ML20199J180
| ML20199J180 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/1995 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20199J167 | List: |
| References | |
| FOIA-97-325 NUDOCS 9711280072 | |
| Download: ML20199J180 (36) | |
Text
b, . . .
t EXHIBIT 23 i
I C
9711280072 971124 J PDR FOIA KEENAN97-325 PDR Case No. 1 95 013 Exhibit 23 l
"! 1 N H r w ) 1
1 1 UNITED-STATES OF AMERICA 2 NUCLEAR-REGULATORY COMMISSION .
3- +++++ .
1 4 OFFICE OF INVESTIGATIONS !
, .l 5- INTERVIEW-6 -------------------------------x 7 IN THE MATTER OF: : Docket No.
8 INTERVIEW OF : 195-013 9 GITA NARASIMHAN :
10 :
11 t-------------------------------x 12 Tuesday, August 22, 1995 13 g
. 14. Conference Room 13, 2nd Floor 15 PSE & G Administration Building 16 E'nd of Buttonwood Road 17 Hancocks Bridge, New Jersey ,
18 19 The above-entitled interview was conducted at 20 9:09 a.m.
21 BEFORE:
22 KEITH LOGAN, Investigator 23 24 25 NEAL R. GROSS EXHIBIT b
^"
CASEND .
' l - ' 9 5 ' 0 T 3 ' ""' "'*""5 '"^"SC"*'"S 1323 RHODE ISLAND AVENUE, N W~ PAGE / OFdPAGE(S)
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. 2 1 APPEARANCES:
2 On Behalf of.the' Interviewee:
- 3 MARK J..WETTERHAHN, ESQ.
1 4 MA1 CIA R. GELMAN, ESQ.
5 of: Winston & Strawn 6- 1400 L Street, N.W. -
f 7 Washington, D.C. 20005-3502 ;
! 8 202/371-5703-
- i. 9 10 On Behalf of the Agency:
i 11' BRIAN McDERMOTT< "ESIDENT INSPECTOR 12 475 Allendale Road -
13 King of Prussia, PA 19406 14 610/337-5345 15 16 i.
17 ,
i 18 4
-19 .
. 20 21 ,
22 23 d
24 25 .
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3 1 PROCEEDINGS 2 9:09 A.M.
3 INVESTIGATOR LOGAN: Ms. Narasimhan, welcome .
4 anck. My name is Keith Logan. We've spoken several times 5 aefore. What we'd like to do today, as we've discussed 6 3rior to going on the record, is to go over a couple of 7 additional points on the memo that you prepared on the POPS 8 3ystem and the events surrounding that issue.
9 With me today is Brian McDermott.
10 MR. McDERMOTT: For the record, my name is 11 Brian McDermott, a Resident inspector with the Nuclear 12 ;
Regulatory Commission and I'm here today to provide 13 technical back-up ior Mr. Logan.
14 INVESTIGATOR LOGAN: And Ms. Narasimhan, is it 15 still your desire to have Mr. Wetterhahn and Ms. Gelman 16 :Tere as your counsel?
- 17 MS. NARASIMHAN: Yes, it is my desire to have 18 them here.
19 INVESTIGATOR LOGAN: Mr. Wetterhahn, will you 20 identify yourself?
21 MR. WETTERHAHN: For the record again, my name 22 is Mark Wetterhahn with the firm Winston & Strong, 1400 L 23 3treet, N.W., Washington, D.C. 20005. With me is Marcia 24 Gelman, also of the firm.
25 INVESTIGATOR LOGAN: As with last time, Ms.
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4 1 icracinhan, you're awaro that Mr. Wattorhahn and Ms. Galman 2 do represent other individuals for the corporation'in this- ,
3 natter?
4- MS. NARASIMHAN: Yes, I'm aware of-that.
5 INVESTIGATOR LOGAN: Do you still desire to 6 1 ave them here today?
7 MS. NARASIMHAN: Yes.
8 INVESTIGATOR LOGAN: Thank you. And for the 9 record, I'll note that I'm still an Investigator with the 10 9RC and we're still located in King of Prussia, 11 pennsylvania.
12 What I'd like to --
13 MR. WETTERHAHN: Can we go off the record for a
~
14 second?
15 INVESTIGATOR LOGAN: Sure.
16 (Off the record.)
17 INVESTIGATOR LOGAN: As we discussed, Ms.
18 Narasimhan, this is a continuing interview to cover the few 19 additional points that we addressed earlier, I'm sorry, the 20 two points that we discussed earlier on this subject.
21 I'd like to start off, we talked to Mr. Ken 22' 0'Gara last week. Mr. O'Gara told us that he had a 23 conversation with you about a month ago and that he 24 indicated that you had talked to Mahesh Danak about the 25 October 1993 time frame on the POPS issue. You did discuss NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 AHOOE ISLAND AVENUE, N W.
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5-1 that with Mr. Danak about that time, didn't you?
2 MS. NARASIMHAN: No.
- 3 INVESTIGATOR LOGAN: You-didn't discuss the 4 ? OPS issue with Mr. Danak.
5 MS. NARASIMHAN: Let me clarify what I want to 1
6 isay. I had a conversation with Ken O'Gara in the hallway 7 <
ind at the time I mentioned that I had early on considered .
8 :.he RH3 valve and that is in my chronology of evidence that 9 1 did look at the RH3 valve.
10 I do not recall having a conversation with 11 Hahesh or saying that to Mr. O'Gara.
12 INVESTIGATOR LOGAN: We'll call Mr. O'Gara back 13 and ask him again.
T 14 Let's talk then, if we can, I believe your 15 chronology of the event indicates that you did consider 16 taking credit for the RH3 valve with regard to the POPS 17 Lssue and the document you prepared for Mr. O'Gara and that -
l 18 was in March of '93. I believe you're looking at your 19 chronology also? .
j 20 MS. NARASIMHAN: Yes, I am.
21 INVESTIGATOR LOGAN: And you considered it. Why
- 22 c lidn't you take credit for RH3 back in, I guess, March of 23 '93?
l
! 24 MS. NARASIMHAN: This was some preliminary work 25 a nd I think the work'was. started even before the NSAL came NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W, (202) 2344433 WASHINGTON. D.C 20005 (202) 234-44't1
6 1 ap. -I htd diccuccions with Wastinghouca psople. I had ,
.2 come across that W cap which I referred to which provides a 3 methodology for crediting the RH3. I think if you look on 4 the 4/5/93 it says W cap 11640. I had come across that and 5 [ had some discussions with Ray Brown at Westinghouse about 6 'asing that methodology, but this was done, I think, it was-7 started before the NSAL came out and"right about April time 8 frame, I prepared a' draft evaluation and then I didn't 9 really proceed any further with that work. Westinghouse in
'10 their NSAL had identified RCP, reducing the number of RCPs 11 as an option and I think about that time we had -- the 12 decision was made to pursue getting a Delta-P calculation 13 for different numbers of RCPs from Westinghouse. I really 14 didn't pursue any further with the RH3 evaluation. It
- 15 still exists as a draft document which was not reviewed.
16 INVESTIGATOR LOGAN: And where does that 17 document currently exist?-
16 MR. WETTERHAHN: You have it.
19 INVESTIGATOR LOGAN: We have it?
20 MR. WETTERHAHN: Yes. It's this document --
21 MS. NARASIMHAN: That's it.
22 MR. WETTERHANN: Mr. Danak gave it to you at a 23 13rior interview. He didn't indicate it was Gita's 24 document, I don't believe, b'ut that's the document --
25 INVESTIGATOR LOGAN: Let's read the name into NEAL R. GRO3S COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W
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7 1 bho r3 cord.
2 MR. WETTERHAHN: It says, the title is ,
3 " Evaluation of Nonconservative Low Temperature Overpressure 4 Set Point for Salem 1 and 2."
5 INVESTIGATOR LOGAN: Is there a date on that?
6 MR. WETTERHAHN: It's unsit ni and undated.
7 INVESTIGATOR LOGAN: Let8s go off the record.
8 (Off the record.)
9 INVESTIGATOR LOGAN: We've had an opportunity 30 to look at this document and you indicated that this was 11 the item that appears on your chronology on 4/5/93?
12 MS, NARASIMHAN: That's right. '
13 l INVESTIGATOR LOGAN: What was the purpose of 14 his? Why did you write this document?
15 MS. NARASIMHAN: I was evaluating the operating 16 experience 5832 which had been brought to out attention and 17 4 was looking at differcnt approaches and this was one ,
18 approach I was considering at that time.
19 INVESTIGATOR LOGAN: And why didn't you follow 20 through with your consideration of this approach?
21 MS. NARASIMHAN: I think right about the end of 22 Harch, around that time,.the NSAL came out from 23 Restinghouse and this approach was not identified in the 24- NSAL and I think that I had discussions with people.
25 INVESTIGATOR LOGAN: With whom?
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1 MS. NARASIMHAN Probably with Mahoch,.I' don't 2- .
cecall. . Mahesh was cognizant for the outer systems, so I
- 3 probably had a discussion saying I had been using this 4 approach, but then based on what the NSAL said, we decided 5 to pursue getting the Delta-P calculation at the time.
6 INVESTIGATOR LOGAN: You and Mahesh? ,
7 MS. NARASIMHAN: I don't recall.
8 INVESTIGATOR LOGAN: You said "We decided."
9 MS. NARASIMHAN: Me, meaning me and the PS.
10 INVESTIGATOR LOGAN: When you say " PSI" you 11 have to use a name. I don't understand when you say PS.
12 MS. NARASIMHAN: I think it was with Mahesh.
13 I INVESTIGATOR LOGAN: It was with Mahesh.
14 MS. NARASIMHAN: I think it was with Mahesh.
i 15 INVESTIGATOP LOGAN: So you and Mahesh 16 considered it around the March time frame and then backed 17 off.on your consideration of using the RH3 because -- say 18 again, because why?
19 MS. NARASIMHAN: Because in the NSAL, 20 destinghouse had said that by going with fewer pumps that 21 was an option to find margin for this issue.
22 Now if you look at what I had done, I had used ;
23 74 PSI which'is the Delta-P with four pumps. At the time I 24 did this, we did not have information on less than four 25 pumps and when the 74 PSI, I think, was a number that was l .
l- NEAL R. GROSS COURT' REPORTERS AND TRANSCRIBERS l 1323 RHOOE ISLAND AVENUE. N W l (202) 2344t33 WASHINGTON, D C. 20005 (202) 234 4433 l
9 1 verbally-given tu me by Westinghouse at the time.
2 ~ INVESTIGATOR LOGAN: Quebtions'on this point?
- 3 MR. McDERMOTT: No, I.do.not.
4 INVESTIGATOR LOGAN: Let's go back again to 5 four chronology, March of '93. You had informal 6 discussions with QA on status of code case and crediting it 7 and you have in parentheses "would need approval." s .
8 MS. NARASIMHAN: That's right.
9 INVESTIGATOR LOGAN: When you say "with QA" who 10 are you talking about?
11 MS. NARASIMHAN: I was having diecussions with i
12 Tom Roberts. As I stated in the earlier interview, Tom i
13 Roberts procured a copy of the draft for me at that time.
14 INVESTIGATOR LOGAN: Okay, and that's what you 15 Tefer to the status of the code case because it was in 16 draft. Is that it?
17 MS. NARASIMHAN: At that time, the code case .
18' was in draft. It was to be issued, I think, around May.
19 INVESTIGATOR LOGAN: And when you say "would 20 aeed approval" you were referring to NRC approval, weren't 21 you?
22 MS..NARASIMHAN: I don't recall what I made 23 that statement. I think that was what was implied there.
l 24 But it would need approval.
25 INVESTIGATOR LOGAN: By the NRC?
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10 l' MS. NARASIMHAN: Right.
- 2. INVESTIGATOR LOGAN: In order ior it to i>e used -
3 in NSAL?
4 MS. NARASIMHAN: It says for crediting it, yes.
5 INVESTIGATOR LOGAN: And go back down to 493 on 6 four chronology again. It says," confirm epplicability of 7 generic 4, RCP Delta P Os :rll and obtain from Westinghouse ,
8 informal discussions with a licensing engineer."
9 Who is the licensing engine **r referred to.on 10 that line?
11 MS. NARASIMHAN: I think Howard Onorato was his 12 nsme.
13 INVESTIGATOR LOGAN: And what was his 14 responsibility that vou chose to talk to him on this issue?
l 15 MS. NARASIMHAN: I don't recall. He was in 16 licensing.
17 INVESTIGATOR LOGAN: Just in licensing. But .
18 you don't specifically know why you spoke to him as opposed 19 to someone else? .
20 MS. NARASIMHAN: No.
21 INVESTIGATOR LOGAN: And you discussed the RH3 22 with him and the code case and what did you conclude after 23 your discussions with Mr. Onorato?
24 MS. NARASIMEAN: ~I can't recall.
25 INVESTIGATOR LOGAN: Take your time.
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11 1 MS. NARASIMHAN: I don't coa anything in my 2 lotes on that. I don't recall. This was before the code .
3 case had been approved. I don't recall any --
4 INVESTIGATOR IhGAN: Why did you go and talk to 5 .11m? Do you rememoer that? Because the reason I'm asking 6 is you said you discussed discussions with a licensing 7 engineer on RH3 and cods case and then in brackets or 8 axcuse me, parentheses, it says "no problems identified.
9 '4111 proceed use of code case with licensing supervisor."
10 Who was the licensing supervisor in this case?
11 ,
MS. NARASIMHAN: I don't know who Howard was 12 working for at the time.
13 INVESTIGATOR LOGAN: So Howard said he would 14 pursue it with a licensing supervisor and not you?
15 MS. NARASIMHAN: I think that's what -- see, I 16 prepared this in '94.
17 INVESTIGATOR LOGAN: I understand.
18 MS. NARASIMHAN: I guess at tne time that was 19 my recollection, yes.
20 INVESTIGATOP LOGAN: But what's of concern is 21 that there were r;uite a few names in here and if you recall 22 that you spoke with a licensing supervisor, or someone who 23 aas going to pursue this with a licensing supervisor, you 24 aould have had to recall the name, wouldn't you, in order 25 to write that down?
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12
~
1 MS. NARASIMHAN - I recall the name of the ,
-2 engineer. ,
l 3 INVESTIGATOR LOGAN: The engineer.
4 MS. NARASIMHAN: . But I can't remember who the 5 supervisor of the group was at the time..
I 6 I!NESTIGATOR LOGAN: And what did you mean by 7 *no problems identified?" The use of the RH3, no problems ,
8 identified, the code case, no problems identified? It 9 seems to be somewhat contradictory to what you said, that 10 rou discounted the RH3, the RH3 valves.
11 MS. NARASIMHAN: That was discounted after 12 bhis. If you read the next one, it says " reconsidering, 13 also considering PORE with Salem specific Delta-P."
14 This was right about the time the NSAL had come butandwewerere-reviewingouroptions.
~
15 10 INVESTIGATOR LOGAN: And you have notes of this 17 :onversation with Howard? I'm looking at the right column, ,
, 18 fou have reference documents and notes. Are those the 19 3andwritten notes you're looking at there?
20 MS. NARASIMHAN: Yes, I think it's referring to 21 those handwritten notes, but there is nothing there about 22 the conversation with the licensing engineer. Maybe that 23 part is a recollection. All the notes I have are attached.
24 INVESTIGATOR LOGAN: And Howard said he was 25 going to talk to a licensing supervisor or you were going NEAL R. GROSS COURT REPORTERS AND TRANSCRC ,
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13 1 to talk to a licensing cup;rvisor, what's your boat 2 cecollection?F 3 MS. NARASIMHAN: My best recollection is Howard 4 Onorato who was the licensing engineer, that he would talk 5 r.o the licensing supervisor.
6 INVESTIGATOR LOGAN: Do you know who Howard 7 dorked for at that time?
8 MS. NARASIMHAN: I do not know who he worked 9 for.
10 INVESTIGATOR LOGAN: Next one, "GN 11 cecollection, internal discussions, reconsidering using 12_ RH3, considering evaluating PLnVs with Salem specific 13 data."
14 MR. WETTERHAHN: Delta-P, actually.
15 INVESTIGATOR LOGAN: I'm sorry, specific Delta-16 Ps.
17 Is there anything more that you can tell us 18 about your consideration of the RH3?
19 MS. NARASIMHAN: My efforts in the RH3 resulted 20 in this draft document and this took place in March, mostly 21 in March and by about the first week in April this approach 22 aas not pursued.
23 INVESTIGATOR LOGAN: Why?
24 MS. NARASIMHAN: Again, W^stinghouse NSAL came 25 aut which had identified different options. This was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W.
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14 1 som0 thing that I had otertOd on, b200d on my,diccuccions 2 vith Westinghouse, even before the NSAL came out.
3 INVESTIGATOR LOGAN: And did you communicate 4 rour intention not to pursue the RH3 further to anyone 5 sise? Did you talk to Mahesh Danak about it?
6 MS. NARASIMHAN: I think I discussed it with 7 (ahesh and that's when we decided to request the Delta-P 8 -:alculations from Westinghouse.
- 9 INVESTIGATOR LOGAN
- Did you also discuss it 10 'vith Howard Berrick?
11 MS. NARASIMHAN: I may have. I don't have 12 specific recollections from that time frame.
13 INVESTIGATOR LOGAN: Is there anyone else you
~
14 : night have discussed it with?
15 MS. NARASIMHAN: No, I don't think so. I can't 2
16 bhink of anyone else.
- 17 MR. McDERMOTT: I have a question regarding 18 rour draft document in the use of the RH3 valve. This is 19 the document which we were discussing. Earlier, you 20 prepared it in the March 1993 time frame. In that you make 21 ceference to Salem POPS analyses, SGS/M/MDM/042 and 062.
22 MS. NARASIMHAN: Yes.
23 MR. McDERMOTT: The specific numbers that you 24 ase in there lead me to believe that you actually had those 25 documents and were reviewing those as part of your NEAL R. GROSS COURT REPORTERd AND TRANGCRIBERS 1323 RHOOE ISLAND AVENUE, N W. i (202) 234 44.13 WASHINGTON, D.C. 20005 (202) 2344433 l
15 1: evaluation of tho issue?
2 MS. HARASIMHAN: That's right. . .-
3 MR. McDERMOTT: And were those documents 4 :onsidered to be the design basis for this system?
5 MS. NARASIMHAN: They were the design 6 ::alculations. That's what I wis aware of then.
7 MR. McDERMOTT: -Okay, and how did you view the.
8 discussion of RH3 in those documents?
9 MS. NARASIMHAN: I don't have any specific 10 cecollection at this time.
11 MR. McDERMOTT: Okay. In your draft memorandum 12 :liscussing the use of RH3 you mentioned the auto closure 13 Snterlock.
14 MR. WETTERHAHN: Where are we? Let's identify
- 15 the page.
16 MR. McDERMOTT: Second page of the draft 17 document, second paragraph. ,
18 MS. NARASIMHAN: Yes, I have that.
19 MR. McDERMOTT:
It discusses the deletion of 20 the auto closure interlock. Can you tell me about your 21 ::onsideration of RH3 and how that related to auto closure 22 interlock?
23 MS.-NARASIMHAN: The Westinghouse W cap 24 methodology, I think, made reference to the fact that auto 25 closure interlock had to be deleted before you could take NEAL R. GROSS COURT . PORTERS AND TRANSCM18ERS 1323 RHOOE ISLAND AVENUE N W (202) 234 4433 WASHINGTON, D.C. 20005 (202) 234-4133
16 1- :redit for RH3 and I think that's the conn 3ctionin which I -
-2 1 ave that-paragraph.
3 MR. McDERMOTT: And to your best recollection, 4- <ere you. aware of whether or not that auto closure 5 interlock was removed at the time you drafted this 6 document?
7 MS. NARASIMHAN: Yes, it had been removed. I 8 bhink I got that'information from the CBD.
9 MR. McDERMOTT: The CBD being?
10 MS. NARASIMHAN: The configuration base line 11 Socument.
12 MR. McDERMOTT: Okay. Thank you.
13 INVESTIGATOR LOGAN: Ms. Narasimhan, are there I
- \
14 'any other-discussions that you had related to the POPS 15 system and the preparation of your document that you and I 16 nave not discussed in the course of this intarview or an 17 earlier interview?
18 MS. NARASIMHAN: When you say " document"?
19 INVESTIGATOR LOGAN: That's the draft memo that you were working on at the time.
21 MS. NARASIMHAN: The one that was --
22 'INVESTICATOR LOGAN: Dated 12/3 0 ---
23 MS. NARASIMHAN: The draft that I had prepared 24 3n 10/30?
25 INVESTIGATOR LOGAN: Yes. Prior to your NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHoDE ISLAND AVENUE, N W (202) 2344433 WASHINGTON. D.C. 20005. (202) 234 4433
17 1 1Goving that offico. -l 2 MS. NARASIMHAN: No, I do not think there it. .
3 tnything. I had discussed it, I had prepared the draft and 4 turned it over to Howard Berrick on my last day of work 5 :lere. I had had on-going discussions on the POPS issue 6 with Mahesh since he was cognizant of the system. That was l 7 .nbout my involvement on that issue with other people.
, 8 INVESTIGATOR LOGAN: Okay. Are there any other 9 questions-that you have, Brian?
! 10 We can go off the record for a minute.
11 .
(Off the record.)
12 INVESTIGATOR LOGAN: Ms. Narasimhan,.one last 13 question, are there any documents that you prepared or any
- 14
- Totes that you have or anything that you would be aware of 15 that would indicate that licensing was in on the 16 discussions of the use of the code case or the RH'a valve 17 M icr to December of 1993? '
18 MS. NARASIMHAN: I did not have anything in my 19 files.
20 INVESTIGATOR LOGAN: So there is nothing else 21 that you are aware of that would reflect licensings 22 involved?
23 MS. NARASIMHAN: Not that I'm aware of.
24 INVESTIGATOR LOGAN: Okay. Brian, anything
.25 else?
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1 MR. McDERM0TTt Unlose -- cro you aware of any
_2 ::opies of the draf t of your letter that was eventually !
3 signed by Howard Berrick on December 30,1 993,_the draft 4 version of that? Do you have the original concurrence copy 5 3r would that original concurrence copy --
6 MR. WETTERHAHN: Are we on the record?
7 INVECTIGATOR LOGAN: Yes, we are.
8 MR. WETTERHAHN: Gita had left by that time so 9 I don't think you would have seen any concurrence on the 10 December 30th, what was it the '93 --
11 INVESTIGATOR LOGAN: I think we're all aware of.
12 the 12/30 --
13 MR. WETTERHAHN: 9/7, I'm sorry. You don't 14 have a copy of that, do you?
15 MS. NARASIMHAN: No, I don't. I had a draft of 16 the final memo, but I turned over --
17 INVESTIGATOR LOGAN: We received that.
o 18 MR. McDERMOTT: I was just looking for any 19 other documents that might have circulated before your 20 leaving in October that would indicate-that licensing would 21 be part of those discussions, the original memo that went 22 out didn't have any distribution to licensing and'I was 23 looking for something that would perhaps indicate that they 24 had been part of the original drait of that.
j 25 MS. NARASIMHAN: I'm not aware. I left in NEAL R. GROSS COURT RtPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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, .3 19 1 3ctober.
2 INVESTIGATOR LOGAN: Certainly from your -
3 discussions you indicated that licensing was involved in 4 rour preparation of the draft. J 5 MS. NARASIMHAN: I need-to clarify that. I had 6 balked licensing in March, April time frame on the RH3, 7 3rediting the RH3. After that, I did not have any .-
8 '
discussions with Howard Onorato on that.
9 MR. McDERMOTT: Did you have discussions with 10 anyone else from licensing after that point?
i 11 MS. NARASIMHAN: No, I don't recall any 12 ' discussions.
13 INVESTIGATOR LOGAN: That is all we have.
14 MR. WETTERHAHN: Tro questions. With regard to 15 the document we've been speaking about, the evaluation of 16 : 1onconservative low temperature overpressure set point for 17 3alem 1 and 2, how many RCP pumps or RCPs does this assume .
18 Ln your analysis?
19 MS. NARASIMHAN: I assumed four RCPs. On page 20 .2, there's a statement that adding the 75 PSI pressure 21 <
iifference and -- I'm sorry, 74 PSI prussure difference.
23 MR. WETTERHAHN: One final question, in your 24 <
- hronology, there's an indication of a file name of all 4
25 <
- aps, GITA. DOC. Have you brought-a copy with you?
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=e -*
20 1- MS. NARASIMHAN: Yes,-I have a copy of that
. 2 with me. -
3 MR. WETTERHAHN: Okay, does that appear to-you nfter your review to be a draft of the document we've just
,. 4 5 aeen discussing?
6 MS. NARASIMHAN: That's what it appears to be.
7 MR. WETTERHAHN: And when was it last revised? .-
8 MS. NARASIMHAN: According to the records from 9 the secretary, it was revised on 4/5/93.
10 MR. WETTERHAHN: I have nothing further.
11 INVESTIGATOR LOGAN: That's all. Thank you 12 very much for coming. ,0ff the record.
- 13 (Whereupon, at 9:47 a.m., the interview was 14 concluded.)
15 16 17 18 19 .
20 21 22 23 24 I 25
- NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
(202) 234 4433 WASHINGTON. D C,20005 (202) 2344 433
-CERTIFICATE This is to certify that the attached -
proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name of Proceeding: INTERVIEW OF GITA NARASIMHAN Docket Number: 195-013 Place of Proceeding: HANCOCKS BRIDGE, NJ were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear
- Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and
, accurate record of the foregoing proceedings.
fW #
Mc KAREN HANTMAN Official Reporter Neal R. Gross and Co., Inc. .
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
1323 RHODE ISLAND AVENUE N W.
(202) 234-4433 WASHINGTON, D C. 20005 (202) 2344433
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EXHIBIT 21 .
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a 4 FORM NC.D N .22-0018-1 DISCREPANCY EVALUATION FORM 99- Co(oc
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DISCREPANCY
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ORIGINATOR M .h A KIAE DATE 4kMI %
(Print Name) -
DEPARTMINT G I4 PB EXTENSION N'72.
INITIAL ASSESSMENT:
TECHNICAL SPECIFICATION APPLIES YES _., No __ ,
, IF YES, LCO NUMBER OPERABILITY CONCERN YES ___ NO V SAFETY CONCERN YES /_ NO __
INCIDENT REPORT WRITTEN YES _ NO '
IF YES, IR NUMBER SYSTEM ENGINE C+ MM AM DATE NOTIFIED b3 "d 4
( int Name) t SUPERVISOR ;
DATE COMMENTS S cdi UtB 8F- P Ebf EW6h MG kl fTt.4 *TH E 'T\M O PA4 M F r~ntw thPNr1 A "r"T A f 44 E n w it e e.14 r - ,c e . , : c.,a w r o > s Page 1 of NUCLEAR COMMON Page 1 of 4 Revision 4 EXHIBIT'- N CEn 1- 9.;-013 hp.o '
PAGE / _OF 3 P[GE(S)' ,
, '. L, COMMENTS ATTACIIED TO RCS DEQ
[1] AS IDENTIFIED IN THE MEC 93 917, THE CALCULATED MAXIMUM PRESSURES AGAINST THE APPENDIX G ALLOWABLE PRESSURE ARE AS FOLLOWS FOR SALEM 1&2.
UNIT RCP IN CALCULATED MAX. TECH. SPEC P/T SERVICE PSEG' PSEG 1 2 485 450 1 A 477 -
450 2 2 485 475 2 1 477 475 -
[2] AS IDENTIFIED IN THE MEC-93-917, ADDITIONAL MARGIN IN THE TECH SPEC CURVES CAN BE GAINED FOR THE LTOP APPLICATION BY TAKING CREDIT FOR ASME CODE CASE N514. THIS CODE CASE STATES "LTOP SYSTEMS SHALL LIMIT THE MAXIMUM PRESSURE IN THE VESSEL TO 110% OF THE PRESSURE DETERMINED TO SATISFY APPENDIX G OF SECTION XI, ARTICLE G 2215". BY TAXING CREDIT FOR THIS CODE CASE, THE ALLOWABLE PRESSURE CAN BE INCREASED BY 10 %. IN THIS CASE ThE LOWEST PRESSURE THAT MUST NOT EXCEED IS 495 PSIG FOR SALEM 1 AND 522.5 PSIG ON UNIT 2.
THIS WILL ELIMINATE THIS DEF. DISCREPANCY, IF APPROVED..USE OF THE CODE CASE HAS BEEN RELIED UPON BY OTHER UTILITY (FP
&L). HOWEVER, USE OF CODE CASE WILL REQUIRE NRC PERMISSION AND POSSIBLE REVISION OF TECH SPEC CURVES TO ADDRESS 10 %
INCREASE.
[31 LIMITING THE RCP OPERATION TO NO MORE THAN 2 RCPS IN yS MODE 5 IS ALREADY INCLUDED IN THE CURRENT PLANT PROCEDURES.,.r.,,g N
[THROUGH IMPLEMENTATION OF PROCEDURE REVISION REQUEST'.,'4 9
'/
R07326]. PROCEDURE CHANGE TO LIMIT RCP OPERATION TO ONE PUMP- '
IN OPERATION IS BEING PURSUED BY THE SYSTEM ENGINEER.
[4] THE CJRRENT PLANT DESIGN RELIES ON ONE PORV SET AT 375 PSIG.
[5] ORIGINAL RHR DESIGN AT SALEM INCLUDED AUTO. CLOSURE (ACI)
INTERLOCK OF RH 1 & 2 VALVES TIED TO PT403 AND PT405 PRESSURE > 375 PSIG. SALEM UNITS REMOVED THESE ACI THROUGH DCPS. BASED ON WESTINGHOUSE WCAP 11640, IF THE ACI IS REMOVED, THEN THE INADVERTENT ISOLATION OF THE RER RELIEF VALVE IS CONSIDERED TO BE HIG9LY UNLIKELY. RHR RELIEF VALVES ARE TFEN AVAILkBLE TO MITIGATE. POTENTIAL LOW TEMPERATURE OVER PRESSURE TRANSIENTS. THE RELIEF VALVE SET POINT OF SALEM UNITS ALON", WITH THE RH3 VALVE CAPACITY WERE GENERICALLY EVALUATED BY WOG TO BE ADEQUATE TO PROVIDE APPENDIX G PROTECTION WITHOUT RELYING ON THE USE OF PORVS FCR LTOP. ALTHOUGH THE PLANT SPECIFIC ANALYSIS FOR LTOP SYSTEM USING Rii3 RELIEF VALVE IS NOT COMPLETED YET, THE RESULTS ARE EXPECTED TO PRODUCE PEAK PRESSURE WITHIN THE 10 EX Bli N.
PAGE odP GE(S) i
. o
% ACCUMULATION OF THE SET PRESSURE. ADDITION OF PRESSURE DIFFERENCE BASED ON ONE RCP WILL PRODUCE ACCEPTABLE !
RESULTS. (INITIAL ANALYSIS COMPLETED TAKING CREDIT FOR RH3
- PROVIDES PEAK PRESSURE FOR MASS INPUT CASE SUCH THAT THE CURRENT THE HEAT INPUT TFCH CASE SPECS HAS CANNOT BEBEEN MET WITHOUT COMPLETED, THE USE BUT IS OF CODE LIKELY TOCASE.1 -
BE NON LIMITING CONSIDERING THE CURRENT DESIGN FOR WHICH THE '
HEAT INPUT CASE IS NOT LIMITING.] }
[6] UPON COMPLETION OF THE RH3 UIOP CALCULATION, THE SALEM !
FSAR WILL HAVE TO BE REVISED THROUGH A 10CFR 50.59 J FVALUATION. TECH SPEC RWISION IS NOT EXPECTRD, BUT IF .
MANDATED, LCR WILL HAVE TO BE GENERATED.
(7) THE DISCREPANCY IDENTIFIED IN THE DEF CAN BE RESOLVED i THROUGH ONE OF THE FOLLOWING APPROACHES: ;
+
(A) GETTING ASME CODE CASE N514 APPROVED BY NRC FOR SALEM.
INCIDENTALLY, THE CODE CASE HAS NOW BEEN INCLUDED IN THE ASME XI THROUGH 1993 ADDENDUM. t
, OR (B) . COMPLETING THE CALCULATION FOR LTOP USING RH3 VALVE AND j REVISING PLANT DESIGN BASIS. .
P' -
' (8) THIS DEF IS NOT CONSIDERED AN OPFVuILITY CONCERN TAKING l THE CREDIT FOR CODE CASE 514 OR THE 1993 ADDENDUM OF AS !
XI. 9f, 4
e EXHEIT PAGE d 0FdPAGE(S) '
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Case No. 1 95 013 Exhibit 22
______._,_._.-__. _ .- _.-- -~-
v2 wu6nu ersuunnca annurACK MEETIND STATION:- /b DATE: __
/ /
R&A AGENDA ITEi1 No. PROSPECTIVE SPONSOR SUBJECT PRIORITY AESIGNEE
' SS $h
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._ COMMENTS ATTENDEES:
General Manager / /* Maintenance Manager / Alternate /Z/ Operations Manager / Alternate /,__/ ,
, RP/ Chemistry Manager /Z/ Alternate Technical Manager /Z/ Alternate ,
hk other SehIY:E-[Ge) R&A Representative:_ MWic Stkkuv /mtW3 /c.hrrom.ask!/- EXH TM CASENO. 1 - {} ; - 013 / "0 PAGE / OF 9 PAGE(S)
--------------------- ACTION TRACKING ITEM RESPONSE ---------------PAGE 1 OF 1-COMMAND INPUT ===d DISPIAY MODE URCEt NRC_, TYPE: INFO I'IEM NO: 93-58 !' ' '
================================= RESPONSE ====a==========================="
- REFER TO WEST NSAL 93-204 1
* " ~ ~ ~
ITEM ALSO SENT TO E&PB FOR ADDITIONAL INFORMATION APO. DISTRIBUTED AT SALEM OEF MANAGERS MEETING ON 8/4/93 FOR INFORMATIOh TO THE SYSTEM ER51C ,Z':', .
% v...~
~~ 15
-j MESSAGEt ENTER 'HEXT' TO VIEW NEXT SCREEN, 'PF4' TO RETURN TO HEADER B MY JOB LU #15 !
l
~
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hl Y
--------------------- ACTION TRACKING TASK RESPONSE ---~~~---------PhcE 1 OF 1-COMMAND INPUT ===> DISPLAY MODE LAST UPDATE: 05/31/94 BY JRH SURCE: WEST TYPE: HSAL ITEM NO: PSE-93-204 -
c,=========================== ITEM RESPONSE ====m============================= b 91 THIS HSAL DEALS WITH Tile COLD OVERPRESSURE MITIGATION (COMS) NON-06V2 CONSERVATISM.
,.,t=============== u======== TASK RESPONSE =================='a==========e====
. TASK HO: 0001 ,- EVALUATION IS COMPLETE. APPROAcil TAKEN TO RESOLVE ISSUE CONSISTS OF 1)__, 1 RESTRICTING Tl!E NUMBER OF RCP'S WilICH CAN BE IN OPERATION IN MODE 5 TO ~ 2 2 RCP"S AND 2) TAKING INTO ACCOUNT Tile 10% RELAXATION OF THE TECli. SPEC 3 IIEATUP AND COOLDOWN LIMITS PERMITTED BY ASME CODE CASE N-514. DOCUMENTA- 4 TION OF EVALUATION IN PROGRESS. 5
*SEE MECilANICAL MEMO MEC-93-917, DATED 12/30/93. IN
SUMMARY
, THE RECOM _ 6 HENDED RESTRICTIONS ABOVE SHOULD DE PROCEDURALIZE
D. PROCEDURE
CilANGE REQ ~ 7 IS BEING ISSUED TO OPERATIONS TO AFFECT THE CilANGE TO REVISE IOP -2 AND 8 IOP - 6 FOR SALEM UNITS I AND 2. THIS ATS ITEM IS CONSIDERED CI4 SED FOR- ~ 9 SALEM MECllANICAL NSSS GROUP, *HGB 12/29/93* 10 UPDATE:5/1/94: ITEM REJECTED BY STATION---REOPENED FOR E&PB TO REDO EVL 11 MESSAGE: ENTER 'NEXT' TO VIEW NEXT SCREEN, 'PF4' TO RETURN TO HEADER B MY JOB TIME LU #15
------------ .-------- AC'..' ION TRACKING TAS K RES PONS E ---------------PAGE 1 OF 1-COMMAND INPUT ===> __ DISPLAY MODE
. LAST UPDATE: 05/31/94 BY: JRH SOURCE: WEST TYPE: NSAL ITJM NO: PSE-93-204
==========================i'=== ITEM RESPONSE ==================================
9001 Ti!IS NSAL DEALS WITH THE COLD OVERPRESSURE MITIGATION (COMS) NON-J002 CONSERVATISM.
================= m=,=====1=== TASK RESPONSE ==================================
TASK NO: 0001 FOLLOWING CONVERSATIONS WI"Il STATION AND LICENSING, MECHANICAL MEMO MEC- 12 93-917 WAS REVISITED AND RE-ISSUED AS MEC-94-630. THIS MEMO PROVIDES Ti!E 13 REVISED JUSTIFICATION FOR OPERATION AS IS WITHOUT RELYING ON CODE CASE 14 N514. Ti!IS MEMO ALSO RECOMMEND Tile PURSUIT OF CODE CASE APPROVAL AND TIIE 15 SUBMITTAL OF A LCR FOR CRED7 TING RH3. TIIIS WILL PROVIDE FUTURE MARGIN._,,_ 16 TlilS ATS TASK 10 CONSIDERED CLOSED. ***HGB/MRD 05/26/94*** 17 MESSAGE: NO MORE DATA TO SCROLL IN FORWARD DIRECTION B MY JOB LU #15 c, a I 4 'JW. mn Y$ $ he /h L gm Y j Y 7 y] c& f M /y . ca% 2b h/ 2/n aj al14 exn ,r y PAGE OF E PAGE(S)
NC.NA.AP.ZZ 0054
^ '
5.2.3 After detennining the need for further evaluation, the sponsor department should negotiate a task assignment and an appropriate evaluation period based upon priorities established'in NC.NA AP.ZZ 0057(Q), Action Tracking System, Appendix D. . NOTE The evaluation period is discussed between the sponsor and responsible department and resolved based upon the severity of the issue or by the agency issuing the document. One extension to the committed due date will be considered for extension requests signed by the department manager. Following agreement the sponsor should: - l t
~
A. Enter the task assignment into the ATS IAW NC.NA AP.ZZ-0057(O) or CADB. OEF documents not requiring any follow up action should be inputted into the ATS/CADB with key words and cross references for future retrieval purposes (sponsor judgement). B. Prepare an assignment package to include:
+ NC.NA AP.ZZ-0057(O), Attachment 2, Action Request Form, with Section
. I completed including a clear concise task assignment
+ A copy of the original document
+ All pertinent information obtained during the screening process, including copies of reference documents C. Forward an assignment package, to the responsible department / coordinator.
5.2.4 The responsible department / coordinator should review an event utilizing the following , guidelines: - . A. Determine the implications or effects on personnel, operations, equipment, design, envir'onmental qualification (EO), current practices, and procedures. . B. Initiate requests for assistance in performing multi discipline review of complex events. It is the assigned department's responsibility to assure that the assistance requested receives the proper attention to complete the task. C. Inteniew personnel associated with the issue. D. Review previous events, both external and internal. Assistance may be required. Nuclear Common Page 9 of 18 Rev.2 EXJH BIT M PAGE 7 _OF I PAGE(S)
5.2.1 Continued NOTE INPO SOERs, SERs, sos, and SENs and NRC Bulletins, Generic Letters and Information Notices are classified as significant since the agencies have thoroughly evaluated the particular issue and issued the document. The screening process only evaluates applicability to llope Creek and Salem. If the issue is applicable, an evaluation is required. A. Screen to deictmine issue significance utilizing the INPO EVENT SIGNIFICANCE GUIDE (Exhibit 1). In addition:
+ Consideration should be based upon specific component and generic issues. ,
+ Perform searches (internal events, OEF documents and NPRDS) to determine if a similar occurrence has been previously dispositioned and if that previous disposition is currently suitable.
+ Include the bases for judgements.in the documentation for future reference.
+ Communicate events considered of high importance to the appropriate departments as soon as possible.
+ Defects or non compliance issues that have been transferred to PSE&O under 10CFR21.21(b) shall be evaluated. The assigned responsible department should provide the evaluation by completing Form NC.NA-AP.ZZ-00541 to c etermine whether the potential reportable concern exists.
B. Screen for applicability to Hope Creek or Salem. 5.2.2 Events deemed applicable by the sponsor department but not requiring further evaluation 1 (based upon the severity of the issue) may be distributed as. "information only" to the appropriate department. The justification should be included in the disposition. ,I
+ Send event reports suitable for use in drill scenarios to the Emergency Preparedness Department.
+ INPO O&MRs and NEkWORK OEs are normally processed as ' info only" and addressed at the department's discretion. They can however, be evaluated as a significant issue when appropriate.
+ Send appropriate event reports to the training department for material to be presented in formal training programs.
Page 8 of 18 Rev.2 Nuclear Common EXHlBIT PAGE d Ob PAGE(S)
4.2 Procram Reautrements 4.2.1 Effectiveness of the OEF program should be rnonitored and resulu reported to management by means of performance indicators by the Reliability and Assessment Department. 4.2.2 Departments should use the ATS/CADB for tracking the status of OEF documents. 4.3 frocram BackgrQuad This procedure provides the overall direction for the Nuclear Department's implementation of NUREG O!37, Section I.C.S. 5.0 PROCEDURE . 5.1 Internal Events 5.1.1 The sponsor department (as defined in Section 6.0) for intemal events should review the event IAW procedures as indicated below:
+ NC.NA-AP.ZZ-00 6(Q), Incident Report / Reportable Event Program and Quality / Safety Concerns Reporting System
+ 'NC.NA-AP.ZZ-0061(Q), Significant Event Response Team Management
+ NC.NA AP.ZZ-0035(Q), Nuclear Licensing and Reporting
+ SC.RP TI.ZZ 1001(Q), Radiological Occurrence InvestigatJon 5.1.2 Station management or Reliability and Assessment personnel should recommend reporting significant intemal events to the other station and to the industry via Nuclear NETWORK as identified during their review process.
5.2 External Events 5.2.1 The sponsor department processes external event report: and requires an evaluation for documents which are significant and applicable as described below: Page 7 of 18 - Rev.2 . Nuclear Common EX IBlT PAGE__ _OF k PAGE(S)
PSE&G NUCLEAR DEPARTMENT Page1 of1 NC.NA-AP.Z7e0054 - OPERATING EXPERIENCE FEEDBACK (OEF) PROGRAM SPONSOR ORGANIZATION: Reliability & At=* cement REVISION
SUMMARY
+ Added NUREGS to Steps 2.2.3 and 6.13.
\
+ Changed titles per current organization titles. ;
L
+ Added 10CFR Part 21 requirements.to Steps 3.5,5.2.5.B. and 6.13.
+ Added Step 5.1.3. -
+ Added requirements for using Form NC.NA-AP.ZZ-0035-1 in Steps 5.2.1.A and 5.2.4.F.
+ Updated references to current revisions.
+ Updated Exhibit 1 to current SEE IN revision.
+ Changed shall to should to conform to the NC.NA-AP.ZZ-0001 revision.
+ Eliminated Form NC.NA-AP.ZZ-0054-1 and reused form number for Pt 21 purposes. l 4
APPROVED: Ge ra 9 [ ' [ alem Operations Dale / APPROVED * / % , 4[9'/ General Manager - Hdpc Creek Operations Date 1 EXylT$ PAGE
/ OF E PAGE(S)
Page 1 of a Part,G NoCLEAR DEPARTMExT CONTROL COPY # NC. NA-AP. 22-0 057 (Q) - Rev.2 ACTION TRACKING PROGRAM - SPONSOR ORGANIZATION: Engineering and Plant Betterment REVISION BUMMARY This is a Limited Revision to NC.NA-AP.ZZ-0057(Q) . * ' This Revision incorporates the following:
- 1. A request by QA to change Appendix D (Priority Classifications). Changes will provide a priority system consistant with the priorities in use by both stations per NAP-8 and NAP-9. ,
2 ., Deletion of. task status code "NEGO" (task under negotiation) from Section 5.1.1. The deleticn of this code will make the NAP consistent with the ATS program; tasks must be negotiated before they are entered into ATS.
- 3. Appendix A (Primary ATS Tracking Responsibilities) has -
been updated to include SOURCE / TYPES added to the Action Tracking System since Revision 1. IMPLEMENTATION REQUIREMENTS This procedure becomes effective on date of issuance. Retrofitting of priorities is not required but may be done at the sponsors discretion. The format of this procedure has been - changed to conform with NC.NA-AS.ZZ-0001(Q) - NUCLEAR LEDARTMENT PROCEDURE FORMAT AND CONTENT STANDARD. APPROVED: --
/2/N/gL.
Gen' al Mafia 'r - Engineering and / Dhte P nt Betterment CONCUR: V -
\1 \ V General 3 %)r '- Quality Assurance / ' Date el faty Review APPROVED: .
/ . b 8 8 GenefIl Mana dr'- Salem Operations D#te APPROVED: [ -_
_ /2"l_I "f2 Gene n' er - Hope Creek Operations Date EXHglT PAGE 7 0F_ Y PAGE(S)
{' . MC.HA-AP.22-0057(G> APPENDIX D PRIORITIES 4 PRIORITY DESCRIPTION , A Erargency work requiring immediate action. Includes issues with immediate e Nuclear, industrial, or radiological safety . consequences, e Regulatory significance including entering of action statements or notification of regulatory authorities.
~
B Action required to start as soon es possible
, normally no later than the next scheduled work day.
- 1. Problem, to which action is directed, is not threatening to safe plant operation, but may have adverse operational
- impact and should be addressed quickly - one to two weeks. There is clear potential for developing into a larger problem. May involve significant regulatory commitment compliance.
- 2. Problem, to which action is directed, is not expected to develop into a larger problem in the near future.
Should be addressed in the near term - three to six weeks. May involve regulatory or commitment compliance.
- 3.
- Minor deficiencies not affecting component operation '
and may include minor compliance issues, " nuisance" or
" eyesore" type situations. solutions should be implemented in seven to twenty weeks.
- 4. Plant betterment activities, general enhancements which would result in more effective, efficient or lower cost activities'. Greater than twenty waaka.
Nuclear Common Page 1 of 1 EXhIT Rev. 2 PAGE 7 0F 9 PAGE(S)
. . .. . _ -}}