l' generally to first refueling outages but that is not relevant rop?nsAr l 3 Mrmitt.L. *r2c 17 N. Loct:WILLoct Ayr - Wcn ;5W.c, pp. 3'/t1.*,
i
._.,..g
- =--
4 Dunn-cross 85 to this particular firnt refueling outage, 'is that correct?
'g h
2 A
That is correct, because we in Duquesne
.)
J 3
Light's case took advantage of the transformer outage in ordez L
to do this work..
4 5
Q That was not the first refueling outage;-
6 we are currently undergoing the first refueling outage?
7 A
That is correct.
1 8
Q At page 35 you state a number of reasons -
9, why Duquesne-did not bring legal action against General 10 Electric for damages arising from the transformer failure.
11,-
Is it also true that during that time the replacement energy 12 costs associated with that outage were passed on to the rate-D 1
i 13 payero?
if 11R. THOMAS:
Read the question, please.
15 (Question read.)
16j; 17 THE WITNESS:
This is true ci' any outage, I
y,8 to the e:: tent a unit is down, the increased costo, assuming I
19 there are some increased coste, would be reflected in the not 20[
energy cost.
Of course the other side of the coin is uhen
\\
21!
the plant operates, the customers get the benefit.
I_
l 22; So the customers get the benefit, the 4
i 23!. customers take the risks.
It is s' norical business risk.
O
- p,.}
BY MR. FOPOWSKY:
23?
' 4 You spent sone time this morning describing
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86
__ Dunn-cross the lon head safoty infection cystem.
I am not curo that_I 2
O fully understood what you said thic morning, but I would like 2
to.ask you a couple questions.
On page 36 toward the beginning of the par &aph ym state hat the modincatim was perNmd e
n 5
because in the event of a maijor loss-of-coolant accident, the 6
vapor pressure of-the water in the containment sump -- I will 7
I skip somathing -- may be closer to the containment pressure
,g than original analyses had indicated.
p When were those original analyses done?
g A
They would have been done sometime prior i
g t
the plant going into operation.
If I had to make an off-12 O
hand estimate, I would say 1971, 1972, somewhere in that 73 74 period; certainly early in the des,ign phases.
Q Who would have been responsible for those -
15 analyces?
l g
st A
Stone & Webster would he.ve performed those 7,j.
- analyscc, perhaps with hcip from some other consultant such i
as Westinghouso.
I em not sure.
49 g
Q Who discovered that these analysea were incorrect?
37
-A No one has said they are incorrect.
t, gg Q,
Well, that the pressure was closer to the i
f containrsnt pressure than original analyses had indicated.
{
A I 'am not sure how this came about.
We were
.n ;
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i Dunn-cross 87 naking some modifications to those systems and during the' 9i i
course of the modifications'we were reviewing a number of 2
~
things such as the design of the safety 1njection system to 3
reflect the cross-ties we put in, and I can only assume --
4, I d n't know for sure -- that during the cource of this 5
6 review we went back and reviewed this pcrticular type of
~
7 accident a nlysis.
.g Basically, what it boils down to, in your calculations to determine what happens during the cource of p
10 an accident, what sort of assumptions do you make, as to the 11 distribution of the energy which is roleased in this accident 12 between the atmosphere in the containment and the water which 13 is in the sump, it is a question of what assumptions you 14 use in making these calculations which determines how hot the i
15 water is, shall we say, in the sump, and therefore how much g
cooler the vapor is in the containment, therefore how much i
77 lower the precoure 13.
yg It is a very complicated transient type of i
,tp analysis which involves many assumptiono including those l
20 which I have talked about.
i 21 Q
Do you know if this is a generic problem 3
or is this specific to Beaver Valley, to your knowledge 7 23 A
I don't know.
O MR THOMAS:
Can I have the question prict 24 25 to thab questica read back, please?
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Dunn-cross 88
[
(Tho~ following was Imd by the reporter:
g 2
Question:
Well,.that the pressure was closer to the containment pressure than 3
original analyses had indicated.)
4 5
6 MR. THOMAS:
I gjust want to observe that 7
the question' misstates Mr. Dunn's direct testimony.
His direc t 8
testimony was it "may be closer."
p BY NR. POPOWSIW:
10 Q
The discovery that it may be closer, as I 11 understand it, was made by Duquecne not by the NRC?
12 A
I am not sure exactly who discovered it 13' first.
Ify recollection is -- and you are ~6oing back to 1977 14 is tha,t we were both involved in the question.
I know that 15 we at Duquesne Light went to Washington and sat dotm with 'the i
16 NRC personnel to review the calculations, to review the-17 modeling, the revieu the assumptions and to review the y,3 results, and that result of all'those discussions and
,tg i ovaluations was that we had to make an interim modification 1
20 to the plant so as to allow the plant to return to potter at I
21 that particular point in time, with the coz::mitment that we 3
22 would make permanent modifications during the first refueling
~
23 The interim modification was simply a croos-O 24f tie which allowed us to divert cool water irrto the sump.
'By-l 25 diverbing cool water into the sump you lower the sump-nomusan a w.nm: sna. - w n.1.acxmn.:.cn.m. - vnenun:. n. m m y,.
7
~.: -
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V Dunn-cross
.89 3
i i
temperature, therefore you. lower the vapor proscure, therefore 2
the probability of pump cavitation _is minimized.
3 Now that is part of the problem but that is 4
my recollection of what happened.
5 Q
But you have been ordered to make a permanent modification, you have been ordered by the NRC to O
7 make a permanent ' modification or to ensure that this problem
'O is' resolved before you are allowed to go back on line at the-end of this outage, in that correct?
10 A
We made a commitment to make the modification.
11 There was no order per se that I am aware of.
12 Q
To whom did you make the commitment?
O A
To the NRC.
In tho interest of public 14 safety they wanted a better safety' mar 6in than uhat apparently U
existId.
Again, we ma'do an interim modification which was on 10l interim solution to the prob 1cm but they wanted a more 17l permanent fix in order to improve the overall safety margin.
16 Q
With reference to the uchedule which is included on E::hibit K, starting at pago 5, is this the most.
M current outage summary thabis now available to Duquesne?
I 21 A
Thio' summary is dated March 12, 1980 as 22 you can see in the heading.
I would expect there would be l
. I' a later updato on this report.
I do not normally see these.
D 26'l I get other reports.
i 25!
The purpose of putting this report in cameAcw e xmn:ut me.-es n. i.oewnww ::.- nummnc. n. m:n
- ~ 7,
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. _ _. J u
- ~... _. _.
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' ' ~ _
~j Dunn-crocs 90 there Wac to demonstrate the degree of-scheduling effort A
which hac gone into and will go into this outage.
These are 2
typical types of computer printouts which show various people 3
in the organization exactly where we are in the outage and what work has been, is being and will be done.
Q Have there been any significant changes in g
this schedule since March 12, thati you know of?
7 A
Significant in what context?
.g Q
Well, cignificant that could extend the 9
length of the outage.
,0 A
Not at this point in time, but there is no 77 guarantee that something won't come up which will change the 73 O
outage.
Another problem has surfaced in the last two weeks 33 which we are still trying to evaluate.
g Q
Ccn y u tell us what that is?
15 A
A question on the safety valve header on g
the main steam leads and I don't have the details on it yet.
yy Q
Is that a safoty-related prob 1cm that would 0
4 have to be corrected before the plant could reopen?
g A
It is iny understanding it is.
g i
Q In the-very end of your statement at page
,21 43 it is. pointed cut that ycur testimony covers a wide range 22 cf areas and you are asked whether you are technically f
. qualified as to the details involved.in ench of these activities.
could I ask specifically whether you have any 25 eorwen a nr mn ma. - n u. Lc:nnu.aw a.
- n:.s:muunc. n. sm:.
.,7
,y,,
y3.,
Dunn-cross 91-specific trainin6 or e::perience in se imic analysic?
1 l
O A
No.
2 Q
In piping design?
3 A
No.
4 s.
Q Nuclear engineering?
A I have e::perience in the nuclear field.
How broad a definition you would apply to nuclear engineering I am not too sure.
But I did work at Shippingport.
I have 8
been at Beaver Valley.
I have received training in the nuclear field.
10 I am generally. familiar with the concepts, although I have never made any detailed engineering calculation f
of a design nature.
I am more of-an operating individual than g
I am an enginecring individual.
Q You are not a Registered Engineer?
I A
No, I am not.
Q.
I alsoInow that you are not an attorney,
'out you have sponsored the answer to Interrogatory No.11 in
'!.8 response to the PUC Staff interrogatories dealing with whether any steps have been taken to recover any damages from the s
principal contractor involved.
A That response was prepared under my direction.
23 p
Q Have any additional steps been talten since the time when this answer was prepared or has a decision been u mu:n o uxw:w ne. - o n. s.o m:wn.:.cw x v. - ma"mune. 9r, min
._,.,.m.g,
,,,,,_.y 77 _,
'Dunn-cross 92 l
made. as to whether you will take any legal action against the O.
- 2 principal contractor involved?
3 A
I will take your last question first..
No, there has been no decision as to whether or not we have 4
5 cufficient grounds to pursue legal action against stone a-6 Webster at this point in time.
7 To answer your first question, second, yes, 8
there have been additional steps,taken in that we have retaine' $
9 the services of'an outside consultant who is totally qualified I
10 in the crea of seismic design, pipe analysis, computer codes 11 and what have you, and he, the outside consultant, his firm, 12 is actively reviewing the work which Stone 8 Webster has.done i
13 and also reviewing various code requirements in terms of.
3 14 seismic design, plant design, what' have you.
15 As of this date there has been no report.
}
16 Q
Could you identify who that individual. is?
.17 MR. THOMAS:
We object to that, Your Honor.
,19 That work is being done in connection with the possibility
,19 of bringing an action against Stone & Webster..It is under.
2()
the direction of different counsel.
We do not believe it 21.
contributes to this. proceeding and we object to revealing 22 the name at.this time.
23 THE ADMINISTRATIVE' LNvT JUDGE:
The objection I
f%
24f is sustained.
25!
MR..FEIN:
Your Honor, I~have to exceptlto I
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Dunn-cross 93 1
that objection being sustained.
There is no longer even an D
2 objection in Pennsylvania in the evidentiary field on the basis of work pr oduct or litigation, let alone the names 'of i
S, 4,
consultants hired to' produce that work product.
Those 5
exceptions arc just all gone in Pennsylvania.
6 MR. THOMAS:
Relevancy has not gone.
7 MR. FEIN:
If that was the nature of the-8, objection, I think there should be a whole new ruling, 9
because as I understand you are claiming a privilege to the
-10 name of that person.
11 MR. THOMAS:
I was not claiming privilege 12 in the context of an evidentiary privilege.
I was claiming, i
O 13' number one, that it is not relevant, number two, the'individuni 14 or consulting firm, whoever.it isj has been employed in i
15 connection with a different lawsuit.
He is employed by 16 different counsel than us.
i 17[
I do not think the fact that we have put a
-)
iff name in this record will aid or-assist the Commission in any 19 way in disposing of this proceeding or in discovery.
20I We have had no reports from him and,I-21-don't know the name of the individual myself.
I don't~see i
22 where it has any relevancy to this. proceeding.
l' 23 They are working with Reed,. Smith, Shaw O
2.} l
'and McClay in connection with Stone Fc Webster, not in1 25l connection with.this proceeding.
'I
~
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94
'Dunn-cross 7-I MR. POPOWSICf:
It was. ;just that this g
morning Mr. Dunn testified concerning his understanding as 2
to the propriety of the use of the seismic techniques by 3
j 4
Stone & Webster.
If you have contacted a consultant concern-5 ing that very issue, while it may not be for this case, we 6
would like to know who is providin6 that information to I
7 Duquesne.
6 MR. THOMAS:
Say it again.
I missed you.
I 9
Read back counsel's statement, that last part.
10 11 (The following was read by the reporter:
12 Mr. Popowsky:
We would like to know O
uho is providing that information to Duquecne.)
13 t
14 15 MR. THOMAS:
There is no testimony here by 16 Mr. Dunn that is based upon this other consultant because we 1?
have had no other report.
There is no testimony in this 18 record at all based on the other consultant.
19 MR. POPOWSKY:
Let me clarify that with 20 Mr. Dunn.
21 BY MR. POPOWSICI:
22 Q
Is it correct that your analysis or the 23 testimony you gave this morning concerning your understanding O
of the seismic analysis problem was not based on any consulta 24 25 tion with anyone outside of Duquesne?
tnr: m en r teunrt.. me. - m' n. te:n:~ne.o ?? r.~r. - mnmernco, en.1r.tn.
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Dunn-crocs 95 1
MR. THOMAS:
That is not what you said.
O 2
The witness clearly testified this morning -- he made 3
reference to the testimony of a witnese from the NRC in 4
connection with the. Maine Yankee.
He talked about Duqucane t
5 people.
He talked about NRC pcopic.
6 If you ask him directly, did he base any 7
of his testimony on this other outside consultant, I have no 0
objection to that.
9 MR. POPOWSKY:
Let-me rephrace the question; 10 then.
11 BY MR. FOPOWSKY:
12 Q
In determining your position on the scismic O
13 analysic problem, in preparing thin testimeny, have you con-14 nulted with, A, the percon who yod ctated is working on the 15 seismic in relation to the suit against Stone & Webster, or, 16 B,
17!
A The. answer to that question is no.
18l Q
Havo you conferred with any other outside i
i 19}
concultents ? -
?,0!
A
.I personally have not consulted with any t
j 21!
outside consultants.
I bace my opinion on various reports, I
o 22j 1etters, correspondence I have seen or read, such as the one d
-23I Mr. Thomas'. referenced before, the testimony in the Maine p
?Aff Yankee proceeding.
t 1
25 (
I base it in part on discussions with Stone.
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Dunn-cross 96 s
& Webster in trying to understand what their position is.
.g' O
And specifically a letter which is dated 3
May 25 from Mr. John Landis, Senior Vice-President of Stone &
3, Webster, to Mr. John Arthur, which in turn forwards a letter 4
5) which was sent by Mr. Kennedy, Vice-President of Stone &
Webster to Harold Denton, in which Stone & Webster denies g
7' that there was an error made.
The Stone & Webster position as I understanc
,g.
it -- and my understanding only comes from documents I read g
10 and things which Stone & Webster have said in meetings where I participated -- is that it was not a mistake on their part, 11 12 there was no error, the computer code used was the acceptable O
computer program at the time the design was made, that the 13 14 computer programs that the IEC is,now usin6 and forced us to 15 use, so to speak, are later developments, that there were 20 16 to 22 to 29, some number in there, reactors which were 17-operating at that time, at'the time of the show cause order, gg{
uhich were designed using the same type of computer codes, i
Lo:
and if the IEC shut down Beaver Valley and the other four I
~
20 plants, why didn't they shut down the other 22 reactors which 37 were designed to the same criteria?
i Q
Does either of those letters you mentioned 22 also mention that Stone & Webster developed a new method of 3
O 2N summation of. stress that did nct use the algebraic summation pjl method, and that that was done in aporoximately 1972?
[
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Dunn-cross 97 1
A As I understand it, and again my understand-O 2
ing is based upon documents I read, it is my understanding 3
that this whole process of seismic design has.gone through an 4
evolution starting in the early 1940'c through the 1950's 5
through the 1960's through the 1970's andLtoday, and it is 4
comething which will probably change in the 1980's.
It isla 7
dynamic type of evolution on our ability -- our meaning the 8
industry in general -- to do these type of calculations.
It 9
is an evolutionary thing.
10 Q
Is it your understanding that the Stone.&
11' Webster evolution in 1972 was from a method which used l
12 algebraic summation to a method which did not use algebraic O
15 summation?
14 MR. THCMAS:
Objected to.
There is no 13 proof in this record what Stone & Webster did in 1972.
l 16; MR. POPOWSKY:
He referred to certain letters 17 from Stone & Nebster.
Could we review those at this time?
j 10 MR. THOMAS:
I did not understand his i
19 testimony to be that way, but I understood your. question to 20 assume that the change was made in 1972 and I don't know that 3
l 21!
it was.
a 22
.MR..POFOWSKY:
I was hoping Mr. Dunn would i
~
23f have that'information from the materials he has used..
i e
j 24 THE WITNESS:
I cannot testify'as to what-
)
25 type of computer programa. Stone & Webster may have used in uwxo.c;: a w.n=ne ma. - cr u. s.ca:rwu.aw em.- 1:sur:cuuna, vs. swa
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i Dunn-cross 98 1972, 1973, 1974, what-have you, and how they went through 1
this-transition from one computer code.to another.
2 But there'is evidence in the-record - 'and 3
I testified to it before and ' read it out of the exhibit --
where in 1974. Stone & Webster had to go back and redo the g
seismic calculations for those six safety injection lines,'
6 and when they did it, they had done it using the PSTRESS
,j g
Shock II program, which uses the algebraic summation, which i
p according to Stone & Webster's position was an acceptable code at the time that the plant was designed.
10 BY MR. POPOWSKY:
77 17.
Q c uld y u give us the dates and the authors t
13 of those letters that you refer to for Stone & Webster?
A One letter is dated May 25, 1979 from Mr.
14 15 J hn.Landis to Mr. John Arthur and the Stone & Webster letter' to Mr. Lenton, I don't see a date on it, but I have t6 escume g
it was sent about the same time.
g Essentially it sets forth Stone & Webster's g
gg' position on this whole question.
BY MR. FEIN:
20 Q
Who is the author of that letter?
Was that.
gg als J hn Landis?
22 A
No, Mr. Kennedy, Vice-President.
g f
g BY MR. POPOUSKY:
25 Q
Is that a letter.of May 18, 19797 s cmaneu a uc.=v t.. m. - w x.1.om:ws1.1.o.:wr~. - n.v.msos.w, n. m 1.n =
l
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^
^ '
l Dunn-dross
- 99 l
1(
A I do not see a date on this particular copy O.
-2' of the letter.
3 THE ADMINISTRATIVE LAW JUDGE:
Let's go 4
off the record for a moment.
.5 (Diccucsion off the record.)
6-t.
7; BY MR. POPOWSKY:
l 8l Q
Can I ask you to refer to page 4 of the.
' j 9
letter from --
10 THE ADMINISTRATIVE LAW JUDGE:
Mr. Popowsky,
- i 11 before you get into your next quection, the record should shot 12 that during our off-the-record discussion the letter which D
you have is identbcal to the one the witness had previously D
14 referred to and the date on that l'ctter is May 18, 1979 15 MR. POPOWSKY:
That is correct.
16; BY MR. POPOWSKY:
17l Q
Mr. Dunn, this is a letter from Mr. W. J.
18'l L. Kennedy, Vice-President of Stone & Webster Engineering 19, Corporation, to Mr. Harold Denton, Director of the Office of 20j Nuclear Reactor Regulation?
31i A
Yes.
22 Q
Can you look at page 4 of that letter, the.
I,3 third paragraph..Doeu that not state-that in 1972 and'1973 o
tie. started using-new computer programs which introduced a I
24
.)
25 L number of changes including substitution of a modified sque.re l
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100 Dunn-cross t
t root of the sum of the squares procedure for algebraic l
g l
I summation to combine intramodal forces?
2 A
That is what it says.
3 Q
Was Duquesne, to your knowledge, informed of those new computer programs in 1972 and 1973?
g A
I answered that question earlier.
I do not 6
7 know.
MR. THOMAS:
If Your Honor pleases, I would
,a like to object to this type of cross-examination.
Unless p
that letter shows that a new computer code was tied into the g
design w rk for this type of ' station, and Stone & Webster is 11 the engineer / constructor, and if they were using it, then f
12 i
O they would have used it on the station, I would assume, but J,3 p;
it seems to me that Mr. Popowsky gow is possibly taking it
.h j
15 out of context.
MR. POPOWSKY:
I would be glad to,have the 16
' whole letter introduced into evidence.
gj MR. THOMAS:
I don't know what the purpose 28 1p of the letter is.
I would like to at least have a. chance to
, c.
see it.
q MR. POPOWSKY:
That is all the questions 21 I
22l I have at this time.
Thank you.
THE ADMINISTRATIVE LAW JUDGE:
Let8 3 60 i
23 O
ff the record for a moment.
2'}
(Discussion off the record.)
25 idO* 7Dt.C A 0 PthM:t/1, :!fC. - 27 IL LCC' WILLo?! INl".= !!A*,;t3pJ;;c, pA g3 3;;
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-Dunn-crocs 101 THE ADMINISTRATIVE LAW JUDGE:
We will take 1
P a five-minute recess.
2 3
(Short recess.)
4 CLIFFORD N. DUNN, resumed.
5 6
BY MR. FEIN:
7 Q
Mr. Dunn, prior 'to the. break you had
,8 referred to the fact that the seismic designing has gone 9
through an evolutionary stage.
I am not very interested in 10 the evolution back in these 1940's and 1950's, but starting 11 with the year 1968 can you tell me -- and you don't have to yg tell me what the design was or the changes -- but can you O
just tell me when design changes were made, to your under-13 14 standins.
15 A
I cannot answer your question, Mr. Fein.
16' I am not that familiar with the details of the evolution of 17 the art of scismic design.
~
gg Q
Do you know when Stone & Webster's seismic 19 designs have changed from 1968. to the present?
l l
20 A
I don't recall specifically, no.
I have 31 not tried to go to that degree of detail when reading 22 documents.
73 Q
Do you'know when the NRC's standards for.
O 2,}
seismic designin6 have changed, if they have changed since 25ll 19687 l
I
- f.* 0t!ROAOJ2 o f4ARtt!E. IMO. - :".5" 17. L3Str.*TtL' es ' ?.'it? - HA7;t!Mtf7,0. PA. i?'1;*
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pg..
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]
Dunn-cross 102
~
f f
y' A
The only document I am familiar with, but D
I have not read it, ic the Regulatory Guide 192 which was 3
issued December 1974.
Again, as I have indicated in answer 3
to an earlier question, I personally have. not reviewed that j,
i 5-regulatory guide.
6 Q
You would not know if their standards for 7
seismic designs conform to the seismic design being used by 8
Stone Ec Webster for Beaver Valley No. 1 at that time?'
s A
It is my understanding, based upon 10 documents I have read, that Beaver Valley was essentially 11 designed to the types of seismic analysis which was the state 1
12' of the art in the 1972-1973 periods.
l f
13 There were a number of plants, I have read 14 numbers like 20, 22 as high as 29,' I am talking about nuclest 15 plants, which were designed and licensed and were operating 4
Jg at the time the shou cause order was issued and the seismic 17 design calculations were based upon the same type of computer; gg code that was in contention in the Beaver Valley show cause 1g' hearing, namely the PSTRESS Shock II.
20 Q.
Is the answer to my question that you -
{
21 don't know if it conforms to the December 19714 guide of-the NRC or that it does conform to it or that it does not conform 22 py; y to it?
'A Thac is one of the questions which'I would 2.};
1 25{
expect to receive.'an answer from this outside consultant'we r-
. umannen e u=c::n v - = ::. t.acr.mwn an. ~ naucuane, n sr m 3
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Dunn-cross 103 I
alluded to earlier.
They are the ones who are the experts.
b 2,
They are the ones doing the research.
3 Q
You don't know personally?
/g A
No, I do not.
I am not a seismic design 5
expert.
6 Q
Are you familiar with the desi6n and the i
7 design stages for Beaver Valley No. l?
8 A
No.
9 Q
I take it you would not knou at what point 10 L in time that construction would have begun on the design 11 3 using Stone & Webster's seismic stress analysis,, construction 12 at that point could not have been changed in order to change O
13 design for a differont seismic stress analysis?
1 l'f A
No, I would not 'knon the answer to that 15 question.
16:
Q Who would know that?
17 A
I den't'know.
18 MR. THOMAS:
You can probably get the date 1S J
of the Stone & Weboter centract.
I don't recall the date, 20 but we'did give it to the judge in the rate proceeding.
21 I think you looked at it.
I 22l MR. FEIN:
I have looked at it.
I am not t
23l sure the contract would tell us when we reached that point e'
D 24l cf no return on changing the design.
I 25' MR. THOMAS:
But it would give you a bench
?
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. Dunn~ cross:
104 1
mark to start from.
-O l
2 BY MR. FEIN:
l 3
Q When you were informed by the NRC that you 4
would have to shut down because of the error in.the scismic 5
stress analysis, what kind of analysis-of your plant did you-
- i I
6 make to ascertain what other repairs or modifications could 7
de made to Beaver Valley-1 during that shutdown period?
0 A
First of all, I don't think it has been 9
cotablished that there was an error made at this point in 10 time.
I am not convinced of that.
11 4
I was using that in the terminology of the i
12 reason for NRC shutting you down.
F U
A The reason was not necessarily it.was an J
I 4^j error, as I understand it.
The' reason was there was a 15l discropancy between two computer codes which were essentially I
I 10 making the same type'of calculation and the anawers were U!
different by a significant amount, and therefore since thero l
18 was a questien as to which one is right and which one wrong,
't 19 or to put it another uay, which one was conservative and I
2 which one was more conservativo, in view of the uncertainty 1
21!. at that time the NRC made a determination to shut down not 27-.-
only Deaver Yn11cy but also four other plants at the same t
M:
time until that safety question could be resolved.
D 4l.
Q.
.Aside from the computer code discrepancy, 4
i actual' plant modifications were made-as a result of the new namuewamw.. rue. - ss u. s.ocr>m.s.vw xm.. v.w wremc, n. sn sc
...%.,~_..
~,,. _.,
,y.
_,_ Dunn-cros.s 105 1'
computer code, were they not?
O 2:
.A As I indicated in the testimony, as a 3
result of all this reanalysis work, which was rather extensive 4 and covered a significant portion of the plant, there was only 5{ a need to make very minor modifications to.the Beaver Valley 6
plant.
7 The numbers are in my testimony and as I
.8 recall them we had to add three snubber type supports and to 9
modify I belicve it was eight hangers, very minor in terms of f
10 the scope of the work being performed.
11 I believe you can find that detail in 12 Duquesne Light Exhibit F which is the NRC letter of August i
O i
13 8 which allowed us to return to power.
I 14 Q
Is that the kind' of work, the work on the 15 three snubber supports and the eight hangers, could that work i
16 have been done during the construction of Beaver Valley No. li 171 A
Could you repeat the question?
l 18.
Q Could the modifications to the three 19 anubber supports and the eight hangers have been done during 20 the construction of Beaver valloy No. 17 3
21 A
If you were as amart in 1974 as you were 22 in 1979 and had taken advantage of new computer techniques 33L which were developed as 'a result of this total invectigaticn O
2't ;
for all plants, then perhaps you could have made the design 25 change then.
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106 Dunn-cross But you were not designing to the some type 1
2 of computer codos and you wore not even designing to some of 7
3 the same criteria upon which the reevaluation was based in 4
1979 5
4 If I remember from your earlier testimony f
of about five minutes ago you stated that you did not know 7
when the last point in time was that modifications could have
.S been made during the construction period.
Where did you get 9
the year 1974 in your statement Just a minute ago?
10 A
I an talking about the construction period 11 in general, 1971, 1972, 1973 1974 was pretty much a judgment 12-as to what would have been going on at the plant at that O
A3 particular point in time.
14' You were still a. year and a half, almost a 15 year away from operation.
You would have been to the point 16 where the turbine walls are built and the generator is on its t
17 foundation and all the larger components are essentially put 13; on their foundation.
LC Now it becomes a matter of running the i
20 pipes, the conduit, the controls, the communication, what 21 have you.
It is a judgment.
22 Q
You don't mean to say that the snubber i
23 supports and the hangers could not have been modified in O
24 1975 or 1976, do you?
25!
A No.
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Dunn'-cross 107
.1 1
I i
Q Now.other than waiting to see what the g
N 2,
results - of the roanalysis would be ' after March 13,1979, h
3 what other types of work, if any, were being done on Beaver 4
Valley during the shutdown period?
5 MR. THOMAS:
During the March 13 shutdown?
6 MR.-FEIN:
Yes.
y THE WITNESS:
I refer you to Tablo IV, Mr.
6 Fein.
I tried to list there some of the major activities 9
which occurred during that period in terms of maintenance, 10 inspections --
11 BY MR. THOMAS:
12, Q
That is Table IV attached to your testimony'i N
I 13' A
Yes, it is.
14 BY MR. FEIN:
15 Q
was any of the work that was done durins 36 the shutdown following. March 13 similar. to any of the work 17 donc during the second shutdown?
gg A
What do you menn by the second shutdown?
gg
.Q The shutdown that came after December of-1 H
20 1979-H Yes,someoftheseactivitiesspannedboth
/
j 21 A
22 of these outages such as-the work assoc'inted with NRC Bulletir!
m 33[ 79-02,-79-14.
i O
'Q Why wasa 't all thei. work completed - during I
24 25 the first shutdown?
When I use.the terms, the first shutdoun rmmer.en a mnow. rne. - r: u. r.oneme. ort m:. - remaneno, a sma 4..---
s.
Dunn-cross 108 t
would be the March chutdown, the second shutdown would bc the 1
1 f
December shutdown.
E' i
A To use 79-02 and 79-14 as an. example, we 3
did a sufficient amount of the work so as to demonstrate to 4
the NRC that we did not have a significant problem in terms g
of the as-built condition of our pipe supports and base plate 4
design, with regard to 79-02, and - we did not have significant 7
l
,g problems and differences between as-built drawings, so to gl speak, and as-built conditions as. reflected in 79-14.
gg I can refer you to Duquesne Light Exhibit 77 H and specifically the letters which I signed to the NRC in 12 response to those bulletins which justified our return to 4
O operation following the work we did.in connection with the~
g3 g
show'cause order and with a commitment to complete this work l
g during the refueling outage.
Q The work that you did in complying with g
NRC 79-02 or 79-14 caused you to remain shut down longer than' 37 you would' have boon shut down just for the seismic reanalysis i g
gg during the first shutdoun?
A No.
gg
=
Q Would your testimony be that you went bach 21 L into operation after the first shutdown as soon as possible
,,3 g
after correcting.for the_ seismic reanalysis and that no other; O
3p work caused 'you to stay s' hut down any longer than. you would 25 have been just for the seismic' reanalysis?
O umnen a nuous. cte. - mtAacw:.uo :wn. - nzusauns. n. m m -
. - ~. _
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Dunn-cross 109 I
A Yec.
g 3
Q For the first shutdown the event triggering, 3
the shutdown was the requirement of the seismic reenalysis, the event triggering the close of that shutdown period was 4
5 the completion of the seismic reanalysis.
Now for the second 6
A You are right but let me put it in context.
7 The reason why the show cause order was terminated was the
~
8 fact that we received a letter from the NRC lifting the shew 9
cause order which in Duquesne Light Exhibit F.
10 You were able to go back on line immediate11 11 after receiving that letter?
l 12 A
As indicated in my testimony, the show cause O
13' order is dated August 8th, at which time we began to heat up 14 the plant and the unit was synchropized August 17 15 BY MR. THOMAS:
16 Q
That' is the letter lifting the show cause 17' order?
18 A
The letter of August 8 lifted the show causc 19-order.
We at that time were setting at about a 190 degree 20 temperaturo in the reactor coolant system.
We did not allow 21 it to come above 200 until this order was lifted.
Once.it 22 was lifted the plant started to heat up and was cynchronized l;
i l
23 on August 17
)
24 BY PJt. FEIN:
l 25:
Q Was there any one event that would have s:: mnACM & mar.r1?S. ;t C. - 3 N. LOCKMLI.CW A*f0. - Hl.t:ntWl3C. ?A. 2NO -
n
.e-~..-
Dunn-cross 110 c
y, triggered the cecond shutdown and would that came event i
2 trigger the end of the second shutdoun't i
3 A
By the second shutdown do you mean --
/,
Q The present.
5 A
The present, it was triggered by the need 6
to refuel.
7 Q
What will trigger the end of that shutdown?
,8 A
Uhenever we complete all of the work wo are 9
committed or required to do by the IEC, cpecifically, completi on 10 of the work IEC Bulletin 79-02, 79-14, complete the work 11 e.ssociated with the turbine replacement, which I don 2t think 12 would be the critical path, and completion of the work O
13 "
casociated with the Three Mile Island lessons learned 14 requirements which must be impicmented on or before December 15 31, 1979 or January 1, 1980 for plants which were operating, 16 Q
If I understand your testimony correctly, 17 even if you had not had to refuel thia year, you would have 18 had to caut the plant down for completion of the 79-14 and 19 79-02 requirements?
20 A
Not quite that way, Mr. Fein.
We made a 21 commitment to complete this work during the refueling period'.
3 7,2 Q
If you were just refueling beginning in
~
?J December, how long woulo that have taken?
24 A
As I indicate in my testimony, if there was 25 a norn:a1 rsfueling outage, and it was the third or fourth L
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Dunn-cros s 111 K
1 time we had gone through thic particular operation, and 2
0 2'
recognizing the need te do certain in-service inspections 3
such as radiogrtsphing some welds and doing routine maintenance 4
my testimony indicates the refueling period would be about 5
eight to ten weeks.
6 Q
This is'a first refueling so I take it --
7 A
The first refueling, as I indicate in my E
testimony, usually takes a little bit longer, and as was 9
pointed out this morning, a normal first refueling would 10 involve the warranty inspection of the turbine generator.
11 In our particular case we took advantage 12 of the transformer failure outa6e in order to do that work U
so we would not have to do the warranty inspection on the 14l turbine generator during the firstirefueling.
15 Normally the first refueling is a major M
activity.
As I indicate in my testimony, we had identified 17 e nunfoor of prob 1can with the ' plant, problems meaning those 18 things associated with operability or maintainability of the 19 plant, not safety questions.
You take advantage of the first 20 refueling to nake improvements in the plant so as to minimize 31:
such problems.
22 4
Hou many weeta do you estimate your first 33 refueling would have taken given the fact tha' you did not c
O 24' have a warranty inspection and given the fact I am going to 25 give you, that you did not have to do the work to cotaply with i
m:nnucu o mecau.. me. n n. tec:c:..aw c - um tune, n. um
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Dunn-cross 112 I
any NRC requirements such as 79-14 or 79-02 during the g
refueling?
3 A
I would say about ten weeks and that is reflected in answers to questions I had earlier this morning 1
5' on Table I attached to my testimony.
6 4
Nc3 let's assume that you were shuttin5 7
down Beaver valley 1 to comply witil all of the NRC requirement s 6
that you are now required to comply with, but that you did 9
not have to refuel.
How long would you estimate that that 10 shutdown period would bo?
11 A
If I did not do refueling?
i 12 Q
Yes.
O 13 A
About the same length of time as we are 14 projecting now.
Refueling is already complete.
So if I l
15 did not nave to refuel I would still have the same workload 16 in terms of the critical path items which have to be 17 cccompliched.
The refueling was not a major task during 18 this outage.
19?
4 You are saying it would be about a six-20'.
months' shutdown?
l 21 A
Roughly the same as we are now estimatin6 i
1 7.2 Q
Six to seven months?
23 A
Six to seven months.
Presen' projection c
O 24 for return to power is July 20 or 22.
Heuever, as I indicate 25 in my tostimony that can be affected by.a number of' variables.
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Dunn-cross 113' f-5 It is not firm.
O I
2 Q
I believe you stated -- and if I have mis-3 heard you, please correct me -- that were it'not for the 4
refueling you may not have shut down during.this period in i
~5 order to comply with these NRC requiremento, is that correct?
6 A
Would you repeat the question?
7 (Question read,)
8 THE WITNESS:
I can't say that is true, 9
Mr. Fein, because in making these decisions with the NRC, and 10.
the NRC understanding our position and what we have done and c
11 our justification for continued operation, I'think the relief i,
12 they gave us was premised on the fact that we did make these j
13 commitments to do it during refueling and we were able to do 14 sufficient amount of work during an earlier outage'to justify i
15 continued operations on an interim basis to the NRC.
16 EY MR. F3IN:
17 Q
To your knowledge, and to this point in 18 time, arc there any nuclear plants of a similar design to l
19 Eeavor Valley 1 that have not shut down yet to comply with l
i' 20, 79-14 and 79-02 or any of these other bulletins listed on 21 i pages 20 and 21?
4 22 A
I have not gone through the records to l
23 try to determine why all plants are down.
I again'use the O
24 Gray Book, if I may use that term one more time, as the source j
25 of my information.
A number of the statenents, contained in I
s xr.ucx a runmus mc. - ny u. s.ocxvm. tow me.- manenuno, n. m se -
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Dunn-cross 114 y
my direct testimony are based upon information I gleaned, so g
to speak, from the Gray Book.
3 For instance, on page 23 of my direct 4
testimony and going through page 24 I give examples of a 5
number of plants which are down because of refueling and NRC 6
requirements.
7 For example, the'very first one I S
identified is the Farley No. 1 unit of Alabama Power Company 9,
which was shut down March 8, no less, 1979 for refueling, 10 and NRC Bulletin 79-02.
It di.d not return to operation.until 11 Notrember 5
}
12 The Oconee No. 3 unit was down for refueline 13 in April and other reasons.
It says in my testimony from i
l 14 July 1 the station was on a forced, shutdown for inspection 15 requirements of NRC Bulletin 79-02 and 79-14, the same way 16 we are.
1 17 Q
Is it your understanding from your dealings 1;3 with NRC and your knowledge of other power plants similar to J,9 yours that when these bulletins do come out, and new require-20 ments are imposed on nuclear plant operators by the NRC, that i
21 the HRC expects those requirements to be complied with during 22 the next refueling period of a plant?
a 23 A
No, the requirements may be such that you O
must do something within 30 days, 60 days, 90 daya.
)
24 25 Q
I meant at least by the next refueling peri Ld.
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1 A
No, not necessarily.
I think they make a 2
i determination on each 'and every case as to what is a reaconabi r 3
time for the licensee to evaluate the information supplied to 4
them in the bulletin and make a proper reopense, which is 5
normally a 20 or 30-day written response to the bulletin, 0
and for them to make some evaluation as to what is appropriate 7
action.
0 Q
Even though all the requirements on pages 9
20 and 21 were for so.foty purposes, semo of these requirements 3O! were not co necessary that plants could not have remained in 11' operation out of compliance with those requirements, is that 12 correct?
13 '
A Would you read the question back?
(Question rbad.)
U THE WITNESS:
As I indicated in an answer 16 to a question this morning, some parts of the work associated 17l sith NRC Bulletins 79-02 and 79-11 i
4 can be done with the plant,
18, operating.
There are certain parts of the plant which are A9 necessible while the plant is operating and therefore you can 20 go in and verify as-b,uilt conditions.
21 By the same token, there are parts 'of the i
22 plant which are inaccessible while the plant is operating and J
can only be dono while the plant is shut down.
O f
2f BY MR. FEIN:
1 oJ Q
If I understood your testimony of e. bout ton l'
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Dunn-cross 116 p
j' minutos ago correctly, there seemed to be some trepidation O
3 on your part as to whether you will be able to really go back 3
into operation on July 22, 1980.
What could possibly cause 4
you not to be able to begin operation at that timo?
g A
My concern at this point. in time is the 6
work associated with the Three Mile Island lessens learned 1
7 requirements imposed by the imC on all nuclear reactor plants.
8 Whether or not we can get the material in time, whether or not p
we can complete the on61neering, the scope of work involved 10 in making these modifications -- many of these things are not l
11 completely defined at this point in time, although we are very 12 cetive at it.
D 13 What attitude the NRC may take when we' get 14 to that point in time and we are, say, finished with all but 15 one, I don't know.
16 Q
Isn't it true that some plants have not i
17 cven shut down yet that are not in compliance with those laf lessons learned requirements?
19 A
Sece are still operating on the basis that 20 the NRC has made a determination that the licensee has made 21-an honesc effort to comply with the requirements; however the 27, material cannot be delivered for 60 days and therefore they 23 permit them to operate, say,.for the 60-day period at which O
time they are going to be required to shut down within 30 24 l
25 days to nake the modification.
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t Dunn-cross 117-1 So there there are juct reasons for not 2
complying with some of these requirements the NRC has choun 3
in some cases a degree of leniency.
4 Q
Has all the work been completed at this 5
point on the refueling?
0 A
Yes.
7 Q
Does any further work need to be done with 0
respect to any of the other requirements or the requirements 9
that you are complying with that is not dependent en the 10 delivery of materials?
11 MR. THOMAS:
Read the question back, please.
12 THE WITNESS:
As of this point in time the O
l 13 most serious materir.1 delivery prob 1cm I know of is that l
i 14 associated with five chemical feed pumps.
These are positive D
displacement pumps from Milton Roy which are needed as part 16 of the modification to the safety injection system as we 17 discussed earlier.
The delivery date I have on these now 18 is June 15, 1980.
19 It is a very tight schedule.
We are still j
20 trying to improve the schedule.
We have authorized the 21 company to work overtime if necessary to get these components 22 nanufactured and delivered.
2 23 The actual limiting thing is not the pumps I
O 24 themselves but the motor that drives the pumps.
Again you M
are talking about Category One type material which must have racunnw, n w.nmw sm. w n. s.acam..cw w. -. n.wo >ww. n. ws w -
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.c Dunn-cross 118-all the documentation starting with where the material was g
3j mined and how it was processed and all the safety requiremento 3
which it must meet.
What we are doing is doing as much of the 4
5 construction work as possible, such as running piping, such 6
as running instrumentation, running controls, building the 7
base plates, and doing everything so that by June 15 the only 6
thing remaining to be done is put the pump in place, hook it 9
up pipe-wise, hook it up electrical-wise, hook it up I
10 l, instrumentation-wise, do the checkin6, testirig out, and start 11 the plant up.
12 BY MR. FEIN:
O 13 Q
I notico on page 5 of Exhibit K under 14 Item A99, plant start-up, that the, plant is due to be 15' ntarted up during the week of May 12, is that correct?
That is when we beGin our otart-up activitik 1(3 A
s.
17 Q
When do you plan to actually be supplying 13 pcuer to your customers from that plant?
19 A
July 22 by this schedule.
You must 7.0 :
roccgnizo plant start-up does not merely mean turning up 21, heat, so to speak.
It is essentially going into that plant j
a j
y l
j p.2,
and verifying tho. valve status, the instrument statue of 23) overy valve, every control in the plant.
I O
2/
q Taking a look at page 'T of that came 25 exhibit, do you expect to complete Item 105 on time?
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Dunn-cross 119 1
A This ags.in is part of this overall singic
~
Z problem, the modifications. associated with the lou head safety 3
injection pump problem, 4'
As I indicated earlier, the critical path 5'
could be this particular project.
The thing that is of concern I
at this point in time is the delivery of those chemical feed 7
pumps.
Assuming the chemical feed pumps can be delivered at 0
least by June 15 or earlier, if possible, I do e::pect to 9
complete that particular task on schedule.
10 Q
I am not sure I understand, since on 11 schedule according to the way I read that would be somewhere 12 between the week of April 14 and the week of April 20.
D A
This is but one segment of that total job.
N Q
I am just asking about that segment.
Will M
that be completed?
M A
I have every reason to believe that it will.
17 I recognize the exhibit says paper.not on sito, partial M
material on site, but those are problems which are identified M, through our daily, weekly, monthly. meetings, being aware of i
20j the problem, and somebody has the problem to expedite matters 2N so as to secure the materials so as to complete the engineerir g,
~
i 22 so as tci get the paper.
M 4
What' does it mean.by paper not on site?
O 24 A'
Documentation in forms cf drawings, material
~
F 25 specificationa, quality assurance documents,' vendors' records tiennnAcn a muev.w inc - cy M. t.oc:exru.ovi Aw::,- nan::rcovie s, p;. m c
~
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Dunn-cross 120 t
I y, l cc to manufacturing or any documentation the vendor must 2
supply in' order to satisfy our quality assurance program 3
test data..
1 4
4 In other words, if all the work has been 5
done on it, it is quite possible that completion could be 6
delayed just because you people would not be able to test 7
whether the product they got was what they had contracted
.8 for, if the paper was not on the site?
9 A
Would you repeat the question?
10 (Questicnread.)
11' THE WITNESS:
This' is a risk you run anytim5 12 you receive material in.
You issue a purchase order, the 13 purchase order contains certain quality assurance requiremente,
14 in terms of paper, when the material is received it gets a i
15 receipt inspection which verifics that what we ordered we gotj L
16 both in terms of the harduare as well as the paperuork; if we 17 do not have the documentation, the material is put in hold.
18 BY MR. FEIN:
J.9 Q
Whose responsibility is it to see that the 20j documentation is on the site?
21 A
The initial responsibility would fall to 22 the people who, perform the receipt inspection.
They will 23!
have a copy of the purchase order which will say this is ubat i
O 24 I ordered and they will ~ open up the carton and say this is -
25 what I got.
i
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Dunn-cross 121 y-.
1 Q
We don't have to 6ct that specific.
What 2
I really meant is,'is it Duquesne Light's responsibility or 3
the vendor's responsibility?
4 A
Duquesne Light's responsibility.
We are 5
the operator.
0 Q
Do you know what the reasons might be for 7
the documents not. cing on the site for items such as 105, 8
130, and there are some others, 1357 E
A At this particular point in time?
10 Q
Yes.
11 A
No, because again the documents -- when I 12 say papers -- they could also be referring to drawings needed O
D l
by construction or vondor books or any number of 101 type of If documents which are necessary to support a nuclear operation.
15 Q
I take it that even though that might be a 16 deficiency at this point in time, the documents are not actual ly 17]
necessary until it would become time to check the actual 18 installation of the product?
E A
I would have to go back and refer to 20 specifics of that particular onc.
21 Q
Do you know of any instances during this M
second shutdown at Beaver Valley No. 1 where one of theco 73
- various projects the completion date has been deldyed because O
documents were not on the.sice at the time they yere necessary ?
2'5l A
I don't have specific information on it, I
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Dunn-cross 122 1
every one, Mr. Foin.
Many of these projects and taska are 7,
rather short in duration and the fact that they are not done 3
at this particular instant in time does not necessarily mean s}
it will affect the overall outage time.
5 I fully recognize and have to guard against 6
the fact that if I have 100 tasks, it may be relatively easy 7
to do them in ten weeks doing ten per week, but by the same 8
token, I can't do a hundred tasks in one' wock.
9 So there is a requirement on my part and on 10 the people specifically responsible for the work to make sure 11 everything doesn't end up being scheduled in the last week 12 of the outage.
O 13 Q
You have had numerous problems at Beaver 14' Valley No. 1 since June of 1976.
Have any of your problems 15 been caused because your employees did not make' the adequate 16 checks on what was being installed at Beaver. Valley No. l?
17 A
Not to my knowledge.
That is a. judgment 18 question, thou6h.
19 Q
I realize that.
Earlier this afternoon you.
20 gave what I considered to be somewhat of a philosophical v
21 answer when you discuused the fact that ratepayers should 22 pay for the additional cost of power when a nuclear plant 23 is dcun because they received the benefits when the nuclear O
I 24 plant was up.
25'i Has Duquesne 7;ight made any analysis 3-to f.1 ;;2inG " C7; 4 f.1N*mi?.f I C. = n*/ ff. LCCh*WILI.CY1 XJf!. ~ U.!L'tf LI:'.f00. ?!-. t!*T T P. -
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Dunn-croco 123 l
l' your kno11 edge, as to what the capacity factor would have to 2
be at Beaver Valley No.1 for the ratepaycrs to receive an 3
absolute advantage of Beaver Valley 1 being in operation?
4 This is weighing down time verus up time.
5 A
I am not aware of any such studiec.
I~
6 personally have not made them.
7 Q
Do you know of any such studies in the 0
nuclear power field?
9 A
No.
10 Q
I can't put my finger on it, but somewhere 11 in your testimony you discuss what the cost to consumers 12 would be for the first shutdown of Beaver Valley 1.
Would D
13 the cost be the same for the second shutdown?
N A
We have projected costs for the second 15 ohutdown under two assumptions, and I will refer you to the I
16 information contained on Table I attached to my testimony.
17 This information was supplied in response to a FUC order.
10 Q
I am not cure I understand the difference 19 between the first and second columns.
20 A
I will explain them again.
l 21 MR. THOMAS:
It was explained earlier but 1^
2%
if you want it explained, go ahead.
M THE WITHESS:
Column 1 essentially is a i
f 24 projection on costs associated with the net energy clause ll 25 for caleadar yes.r 1979 by months, as we now expect them to l*
t
- e. mace a rwimw rum - rw n..eceen.:.ow r.a:. - r.mmsm.me, ra, e>str.
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9
- s
- g be, boced npen' the fact that Der /cr Valley wcc out at the
.p beginning of the year and is es:pocted, t'o return to po: er m
s y,L cperation on July 20, 1980, that is an essumption used.in-4 this calculation.
i 3p BY THE ADMINISTRATIVE LAW JUDGE:
6, Q
Exenae me, Mr. Dunn.
Whe.t table ar.o yev 7,
referring to?'
i Bj A
Table I.
r 9j Q
You said the calendar year 1979 t
l 10 A
Did I?
i y,,t, l 4
Yea.
I
?.7, j A
I wu sorry, calendar year 1980.
s..
1.3 !
Q Well, it isn't even the calendar year 19P0, O
t
- ei is it?
e
- 5.
A Well, it is, for bhe 12 rt.cnths.
I l
Ki; IE. THOMAS:
It is supposed to be.
?.'i-THE ADMIHISTRAT.UIE LAW' JUDGE:
It scys i.a, Em.':*er Vo1*cy off 1-1-00 through T 20.
J i
'? I MS. ARKSTRONG:
Yoir Henor3 I believe if you 3i 1cok down the Icft-hand column you will cee the 12 monthe
- n. ended Decetiber 31, 1980, the caption at th? top of the cclumn J.7., nocely deccribes the on -and off pericdc of time for Beavcr 23 i Valley.
i
'M
?.fil. T6.CIMS :
But 'e-cry month of the yenr in
]
O w ! ahves..
i
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TU.E ADMINXSTBATIVE IAW JUDGE?
All vir;ht, I 5
I
' see it.
3 THE WITNESS:
i'hr! 'second column, Mr. Fein, 4
essentially reflecto a condition whereby Eeaver Valley cuta6C 5
would have been limited strictly'to what 71ould bare been 4
connidered a first refueling, in other uceds, it did cor.c off e
i l
7 Decettber 1,1979 cnd did return to power on February -2'4, 1980 3 9' and tha difference between the two columns represents the I
l 9
increnaed costs to the customers, so to speak, thrcugh ths 1
10 j opcynt an of the ne'.; energy clause in order to comply with I',i NRC reluirements to make improvements in th'e safety m9xsion.
I U.11 of the pinnt.
w I
1! f BY ' 14R. FEIN :
4 O
,1 1.4 f o,
Then the figure for January for both colvmns
- 1 9
y y l' and 2, that ';ould be your toto.3. - --
j l
IGl MR. FEIN:
Strike the quentien.
'S'.
THE WITIESS:
Under both asenptions for the i
)
1.G month :f Jannesy that the unit is off, tihether it is' off for s.i ; refuelins or tihether it 1s off for refueling plus s.11 the 20i other recuiremnha which ;Je truct satisfy 3 co there is no M!111 differance in the cost projection for January 1900 uc9er t,ha
.i i
I 7.7. ! trio a s s umptiens.
M )P BY TIG ADilIHISIBitTflB IAW JUCGE:
4 T'ie.t second column is fcr an eight-wcek pericq.
O i
V A-ht
.i.t nso recogn.u es Vm W.ct t!v.t the unit [
i' uomme: o w:rv1. :::. - n n. r.eci:vev.m t " --.nr.n ricer. v. m m -.
1
+
p-
+%
- ' - wwgaos.n -
og._,
- y.. wo escoessu8*r*
J;**P**.***'* r 8 *;7W*'*'"'*W*
=,r,.
1.,
.c
.... _.. D r a.n_-c r.o.a c..
~ -......
.-.... _..t 26.-
. t. had cir.t de;n DocWnr 1979 for ref rclinr,.
.+ g Il 4
So there is no conf.'iet.'ith thic figtue a.nd 7
i-e, ; yowe iudice. tion in previous testi' tony that norml refuelir5
- I l
g> i time rac ten wceka7 l
1
(
A Roughly ten treeks for a firnt refueling.
.r t.
6-I also define a first refueling to include a j
- I.1arranty inapcetion which is not a conditien here.
t j
3 SY la. THOMAS:
A lt 4
9p Q
lt'. Dunn, to clarify it further, the reason d
4 the nc2bers fer February differ in the two columna is in the y
- 9. ; ! cecond coltrra it anbicipaten that the refueling tronld ba're I
been over and the unit back on line for fivo --
3.2
- a..n.
MR. FEIN:
Four dayn.
4..l IG. THCHAS:
Four dayc, yeo.
l.
t
.y j THE WITNESS:
Firra days.
g;!
MR. THOMAS:
Yec, i'ive dayc, leap year.
.n.. '
'IHE WITIESS:
Yec, that to correct.
i M i's. FEni:
ye
'o' 4
All right, would yw turr. to page 14 of
.;c ;
Statw.:nt Mo.1 and thic 'pauld bc quef;ien nunber 10.
LMkiru; i
i; cb the fiBurcs fo.c Jan'cary and at least tbc first 24 day.c of
,37, Februa:cy for 1980 no uculd not be abic to accortaic frca y
T.Dic 'i: N!r:.. the increeced cnat would be during th?.t verJ ed l
- j. g.
of M 1ay; Mi+.b E u rer Valley off would uc?
3 O
- .3 j a
hoM rpon the infernati.n i.n bho bable 1
- m..
L
- - - w:n. r.m a : um s. c:c.
..7 rt. t.oc.cm..w-v.-
4- :n c. -.
1 A
et m e M.-*
-MMMQ% e'-
- ymDe
- P 6g g $.g ge tillt.M.9s49 4h P
W$
"W$-
l
l
~-n.
u.--..,.-
. _..' J.27..
l
- =
D o
..._..._. ~..... _..._ -.- u.n.a-cr.oc-.
. _. - -.. _. - -~....._.~.- ----~
,.' directly, no, you cannob get ' the utreer.
But goir.g; to the
'. y information choun on pcge li. of my direct testimony in-anntrer t
p A.
16, we made' en cotinato that increased costs associoted with t
the net energy claune, that is, the 501 part which ic cyplicabO.e
, 555, less demand charge,.iunt lookirg 5
at these coats alonc, it looks like on the average during the 3
L outage casociated with the shcw cause order it wen about 7
$123,000 a day.
n Mr. Fein, you can do the'same type of a,
calculations frca Table I.
If you take the increcaed cocta g
divided by the numbar of days you vill ccme out to the same gl number, cro.n though the calculationn ucre made by different i
g, l people using entirely different techniques.
One is after the O
I g l fact, for instance, and onc in a pro,jection.
...?
E I understand th$ but.for the fir::t 55 days s.o gl of 1969 we don't have the increased costo, do uc, on Tnble I?
g,7 l A
There is no increened cost under the.iwo i
gl eAnuaptions becauno the plant ha.d to shut dann for refueling.
i (p j 0,
I understand that, het ay ecsumptten is -that h
yj the pl. int vero open during thcae 53 days.
- 7. am asking rbet i
pl the increased coats would have been.
l
.,, j A
We did not :r.ake the calcolahien on that basis.
- 27..
yj, R
Tha Cigo.ron for the '.nat five days of Februar; and Ihch, /ter11,' 4:,y, Juno and Jul:1 in the colnnn, Difference, j,q, O
those 5.re cwccrabM to the figures in the enmer to auention g!
.cax.~.., a w nn.r: t...~ a. - a w uox:nu.o:: :m. --
- .r.w.r~n. m. mm-
~. _,.,
...._,,,g.
nu-cross 5.
I
~~
...~........... - - -,,
7 'i 16 in Statement 1, in that.t corrocB?
,9 f.,
Yon, they are, again'rado by two differenh p
' pocple using independent techniquce but basically coming.;. cut 3 I trith the seme annuer, Q
If one wanted to ct.lculate the incroaced cost 5
I d ring the refueling period as chown in the energy cic.uso.,
6 i
could one get an accurate ectimato of the.t incrected cost by 7
il taking the total $18,139,000 and'dividins it by the number g
of days in that period and using that as a daily average for
~Li the period Decenbar through February 24, 1960?'
?.0 1
l 3
You u'ould get an averago :figuro.
Whether the'
- . ?.
a, arorago would reficct the actual day-by-day variations is a
..w second question since we did not make the enlculation.
g I
O 4
Since ne are talking ebout an estimate -
t l
A You said accurato.
I te'te 9. little exceptien y :,..>
I g
o the nord accurate.
It would givo you a scanure, en catit:0.te t
,l J
li
..,7q on it, using averer,c values for c. lor.7,er poried of tinc.
To i the extent there era do rir.tions frca en steroso *ooth abov:
j,g j and bel.cn you have a statistical crror.
i
.d..,,l Q
Would you say it Uculd be en actinate th..t
- l
.j
' would ha as reliabic as your estimate of an $18,139,000 0
21 J
l difference for that period?
L
- G l
A 7.t would be a reasonablo estimate.
i
/.3 h
-I.
a.
..\\
A
. /.
T
.W t n
9 Shn/h Mc'11d th0 @J cent per dey fin;urG F.DO 'D -
- 'Ct1M.a.CI1 &
- 1.Wi % !., 't T. -* f*.*/ H. 1.*J NMLLOW / . *- t I %I '!:"'" t *, "t. ".5
- t * ' 1 -. - p -
.=---
I
_.m gj,,,._.
.!.2 Dunn. cross
.. 9 _,
- . on png," ?.4 <rt ycur testinony serve ?.n c.n
- Nerirq tPis rospcase?
A It e.oul:1 1;c the as ra order of =cznitucio
.D
. d
., : bece.uco tihen you trrPe the matllematical --
l a:
Q You are bc11pa.rhing it 49 conto c.<. ley --
A..
h no --
fi i
)
Q Or.049 cents per On.y.
f A
A nickel a day.
,(.. !
l MR. THOMAS:
It is 4 9 cents.
It uculd be a q,
\\
hal?.pavk figure.
dt TF.E UITIESS:
It in a tallpark firo.'.rc '.'or th
..h,,'.
9.1 (d racife ;tio.1 custoircr.
j i
THE ADIIINISTRATIVE LM! JUDGE:
Icc.
I BY NR FEIN:
J,.,.,
1 O
'"l l
O If vo e.re to accept your corc?.uc5 cr er page s
l
_.15 1.hn'. tho STCect of chat 5 conts per < ny on the e.ie ter
?. ;
' to de'ninicia, whereas the $20 nillion cTfact on Duq". cane
- i..f
,,. j cctld ~:a calt.tinitot c. ::culdn't ' hr.t nare ren. coning cppl:7 co an c
! argtm.eih by Duqncene tha.t $20 tillicn re..a increacca s.hould l bc cll Mcd by i. hic Conniscion a.'.:ros ; cre fornm rithcut he? rings?
ii.R. TEGIMS:
Arc you asking n:t uitucc: or me
...ti tbat enection?
I will be gle,d to s n3Mer it.
,l i
fib. FEIW:
I know vour anmrer to it.
I
?.7 prei A"y kne his nn nrer. too.
?, 2 7.TE HITHESS :
Cou.l(..'rtn co,r. r ; t5o om :hi":n?
3.,,
g
.s y
smenca.cn roes a Is-..
v.~..
e:. ~ tr.1.umsy n.t m,.-
- r n w : z.
v
._7__
... - -- -.....D. un.. a...c. r o..s..s.
- 1. 3. 0.
tit 3 WITNESS:
Cur 3 cr.rned cc'mnel nor nce 4
thr.t cr6 ment.
Whether or not the Oc'inicsion acceptc it p
e would he a second question.
I thinh the Oc _ mission is botmd
.v by law to ectablish fair and reasonabic raten, fair and e,
reasona.ble both to the customer as nell ao to the stockholders.
g BY 18. FEIN:
Q Ansuming that como July 22, 1980 Eeaver Valley 1 goca back on line, everyone hac learned their leoson 6
from E1I, and there is nothing further to adapt to thoce g
requiremento: what '1ould you c::pect the capacity factor of 7.L, 4 Beerter Valley 1 to be fer the na::t three-yem.r paried?
1 1
A' I have no way of cching such a projection j,3 I think my annwor to that question, or at leest Mr. Fein.
p.s.
my attitudo in annwaring it is reficcted in my Girect
.g,;.
teshirony, pc33 17, and I will not repeat it for the record.
u.r Q
M:1 question was baned en en assunghicn tboit a.c there would be no further requ.irce.anta impesod on Dec.ver
,,j Vc.11er Nc. 1.
I am acking fo:.' an actitr.Ge of the cepacity
.;,g gn factor ever the ne::t three yearc.
LE. TECMAS:
Ho political inter.t c:'ance --
y,g B'I MR. FET.U:
n...
Q No political interference, this ic just 7,
opere. ting the pin.at nett theb von he.ve ude all the design y
che.nges.
g.d, A
m.tccut any interfercuec eieher n m tw
'? C;;*iO e.T A *.*f.7,3:f o% i. '*. *** l' ? *t. *.C' % *
- f W
'"~'1*!"'".
. '.t
- */ I *. O - -
~, _.
Duno-cross 131
'W
. l po31 tics.1 envircmr.cnt, the regulcto.m on-s ton;;ent. enythin7,
.,,;,, of that neicurc, the plant could cperate over c. the co year p
-) - pericd at scmewhere cround a 70 to 75 percent capreity faccor,
.fr k when you take into consideration time cut for refuelins ---
- "/ hh I should say time down for refueling - cnd the time necessary
- p t e f in order to satisfy all the requirements which are ncy in our
,. p technical specifications, in termo of such things as in-
! ii g ] service inspection, surveillance' testing and matters of that 4
,,: nature.
7..l i'B7 MR. THOMAS:
!. 0 y 11 N
Q Do you mean cereplying with the thi.ngs already
,1 t.
'.on the bookc?
?.7,,'i g (;
A R$ght.
O i
TIiB ADIIINISTP.ATIVE LAU JU.0rg:
gay we ge e
eff the record for n nor.:ent?
..L.
't 16
~
(Dincussion off the record.)
- i. i ;
' BY MR. FEIN:
..o Q
If I un>3cretood 7 cur earlior nesti:nony
- 9 ;
.y; correctly, Duquenne Li6 t bac made no analynis of the ces ;
h a
benefit relationship to their custc ne.rs of ?. 70 to 75 9e). :ent 1L ca.pe.c1>.y factor at Bouver Valley Uc. 1.
A2.1; A
I hr.ve Tede no auch calcule.tient, A 70 to 75 3,,.,
q capnci;y faccor taica al o cocs16cri. bion. aumber one. the
,..e O
tirn recuirc9 to refuel ca a encc-m-yecr "c. :i:, '#.'ich is he m:cuen o ::.nn.u n.-:rv.s.:ce m-
..r n.:nc. r, mm-r
(
-.. - ~
..D. unn -cr os s
'132
,,, ctandard refueling - cycle for most raactcra; number tuo, a
! forced outege rate; number three, the_ deranda '"hich are placed f
3?
i upon-that unit to provide pcuer to the customer, recep;nt ing
,,.;r i
4,that there are periods when the denand is not sufficiently j
l, great. that you can justify operating; that particular ple.nt at
(
3 l
i 4 its full rated ca);ncity.
6 i
i Now this la 'getting into ::ome discussions we i
7 jl had earlier this morning.
With'one cingle nuclear plant on 3 j
,,.,. a system you would normally expect it to run very clone to its i
rated capacity.
As the system grova cnd you get more'and
.g p
l l t d you run into Sunday, 4:00 o' clock in
.'.1, more nuc ear p an o an
.i the morning, holiday weekend, moGero.te weather, the doraand is g
1 y" ji not there and therefore from the standpoint of transmins3cn d
f 3 ) cyrtetti integrity yon have to back off the load, i;
O.
At the present t;ima vith Duqueone cnN g
4 g ( having ona nucieny base lec.d plo.nt in their ajatem, large t
plant, we can leave Shippingport cut, yo't would enpoet
- i p
3,3l Duquesne to cperate Beaver Valley No, 1 after it goes back j
il
- g. q on lina at foirly close to itn aveilability fcctor, wo!Od e
n
.0, that b: correct?
A Basically so, reflecting again tha fact that 73 from tiac to time you can have.equipcont out of service ;!hich J
g
. 2. l]!
. in one vay or anotb.ar :111 derato the unit ':31thout forcim-f g.
.,, '4 it cff.
')
.,.f,.
f-D i
y."-
E170r WE.tcr condit*.tODG %
t$ RI;pO.
!. U W D,.
.h4.
icru:ra:
- t. ?.p.::.n t. mc. - A7 N. tGrmm,Lr, yrt, -
g n, y, m 17: _
4
_1
'f
~ g' * ? F *'
.a...
- f p,.
'y
'*A.
ww ri; ;
~
.L 3;.i
. D.u.'.1 0.'.c r o S 3 e
1 may be down.
A condenacr may got e. little bih dirty co you g,
have t a elec.n it up, 2.>
p.
3; a
when you have more foreca outages ut nuclear 4l plant than you would expect for a year,-it would nico incree.se -
.i 5I the time between refuelings, isn't that correct?
i4[
A As a general'statem?nt that-is tree.
.i 7 l'
-Q Even if you underestimate your forced cuteges, 3
it is still possible to operate at a 70 to 75 percent capacity A
g}' factor because tho'refuelings would not come once c year, is g
, that correct?
A If Fe refer to Duquesne Light Exh!. bit I, 77 I
p which is a curve prepared about July 25, 19'79, which made 9
g lj projections as to when Beaver Valley should chut down, the -
i O
E date. I want to point out to you in that there is t window in
.gI time in tores of burn-up durin$ Tihich the plant can be' shut g
down c.nd r,efuel without the need for going thrcvgh a whole.
9 7 p new refueling type analysis.
.g Ih other words, Dener v lley could have a
{chutdennanytimobetwoonrouchlyI!00equive.lentfullpcNer ip i
y,o days of burn-up cod 427 equivalent full power days of burn-up.
So thero is scme degree of operating flexibili ty i
.u ac to uhen you actur.11y go into refuelirg and it 10 entirely '
,,y I poccible in a c;iven 12-nonth period you could hevo tuo re -
.,3
.,j, fuelint.s; but by the cas token it is aloo pescibic that.*ou t
pgfcOulf,fj3*bhroughP 12 -HODth period and dot hP.VO. r10f Nfdeling P.- -
- m:r.v,en a tu:vmr t um ~.tr tr. t.cfxtera.cw wa. - tt-ar.rgmr.
- t,
- 71 m
,,g, 7..~s...m
~.
~
_, - ~.~ =. -. -
1)U.Ull CTOSU 13U
.~._.
t
- 3.. _ outO 60.
p 2[
.Q Therefore then I colted ya'r for c whrea-ycar I
3 pro;]ection of capacity factors, that would be a more realistic 4
way of looking at it than a one-year projection, is that 5, correct?
t 6l A
I answered the_ question in the conte;;t it in f7[anormal36-monthperiod,whetheritincalandaryears,Idid-6' take 1"1 consideration.
l 9;
Q I talte it that when you chut down Beaver 4
10 Valley for the seisnic reanalysis you bed not rer.ched your 100 days on the firnt fuel that necced to be repinced?
!.1 4
r 12 !
A That is right that is uhat the e::hibit shows, 3
t U
that on August 6, which is abcut the time the chou cause orde2 i
M' uac 3.i+lted, the burn-up was appro:cimate?.y 373, 371.t eouirMent
.tS full peuer days.
16 Q
I take it there ucc n:: ray of btrning th?.t 17 fuel eff during the first shutdown per$oi ao that ymt couM.
)G have refueled during that pericG?
D A
Ho, it 'fas burned der:n na fact as we coulS.
20:
Q What would have happened if you had refueled I
g 31 during that period?
t, If Ue W re to refuCl duriD3' the ---
J 13 '
Q Firnt shutdowa period.,
~ bnber one, it wou3d Lhn.'re m mnt ti c 4 i
r planning and is i
Ti very castly, i
Ui 0,
Was any analysis ccds of what the coat of i
';.g l that would have been versus the coat of chutting daru for i
?.3 : an additional ten unelts to refuel at a 1.ater tido?
1 4
- y. ;
!i I don't understand the question.
O I
35 mil. FBISI:.iiculd yru rnnd the question?
nnd i.
l
..to> nc.a..n c. :.nsus rec. - a n. wwvi6a r er --.v.vaceune, er ima
,-r.
._.._.7.._y
.. ~.
3
._ ___.,_.._.., --. D_.u_n_n..cr o_s. s...
36 1
b fjiif you donit understand it, then'I tcill rephrase it.
(Question reed.i 1
2 t
., i THE WITNESS:
The coat of trhat?
I don't
- I 4f understand the cost of what in the first part of your question,.
t 3, BY 12. FEIN:
3; 4
All right, the coot of all these rectudies,.
I i reenalyses, hearings, et cetera, versus the coct of approxi-7 I
e,l mately $123,000 a day for an additional ten-week period.
I i
A Well, we knew we were coming dann to refuel pj
.:9 l and ue kneu wc had all these other requiremento which 7:e tc.d I
! to catisfy.
It made absolutoly no sense to do the refueling g
g at this particular period when we had to do the rest of the gl work.
O g,l There were no formal studies.
It Mc.c ob riouc 5
g{ that the decision uc made and the cource of action we elected to follow was the correct one.
,3
- t7 l Q
If I understand your tcctimony corroctly3 I
g, j the pronont shutdown would take ;juct as long whether you i
w ;i were refueling or not.
A That is correct, becauso the limiting factor gn,
i yl on the down time in not the refueling acbivity but the time i
,;.j required to satisfy all the.Imc bulletins, modifications,
,,3 j whr.t have you.
z g.
TID?, ADMIUISTRATIVIE LMI. JUDGE: - M".
- Fein, D
.,he.t point ham you re.ched zu your crces-c amim.csen?.
.n n mrc.,c>t a tv exta.. n:a:. ~ n:' n. Lo t:mt.'.c'A W. - t!rr.memme, t r 17t r: ----
5 <.. ~%
w
.v.
3
--+
yy-z.,p y,.s ; ; -..
..y,,.
y
~ - -
Dt;atn-cros s 137 1
3
~
1:
- 12. FEIN:
Probab1r 99 99 percont finishad.
k 2,' fit _couMcvonbethatextraone-hendredthofonepercent.
3l THE ADMINISTRATIVE LAW JUDGE:
We vill then i
4l,finich today.
1 1
- 5) BY 22. FEIH:
6f Q
When did you begin ordering materials for t
ei the procent shutdcun?
i 8l A
I don't know, Mr. Fein.
Some of these 9
natorials I am renconably cure had been ordered for many.
10 ! many tronths.
1 t
1 u, I Q
When did you order tha critical natorinla i
12,i that you are still awaiting dolivery of ?
il 13 i A
I don't knew when thoce materials were orderet.
O M
but the need for thoce particular pueps -- I acciwe that is -
l
,w ' unc.t you rze referring to -- ucs' not determined until lete is, in 1979, 1980 when the NRC finally established a type of desi(;n l
- 7 which pould sabiefy their necdc.
j te,
Ubat ue exc talking about ic a sycten for ir feedir", caustic into the sprays in the containmcat in the t
Nl caso cf a locs of coolent accident.
The pvrposo of che l
3f, ' cauctic is to remon the radioactive iodine from the,vapcr 1
1 p; which "ould form in the deac in cane of an accident of this i
23.
nature.
Up until then tre had had a gravity type feed an6 i'
g ou:. design and our propoaal ta tha' TRO tas Goinft, a1037.; tra M'
lirma of unirig this.grevity ?eod.
? V,1;;r. W "J.it',, f./s 1;' I r.-
7.! 3: 3'OM'M O *.!,Vfr if,1.. (!!C. ~.*.** T ?. LMt*W f t.t. 7 ^.
l ^
l
~
......a
_.3,
Duan CredS
..;id
,a 1
Tim i.iRC tado 1.t retiter c?.ex; that this i:ould
~;.
- I 9
not be accentable ;uel therefore Uc had to ucdify cur dcairm 0
~
~
., ' in ordar to prm-iCo c. inore positiJe !ccann of, first, regulatin ';
4; the e.sw.nt of canctic being fed into the cystem, and nuriner t
p two. rar;ulating the total quantity so as to n'aintain a pH in gi the av ap, no to stor.k, above eight.
i 7
O.
When did you fir:t 'ccortain that :;cu had
+.o 1
e h build 2 caustic fced cyctem?
3
" 'i A
Ue did have a caustic food system but it ' as g) i a c;ravity feed.
The informtien wcs wbr itted to the !!fr on g iFcbru9ry 27,. 1980, r.?.ther recent.
a sy, f Ikra the design may have beca finalizcdood i:
il 3 ] epprovad ocnetine enrlier than that.
Id6 the inforcation on O
4
.; ' ? formi bcsis "an not submitted unt.il that de,te.
O, Iiy queci;1on une. hen you accert'ine6 frco che
..3, NRC th,t they ;ould require you to rebuild your caustic facd f
- 7( cystet?
1 i
s r. ;
A It nould have been late 1979, early 1980.
V
~?i O.
In uhnt the lercost sin {;).e v.cdification thtt I l
x
- in boi::.; TMc at the present ti:
f 2c ?
i m1 A
Largest in what certe::t?
l 4
N
~2 !{
O.
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That is but nr.e part of tbc overe.11 dasic;n i
mafd fi?.ntiouc esace:1?.t:5 *.;ith the pr@le n in the 3 7.- hec 0
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sule y in. Pati ~n !y:mps, tha outside v:ny re-rm ?c the inalde I
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.na....-cross i
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It 10 all an<. r.robl. ors.
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'l Hac; it in late J.9ip thc.t you foumJ cut yc-p 3
3 would.: ave to mod.'.f.; thct one 1c.rse problem?
.(. 4 A
No, we kne,r about the problem in 19'T'T and la f
age.in in 197'T is uhen ne made come interim raodif'ications in i
1 ordar to naticfy ch3 191C that indcol bhe plant in safe to i g operate on au intorJm besic, and at that time no aade a i
L cownitaent to come up with a new design change to submit it 4
1 0;
to thcu for their rrrien and approval to make the modificctiors i
.r.,
on a. r arcanant banis during the first refueling.
t ll gj O
Iq?.amuch as you had a subutenbial outca;e j
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- 17. ; during. 19'79, why/ weren't those modifications made during i.'1 i tbtt peried?
O t
A Eccnuse you took eJ.1 ;rcer engineering
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4 is cuoport nococcery to dc. that typu of vork end put P. hew ot:
1 p:
the ot'ou cauce crier requirements.
- f. gain we are talking 11
'.? $ about Stone f ilebster primarily bc::c.uce they vero the one:.3 1
i.0 ) 't!he rcrc doir ; th-dea gn for this trodificetien uork.
J
!? 3't (Voa Stona 0: We' ester is n$t with c r2 quire.wnt i i
i
' 1 to untisfy the NPM and fivo other Utilities ':hoee ploni,r.
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M.4 wore shut do'.1n.
So escontially uhat happened, you 6,evote d I
cncincoring talenta and engineerin', ti'ne to solrin,3 h e
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OP'10e order O't thS GXpHUSS C" t hO ~ 'f or k %?C c S t.1r.?? ho derJp..Ctc the dr. sir,n afinocintM ' tith tois ciner n rM c.a.
O 7.! t
'd I:7 ~ va.derstand it
-"r'" t i Stoar: & Webater
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y j did non have the onfincering perconnel a"nilable ta work en l
T l both the she:J cauce order for the fi're nuclear plants and the D
g redesign of this whole system for ycur plant?
(;
A That is basically my underctanding.
I won't l
5, cay there uns nobody workir#, on it.
By the same token I am 3
-der the general impression that it wa: not the highest i
? il priority work at the time because we knew-rhere ue. stood 4f G
with refueling, we knew we had a show cause order, we knew l
9 j we had time to complete this other project, and I still r
I O, belie Jo we can ecmplete the work aasociated with tha'c de:'.i.gu a
- .1,I change within the present time con traints.
i!
'!2 (
MR. FEIN:
I have no further questions.
UW THE ADMINISTRATIVE LAW JUDGE:
We will 4
redees until 10:00,temorrow morning.
I' 13 ?
i
- .1 (The hearing was adjourned at 11: 30 o'clcek p.m.)
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1 I hereby certify bhat the proceedings and 2
evidence are contained fully and accurately in the notes
~;
?>
taken by me on the hearing of the within cause before the
'I Pennsylvania Public Utility Commission, and that this is a
'I correct transcript of the same.
6 MOHRBACH & MARSHAL, INC.
7 8
By
- g 6fficial Reporter V - 2.A /
10 s
REPORTB0 BY:
JAMES P. O'HARA i
12 Mohrbach & Marshal, Inc.
3 O
27 North Lockwillow Avenue.
3'3 l
Harrisburg, Pennsylvania 17112 p,:.
(The foregoing certificatien of this 1
transcript does not apply to any reproduction of the same by
')
N any means unless under the direct control and/'or supervision 10 ! of the certifying reporter.)
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