ML20199L634
| ML20199L634 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1994 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20199L462 | List: |
| References | |
| FOIA-97-325 NUDOCS 9712020076 | |
| Download: ML20199L634 (69) | |
Text
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4 1 1 MITED STATES OF AMERICA -
2 NUCLEAR REGULATORY COMMISSION !
+
3 +++++
4 OFFICE OF, INVESTIGATION t
5 INTERVIEW !
6 ,
7 ------------------------------x 8 IN.THE MATER OF: :
9 -- INTERVIEW OF : Docket No. ,
MAHESH DANAK :(not assigned) 11 :
12 ------------------~~----~~----x i i 13 Tuesday, March 14, 1994 14 15 Administration Building
.16 2nd Floor Conference Room ,
l'7 Public Service Electric & Gas Co. .
18 Nuclear Business Unit 19 Hanc.)cks Bridge, N.J.,
20
,E_ 21 ~The above-entitled interview was conducted at
- a.
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22 3:06 p.m.
$,m --
BEFORE:
- u. 24 KEITH LOGAN, Investigator 4
R5 t a, as BRIxw scoERMOTT,. Investigator g_
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. l. 2 1 APPEARANCES:
2 On behalf of Mahesh nanak 3 MARK J. WETTERHAHN, ESQ.
4 MARCIA GELMAN, ESQ. )
i 5 Winston and Strawn ,
l 6 1400 L Street, N.W.
7 Washington, D.C. 20005-3502 i
8 9 ,
10 v
11 .
ll 12 i
13 14 15 '
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19 20 21 22 23 24 -
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PROCEEDINGS 2
3:06 p.m .
' l 3 MR. LOGAN: On the record. l 4 Whereupon !
5 MAHESH DANAK 6 havino been first duly sworn, was called as a witness 7 herein, and testified as_follows:
8 MR. LOGAN: Mr. Danak, if you would please state 9 your full name for the record spelling your last name.
10 '
THE WITNESS: Mahesh Danak. Last name is D-a-n-a-t 11 k. First name is Mahesh M like Michael a-h-e-s-h. I 12 MR. LOGAN: Okay. My name is Keith Logan. I am 13 an investigator for the U.S. Nuclear Regulatory Commission 14 King of Prussia, Pennsylvania. With me today is Mr. '
15 McDermott. Mr. McDermcitt . .
16 MR. McDERMOTT: My name is Brian McDermott. I 17 am'with the N.R.C.'s Region One Division of Reactor Safety 18 and Reactor Inspection.
19 MR. LOGAN: Mr. Danak, you are appearing here 20 today with counsel; is that correct?
21 THE WITNESS: Yes.
22 MR. LOGAN: Mr. Wetterhahn, if you would 23 identify yourself for the record please.
-24 MR. WETTERHAHN: For the record my name is Mark 25 certiJ. Wetterhahn.-I am with the firm of Winston and NEAL R. GROSS COURT REPORTERS AND TRANSC.J.8ERS 1323 RHODE ISLAND AVENUE, N W
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4 1 StrCwn, 1400 L. Stroot N.W., Washington, D.C. 20005. With 2 me is Marcia Gelman another attorney from the firm.
Together we are representing Mr. Danak.
3 For the record I 4 would like to note that we are also representing other 5
individuals in this case and also Public Service Electric 6 and Gas Company.
- 7 MR. LOGAN: And Mr. Danak, bearing in mind that 8 Mr. Wetterhahn represents other individuals including the 9 corporation in this case, is it still your desire to have 10 him here as your attorney today?
11 THE WITNESS: Yes.
12 MR. LOGAN: Thank you.
13 EXAMINATION 14 BY MR. LOGAN:
15 Q Mr. Danak, for the record by means of background 16 could you please tell us your present position with PSE&G 17 and other positions that you may have held here?
18 A I have been with Public Service since 1978. I 19 have been working in Systems for basically the same group 20 from day one. I have been working on the reactor systems 21 and a couple of other systems since I joined. Prior to 22 that I was working with Stone and Webster Company up in 23 New York and prior to that I was working with the 24 govelnment of India in the Department of Atomic Energy in 25 the scientific office.
i NEAL R. GROSS COURT REPORTER $ AND TRANSCRIBERS 1321 RHODE ISLAND AVENUE. N W_
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5 1 My current position with Public service is senior 2
staff engineer in Salem Mechanical Group which is part of 3 Engineering and Plant Betterment Department which is now i 4 called the Engineering Department. ;
5 Okay.
Q Do you know an individual by the name of 6 Chandra Lashkari?
7 A Yes.
8 O And when did you first meet Mr. Lashkari?
9 A He joined Public Service and I have forgot what 10 time around '84 or '85 time frame. We started working in 11 the same group.
17 Q And did you work on any projects. I realize you 13 said you were in the same group with him. Did you work on 14 any special projects together?
15 A Not any special projects together but basically 16 in Engineering you have like a peer review. He could be a 17 reviewer of if he was doing I could be the . reviewer. That 18 is the kind of relationship that we had.
19 Q Okay. What is your impression of his technical 20 ability as an engineer?
21 A He is a fine engineer.
22 Q And how did he get along with his co-workers?
23 A
/
Between the time that I was here he was here 24 with us in our department from 1984 or '85 and worked 25 there until maybe '88. That is the which I know him.
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, 6 1 Aftorwards I do not have day to day dealings with him. At t.
2 our end, I didn't know of any specific problems that he '
3 had with anyone in particular.
4 Q So he seemed to get along well with everybody?
5 A I think so. t 6 Q Mr. Danak, are you familiar with an issue called 7 POPS?
8 A Yes.
9 Q And when did you first become involved with the 10 POPS issue?
11 - A POPS is like an ongoing issue. It is like 12 basically our design, but in '93 and this was later 13 relating on based on incident or based on findings to make 14 sure that we have not made similar error. NS later 15 second called Nuclear Safety Letter. At that t ime it came 16 into light and at that time we became involves sith this 17 issue. O Okay. Who brought the POPS issue to 18 your attention?
19 A Basically it came from Westinghouse by a letter 20 which I-received that Charlie Lashkari had sent it to me.
21- Q- And did Mr. Lashkari call you. Did he send you 22 a letter-or a fax or did he talk to you about it at lunch.
! 23 How did he bring this to your attention?
L 24 A He just-faxed it to me.
i 25 Q Do you have a copy of the fax which Mr. Lashkari l'
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. 7 I cont to you? -
2 A Basically it is a Westinghouse letter but I !
3 didn't -- he sent it to me so that is how I got it, it 4 was sent on the Westinghouse letter but he must have 1 5 gotten a copy and he faxed it.
6 Q So what you have shown me is a ---
7 A Westinghouse letter basically.
8 Q It is a Westinghouse letter dated March 15, 1993 9 which at the top fax line indicates March 18, 1994; is 10 that correct?
11 A Correct. '94.
r 12 Q The letter is dated 1993.
13 MR. WETTERHAHN: Yes but the fax ---
14 MR. LOGAN: The fax is 1994.
15 THE WITNESD: Okay.
16 BY MR. LOGAN:
17 Q And what did Mr. Lashkari do. Did he call you l
18 after the letter or before the letter was faxed to you?
19 A Not on this letter because I would have i
20 independently known about it. This is the letter which I i
21 So this letter is not -- that is when I had in my file.
i l 22- was involved, I was involved before this letter was faxed 23 to me.
24 Q When did you become involved in this? t 25 A After this letter came out like they_ issued an NEAL R. GROSS COURT REPORTER $ AND TRANSCR$ERS 1323 RHODE ISLAND AVENUE. N W.
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. 8 I 1 ATS item on th2 trocking cyctsm that comeons h o to look !
i 2 at it and respond by I think like the end of December of 3 '93.
l 4 Q Do you have a copy of that assignment that you l 5 received?
f 6 A No, not with me.
7 Q Okay. Go ahesd.
8 A So basically once you get some kind of t
9 assignment and you have a certain deadline that you have _,
i 10 to have this done and closed and see the real significance 11 of what is being reported. This here we couldn't do it in l
12 house. So basically we went to Westinghouse to kind of 13 tell us for this issue we needed some calculations from 14 Westinghouse based on various pump cembinations one ,
M' 15 twoII , four phv N . We asked Westinghouse for the h.-
16 proposal.
17 Q Who is we?
18 A Our group.
19 Q In particular who supervised your group?
20 A Howard Berrick.
21 Q Okay. l 22 A We asked Westinghouse for the proposal and 23 Westinghouse sent us the proposal. We looked at the 24 proposal. It takes time to review the proposal and order -
25 it from Westinghouse so we asked Westinghouse to forward ,
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. 9 l 1 that ennlycio which they propocad and wa rocoivsd that. !
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2 Once we received this, we looked at it, digested kind cf 3 what it says and prepared our response based on 4 Westinghouse's analysis. Initially there was another 5 engineer who was working in our group who was also 6
involved. She wasn't with Public Service at the time. Her !
7 name is Gita Narsimman. She kind of initially picked it 8 up. I got .it at the tail end. She was working as a '
d '
9 condact for the person and then finally she was able to t, 10 kind of like -- she wks about to leave the company and at h 11 that point I picked it up.
12 MR. LOGAN: Excuse me. Cpuld we just stop for 13 one second.
14' MR. LOGAN: Sure. Off the record.
15 (Discussion off the record.)
16 MR. LOGAN: Back on the record. Go ahead.
17 THE WITNESS: So, once we received the work from d
18 Westinghouse we reviewed it in house and I responded. A 19 letter was initiated by someone and since she was leaving, 20 I picked it up and the letter was issued to station or not 21 the station but the A S was assigned to us by someone 3
A 22 called the Assessment Group. Any document that generally N 23- comes outside of the agency he handles it and he details 24 who should you review and assigns some kind of time limit 25 to it which it should be done.
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1 So, prob bly ct the ond -- tho docdlina was like the 2 31st so I responded in the time frame. The response which !
3 1 did we had no problem for basic reason that we exceed a 4 little bit pressure. There is a cer;e CodCnwL, L which was L
/M
$ll 5 already used by other utility light and power. While we 6 vere working we had another le'tter that other utilities 7 are using this especially brought up by Florida Power and 8 Light. So we used that kind of same technique and said we 9 exceed a little bit but there is nothing at that point.
10 We knew that and we knew this code case bounced up to 11 10 percent and we were within the code case. Our response 12 was based on that code case that accidents even thottgh it 13 is accident it is still within the limits of the code case
- 14 and we had no problem. That was the conclusion that we 15 made.
16 BY MR. McDERMOTT:
17 Q " hat conclusion that you are discussing, was i
18 that the one that is documented in a memorandum from 19 Howard Berrick Salem Mechanical Engineering supervisor to 20 Fred Schnarr of Reliability Assessment Group dated 21 December 30, 1993?
22 A Yes.
l- 23 0 Was there any discussion at the time this was 24 dispositioned that N.R.C. approval was required for use of 25 that ASME code case?
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. 11 1 A As for 03 --
I woon't thoro. As I cold I woo WOG ,
2 later.
3 Q WOG is? i
\
4 A Westinghouse owners Group. We were told that
. 5 other utilities were using it so since someone else has 6 been vaing it and knowing that it is not a concern as far
~
7 as we were concerned that look margin which we had on the 8 RH3 and at that point the RH3 was capable of providing the '
9 pumps and it was not part of our design basis, but knowing 10 that code caso was there we took it as the co e case is %
11 -valid and based on that code case we called it complete. e 12 O So what I understand your telling me is t!" you r
13 didn't feel there was a cafety concern because you knew 14 the code case was technically acceptable?
15 A Acceptable.
16 Q And that you also were aware that RH3 wasn't 17 available.
18 A That is correct. If I look at WOG's case the day 19 Public Service got licensed the which said we were
- 20 violating back in '77 when Public Service got licensed we.
21 were in violation in '77 even without this Westinghouse 22 advisory letter. Ever since the day when thq are h 23 getting better because all of the are based on 71'L ,
24 default chemistry materials.
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I got tha licanoa or toch cpac. Tha limit was balow 2 446. So we knew that the system was on low side. So we l
3 knew that this code case was approved. That was years- l i
4 back. We didn't kind of rely on that based on what we l 5 had before, but kno. ting that with this code case and RS3 j
6 based on that there was nothing there that the code case f 7 couldn't be used by others. It was reviewed by the 8 committee. That has some kind of lesson the fact that ;
9 other agencies had already used it. Other people had used j 10 it in the time frame of '93. As soon as the Westinghouse 11 advisory letter came out, other utilities had indicated 13 that they were using this.
13 Q What is the rortal process that you evaluated a 14 piece of industry information that came in. You 15 . determined that you needed to rely on the ASME code case.
16 What process what paperwork process initiated you to take 17 care of that?
18 A Basically the letter which you mentioned going' 19 to Fred Schnarr in that letter we say that the code case !
20 should be -- I might have a copy.
21 MR. WETTERHAHN: Is this it?
22 THE WITNESS: Yes, that is it. So basically it 23 says that the only change should be incorporated and they 24 are.done in parallel. Like Charlie Lashkari initiated 25- making those changes on the number of pumps. At that point '
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wa ocid thic coda ecca io tharo end ccm3 to tha concluci'on
- 2 that we are not in violation. We do not have a safety 3 concern.
4 BY MR. McDERMOTTt 5 Q Okay, but as far as what process was initiated 6 to take credit for the code case. It was not generically 7 approved by the N.R.C. so what needed to be done to have 8 that approved. Would that be the responsibility of the 9 Engineering Department to take care of that?
10 A Normally when i:..in thing was done it was 11 believed that the code case is like available to the users 12 since other utilities had used it I am talking about them.
13 If you ask me now yes we should have brought the code case 14 and talked to them and Licensing would have done it. When 15 we subsequently did this work and got this approved, we 16 made a submittal to N.K.C.
17 O Okay, but at the time back in this December time 18 frame when you recognized that you needed as an engineer 19 when you recognized that you needed the code case and 20 N.R.C. approval was needed for that, was Licensing brought 21 into that?
22 A Licensing knew that we had planned to use this 23 code case.
24 0 In December of '93?
25 A Earlier thaa that. Someone elce was working and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) F344433 W ASHNGTON. O C 20005 (202) 734 4433
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if you look ct thio Jntor, th? initici one of this letter 1
M 2 is M 3 BY MR.-LOGAN:
4 Q What is the date on the letter you are referring j -5 to?
1
. i 6 A Letter is 12/30/93.- ;
7 Q From whom? I 8 A From Howard Berrick to Fred Schnarr. If you look !
9 at the initials it was originally done by GN. The letter ,
10 was done and I came back picked it up. This was by her '
11 and the Licensing Department. I have seen a copy of the 12 letter that Licensing looked at it. So Licensing was i
! 13 familiar that we were trying to rely on it. t 14 MR. McDERMOTT: Okay. ;
15 THE WITNESS: So I J.icked up the letter and she 16 was like this was like the last week when she was ready to '
17 leave. I picked up this end and reread this letter.
18 BY MR. McDERNOTT 19 Q Okay. Are any of the other CC's at the end of 20 this letter here would any of those indicate to me that
, 21 this was forwarded to the Licensing Department?
22 A No unfortunately not. It was with Licensing but 23 the copies which.I see here it doesn't indicate that it 24 went to Licensing.
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15 l 1 want from thic point on? !
2 A From this point on like-as far as technical we l
3 said that'we made this commitment so we are like not -- I ;
i 4 was not happy about it. Sometime down the road a couple 1 5 of months later Charlie was kind of mentioning to close 6 the item but we should try to get this code case approved.
7 At that time I said okay that_is a task that has to be 8 done. While we were discussing this code caso; a couple [
9 of moitths down the road in that time frame we figured out ;
10 that since we needed the code case approval, what happens in between. So based on my discussions with Charlie 11 l
t 12 we had to get it and I said where do we stand today. We { .
13 do not have the approval.
14 Q When was that question raised? !
4 15 A I think around like March time frame.
16' Q Did Mr. Lashkari ever show you the draft j 17 incident support I have one here dated January 31, 1994-on l 18 this issue?
19 A No , I didn't see this. As I said it was some ?
a 20 time period that we could not use this one since we were 21 relying on this code case. There is not.iike any kind of ;
22: paperwork between us and Charlie Lashkari telling that we ,
i i 23 couldn't use-the code case.
Since I talked to him, I l ~ 24 initiated a deficiency report or some kind of problem .
i 25 report telling that.
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16 1 0 That was in April.
2 A In April.
3 0 Okay, but just for a moment let's stick with !
4 this draft incident report that l'r. Lashkari wrote on 5 January 31. In your reading of it, ---
~
6 A Could I read it.
7 MR. LOGAN: Please.
8 MR McDERMOTT: Please do.
9 (Pause while witness examines the document.)
10 THE WITNESS: Yes. dasically it talks about the 11 issue. It doesn't talk about the code case in this.
12 BY MR. McDERMOTT:
13 Q Okay. As far as the engineering facts in there, 14 does it reasonably reflect what you understood to be the 15 situation at that point in time?
16 A As I said if you are asking this point in time 17 on January 31st around the end of the month I do not 18 really exact what time frame, but since I wrote this I 19 sometime in that period, I would have counted a couple of 20 days before I wrote this problem report on the deficiency 21 report. I tend to kind of believe and agree with him that 22 it was used. We had to have it approved and until that it 23 is done, we are in some kind of situation where you have 24 got outside normal design basis.
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2 A Yes. tJoril that code case is approved. It was 3 until that code case was approved. We would have not met 4 the considerations spelled cut in Westinghouse letters.
5 That was the purpose of me writing the report.
6 Q Okay. Let's talk then about the deficiency 7 evaluation form that you wrote in April. I have a copy of 8 one here number 94-0060.
9 A Yes okay.
10 0 Is that the one that you are referring to?
11 A Yes.
12 O Okay. So in that DEF do.you recognize that use 13 of the code case will require N.R.C. permission?
14 A It says if it is removed -- unless code case 15 credit is taken then we could have been some while. We 16 did not meet this Westinghouse requirement until the code 17 case gets approved. That was the DEF that I wrote.
18 Q Okay.
19 A Normally once I write this thing, it goes to 20 Charlie Lashkari by procedure. As soon as I write it, I 21 hand it over to him and he is take it from here what to do 22 with this. We acknowicdge that we are in a deficiency 23 here and we knew the code case wasn't approved.
l 24 Q Okay. On the front of the DEF form we are 25 referring to operability concern is checked off as no?
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18 1 A Right.
~
2 Q Who made that decision?
3 A I made that decision.
l 4 Q And was there concurrence on that from your 5 supervisor?
6 A Yes by his signature.
7 (, The supervisor was Howard Berrick?
8 A Yes.
9 Q What was your basis for saying this was not an 10 operability concern?
11 , A It could be -- as I mantioned before the RH3 was' 12 in service --- '
13 Q Was the RH3 valve part of the POPS system?
14 A No, it is not but plus when we wrote this 15 . report, I do not know what more this unit was. The unit 16 could be and maybe the day I wrote it you are not relying 17 on this and that could be.
18 0 But whenever you shut the plant down or actually 19 transitioned, the system would be required.
20 A I agree. I do not recollect what the plant 21 status was but the date that I wrote it that could have 22 been nnother consideration which I do not recollect, i
23 Q Okay I understand that and just for the record 24 to clarify for everyone here the POPS system is not 25 required to be operable unless the reactor coolant system '
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. 19 1 is below 312 degrees.
2 A Right.
3 O So what Mr. Danak is saying is that on the day 4 this was this DEF was ti-itten that perhaps the plant was 5 not in that condition so therefore it may not have been 6 considered an immed,iate operability concern.
7 A Yes.
8 Q However eventually the plant will be shut down.
9 A The main reason was in my mind this kind of 10 there were a lot of -- even though we had some issues like 11
- being involved in the system from a safety point of view, 12 that a lot of other companies and if I looked at the old 13 ones from day one if I looked at that why was the plant 14 licensed the way it was, butifIlookatthehistorybackl 15 'and it indicates to me that this is a concern but it is 16 not an operability concern for the system. Not being able ,
17 to function, the valve would open at a point. The only 18 thing it could go a little bit higher and knowing that it 19 went a little bit higher it was within the safety limits 20 in the code case.
21 Q How would you define that the POPS system is 22 operable. Where would you look for a description of the 23 system that wo~13 ---
24 A It should meet the design basis the way it was 25 designed.
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. 20 1 Q And did it meet that design basis at that point l
2 in time?
3 A At this point in time its operability concern is 4 we knew about the RH3.
5 Q That is the safety concern aspect.
6 A Okay. .
7 Q Operability concern as a 3 icensing issue did the 8 system -- was the system capable of meeting its design 9 basis?
10 A Yes. The interpretation that I would have taken 11 at that point when I wrote this there is nothing that this 12 will -- it is operability is one thing and the second 13 thing is anything inoperable like when a valve or a pump 14 is not operable so that kind of concern wasn't there. We 15 kind of had -- it is like operability is defined if I have 16 a pump that is operable, the pump is being demonstrated 17 that it runs, 18 The same thing. If the system is capable of doing its 19 function and from that perspective there is nothing kind 20 of a disabling feature in the system.
21 Q Dut the POPS system as defined in the tech specs 22 as being the two PORV's either which can mitigate the 23 transient, that statement would no longer be true at this ,
24 point in time; correct. You needed to count on the RH3 25 valve; is that correct?
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. 21 1 A Yoo. As 1 ocy oparcbility is kind of en 2 interpret tion. Since the safety was already Q
( advised 3
wfien I looked at it there are two columns to J h 4 check. One is safety concern so I checked the sefety 5 concern yes. So I acknowledged tkhe design basis. That was 6 one way of looking at i t n" ' year back. Optrability 7 concern there is nothi . e -ble and the safety concern 8 yes there is a safety > T. w-n '~
t I could go outside of 9 the design basis.
10 Otherwise the. safety concern was like I should have 11 been within my design basis and that was if I checked 12 safety concern no then I would have checked here 11 operability concern yes but since I checked the safety 14 concern as yes then it is an issue. It is -- there is a 15 r:afety issue involved and the fact that I am writing this 16 deficiency report it tells that I am'outside of the design 17 basis. That was the purpose of writing this deficiency 18 report.
19 0 Okay, I am just trying to understand from the 20 description that you gave me it sounded like you weren't 21 worried about the plant being saved.
22 A No.
23 Q But you had a concern that the system may not 24 meet its design basis? '
25 A When I said safety concern yes that was my NEAL R, GROSS COURT REPORTERS AND TRANSCRIBERS
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22 i 1 intent that tha cyctcm is oparcblo. It may not m:st tha 2 function. With this new requirement it may not meet that 3 without the code case.
4 Q It just appearu to be reading this form that it 5 is almost like they are reversed.
, 6 A As I said it is I could operate it but I' felt
/ \k f 7 there was a safety concern involved because F'could be g
8 outside the design basis. There was nothing inoperable as 9 far as the system.
10 Q How is this document then handled when you have 11 a safety concern?
12 A This document in the normal process I initiate 13 this and then someone has to take it here and Charlie 14 Lashkari being the system engineer has to make a call 15 whether it is reportable or whether he has to go ahead in 16 wri ting . So this is kind of before I sent this to 17 Charlie, I had to talk to system engineer that I am 18 writing this thing. Basically I tell him when I talk to 19 him that I am writing an incident report and he says okay 20 he agrees with me. If he had any problem with this kind 21 of write up, it is picked up at that point.
22 So I notified and faxed him the copy that this is in 23 writing and I am confident that this is it. This is when I 14 say I wrote this and Dave was notified and he knew about 25 this was coming to him.
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23 1 Q Okay.
So you wrote the DEF and sent a copy to 2 Mr. Lashkari?
3 A Yes. He was the first recipient as soon as this 4 was issued.
5 Q Did you feel that an incident report should have
~
6 been generated based on your knowledge of the issues?
7 A Even if I look at the check marks I can see 8 someone and I must have let .t blank. If 1 look at the 9 check marks it is just like the way I look at it somewhere 10 down the road it was changed. I was just looking at my 11 yes marks. It was filled in.
12 O After the fact?
13 A It might have because the copy looks like it 14 should have been done before it got issued from my end, 15 but based on my discussion with him or based on my 16 supervisor's input this was collected.
17 BY MR. LOGAN:
18 Q Between January and April is there anything else 19 that you did on the POPS issue that you haven't told us 20 just in that time period January to April?
21 A April of '937 22 Q '93 or I am sorry '94.
23 MR. WETTERHAHN: '94 between January and April 24 of '94, 25 MR. LOGAN: Correct.
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- l 24 1
THE WITNESS: I don't think co.
2 BY MR. WETTERHAHN:
3 Q Were there any discussions with other people 4
during that period of timc. Do you recall any? "
5 A Only I recall like after I issued Charlie kind 6
of not knowing at the time he said that we had to get this 7 code case approved. I say okay we will have to do that.
8 We mentioned and I kind of agreed with him like okay. Now
.i 9 since we needed to go for the relief, I do not know how 10 long it takes and until then there we are. Based on 11 that, I agreed that we are in violation. s ,
That is when w "
12 P wrote this deficiency report. %
t) 6C 13 BY MR. LOGAF:
Y 14 Q And that wal written in?
15 A April.
16 Q April of?
17 A '94.
18 Of Q '94. Now I would like to talk to you about 19 an IR that was prepared in April of '94. It goes to the 20 involvement with Ken O'Gara. Did you discuss with Mr.
21 O'Gara his draft incident report in April of 1994?
22 A The way I think if I -- once I sent,this one to 23 Charlie, I think Charlie kind of requesting Licensing to 24 provide him a position on what should he write incident 25 report or not. That could be. That is why Licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON. D.C 20005 (202) 23W3
25 1 could huva been writing tho incid2nt report. Wa knOw
~
l l . 2 about this. We had a meeting after I wrote this. The 3 clock started on all this. So we kind of like stayed late "
4 kind of is there anything that we could do.
5 Since we identified the problem, this also lies on us 6 to find out how or where we had to go from here. So at 7 this point we went V:J. Chandra he has a Ph.D. and works 8
in our Mechanical Engineering. He used to work in Enginee6g /A D
9 Department. So we got together and I am not -- physically 10 do you have a copy of the Ken O'Gara incident report.
I 11 O Yes. Please continue.
12 A We got together and said where we are on this 13 and we had a problem. We issued this kind of thing issued 14 this IR do we hav3 a real issue. Is there kind of leaving 15 out or do we have a problem. So we went through looking 16 at his calculation, looked at the tech specs and kind of 17 part of this we said in the tech spec there is one way out 18 or not one way out but our tech spec kind of our design 19 tells us that injecting to water solid if we used our tech 20 spec as written which is my licensing business, I may not 21 have to penalize myself due to one or two reactor coolant 22 pump and those are things that we had discussed after we 23 issued this.
2'4 Q Do you recall attending a meeting about A st 25 20, 1994 on the POPS issue? Og)L. / /
ffj NEAL R. GROSS .
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202)2344433 WASHINGTON. D C. 20005 (202) 2344433
o 26 1 A It happened as soon as I went to this. .
~
2 Q Let me.show you an incident report cover sheet 3
and three draft incident reports and if you will look at 4 each of those and the top notes on the' cover sheet it has 5 April 20 meeting. The next one has April 20 draft. The 6 next one has April 20 meeting and the last one has 7 subsequent to April 20 meeting and if you will take a look 8
at these for a minute and then I would like to discuss 9 them with you.
10 MR. LOGAN: Off the record please.
11 (Off the record while witness reviews the documents.)
12 MR. LOGAN: Back on the record. I would just 13 like to correct something. I mentioned earlier an August 14 meeting. I was referring to an April meeting.
15 BY MR. LOGAN:
16 Q If we could you have had an opportunity now to 17 look at those draft incident reports; is that correct?
18 A Right.
19 0 Do you recognize any of them?
20 A I might have seen at this time frame when this 21 has been done.
22 Q Let me call yeur attention if I may to the 23 second one. That is the April 20 meeting report. It is in 24 the upper right hand corner. Mr. O'Gara has told us that 25 this was passed out to several people prior to the ineeting NEAL R. GROSS COUAT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W (202) 234-4433 WASHINGTON D C 20005 (202) 234-4433
~_
I 27 1
and that he had copies available at the meeting. Do you 2 recall getting a copy of this draft?
3 A Which meeting are you talking about?
4 Q The April 20th meeting. Do you recall getting a 5
copy of that at the April 20th meeting?
6 A I had seen it not whether I had it in hand at 7
this April 20th meeting. I might have been in. If Ken 8 O'Gara done it, I could have seen it.
9 Q Could have seen it but do you recall having seen 10 it?
11 A Not specifically I cannot recall right at this 12 moment.
13 O Do you recall any draft incident reports being 14 made available to you at the meeting?
15 A No.
16 Q Could they have been there and you don't recall 17 them?
18 A Charlie could have written them.
19 Q What I am saying is when you attended this 20 meeting on April 20th, could these report; or one of these 21 reports been given to you as an attendee at the meeting 22 and today you don't recall having received it?
23 A It was not like a formal meeting. The meeting 24 was not like a formal meating. I was working in my place 25 and finally we wound up in Frank Thomson's office. It was NEAL R. G3OSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOC ISLAND AVENUE. N W (202) 2344433
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U: -
28 liko a sit ; an m20 ting.
1 Thore wr.o not room to oit eo !
\
2 many people ir. the office.
3 Q So yo do recall a meeting?
4 A Yes a meeting. I was there at the meeting, u
5 Q :And who else was there'with you?
6 A My boss was there Howard Berrick, V.J. Chandra 7 our technical'consultiant was there, the licensing Ken 8 _O'Gara was there, Frank Thomson was there.
a 9 Q And at this meeting again I am going to ask you 10 do you recall having an incident report or a draft 11 incident report that wan being discussed? ~
12 A Not to my knowledge.
13 MR. LCGAN: Okay.
I 14 BY MR. McDERMOTT: 5 15 Q During that April 20th meeting,.do you recall 16 whether or not the POPS system was considered at that time 17 to meet its design basis?
18 A On the day?
- 19. Q Yes during that April 20th, were there 20 discussions regarding whether or not the system met it 21 design basis requirements?'
22- A- Yes. After we had a discussion at that point we 23 came to the conclusion that if I read my tech spec which-24 refers to injecting a water solid CS, based on that case k 25 it almost made it except for a couple of fei.me ^ch the EwSg
,- s NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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, v-, ,, -
, - , + -
' 29 1 PSI.
l So thnt wno kind of known at that tima that wa cro
}- 2 within compliance after writing this deficiency report.
3 Q That was based on what? -
4 A Based on the tech spec. As I mentioned to you, 5 what are the other avenues and we kind of read this again 6
literally read the tech spec and the tech Stsays 4C that the e
7 design base is based on mass injection input into a water 93 8
solidjECS and when the ACS is water solid we do not Q W
$,,\
9 operate the coolant pump. So we took the position that 10 sinceourbasisisawatersolid$bsinthat case reactor 11 coolant pumpo are not working.
12 We don't have to penalize ourselves by adding PSI as 285 13 a result of running.hSo based on that we said in talking 14 and confirming with our hydraulic people that this is what 15 I felt and in reading this we should be almost there 16 except for a fraction of PSI and that -- we can see it is 17 like minute increment, It is within the limit. Even if I 18 were to go and read thie. I cannot precisely even if I 19 went to it.
20 0 okay, but so your understanding at that meeting 21 was at that point the system was considered operable 22 because the pressurizer in the bubble would be available 23 when you had RCP's running.
l 24 A Right.
25 Q Okay, but as far as the original analysis which NEAL R. GRGSS Cour 6 PORTERS AND TRANSCRfBERS 1323 AH00E ISLAND AVENUE. N W (202) 234 4 433 WASHINGTON D C. 20005 (202) 234 4433
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o 30 1
. was the start of a single safety injection pump and its 2
injection into a water solid reactor coolant system --- -
t 3 A It doesn't bring a problem. If I was -- the 4
conclusion was that if I had the reactor coolant system 5
were solid and if I had a safety injection pump started, 6
it would not really impact it except for .7 PSI.
4 7 Q With a single PORV?
d A With a single PORV. That was the basis when we 9 closed this DEF.
10 Q What I am trying to understand is what had 11 changed between the December 30th memorandum which 12 initially closed out the issue which indicated for two 13 RCP's running the peak transient pressure would be 485 14 pounds.
15 A Right.
16 O Okay. What changed that between when this was 17 written in December and your meeting in April?
18 A When we wrote in December, we felt that since we 19 had the code case we didn't have to kind of go through 20 under microscope as long as we had the code case. In 21 December we felt with the code case we were coming out 22 okay.
Then we found out that we were not coming out okay.
23 We thought is there anything in the record and that was 24 after -- when I wrote this thing, that was the document 25 that I could be outside and then as I said it was looking NEAL R. GROSS COURT REPORTERS AND TRANSCRtSERS 1323 RMODE ISLAND AVENUE, N W. ;
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o 31 1
j 1 through anything.
2 At that point we decided that looking at the tech 3 spec we should not take this penalty for running the 4 reactor coolant pumps because the tech spec says that 5 water solid CS. So that was in December. Based on what j
)
6 we thought we had in the code case even though we were in ,
7 error at that time, we had plenty of margin. We said why 8 bother going under microscope. We kogw that we couldn't Add L 9 use this code case.
10 Let us sit again with respect to the plant design 11 - basis and the tech spec and reading from the tech spec we 12 came to the conclusion that we don't have to take a 13 penalty for running RCP at that point.
14 0 And that was based on how you operated?
15 A How we operated.
16 0 So essentially that was administrative controls 17 which would limit the situation. Was there any review at 18 that point of the administrative controls that were in 19 place when the POPS system was originally evaluated?
20 A This was long time. It is not something we did 21 and that was that. This is like we talked to plant 22 people. In a very short time there in water solid they 22 don't use the reactor coolant pumps. So we relied on the 24 administrative controls telling that using the exact tech 25 spec we justified that.
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. 2 1 Q l
l And to your knowlcdga wne tharo cny rovicw of.
2 the tech spec amendments that put the POPS system into the 3 unit one tech spee?
4 A Yes I looked at that. I don't know which 5 amendment you are talking about.
6 Q I am referring to the safety evaluation by the 7
N.R.C. related to amendment number 24 to the operating 8 license for unit one.
9 A The heat up and cool down?
10 No.
Q This amendment is the one that placed the 11 POPS system ---
12 MR. WETTERHAHN: Why don't we do this. Can you 13 proffer it to the witness ---
14 MR. McDERMOTT: Certainly.
15 MR. WETTERHAHN: And maybe that will end the 16 confusion.
17 MR. McDERMOTT: Okay. I will give him an 18 opportunity to review the document.
19 MR. WETTERHAHN: '
That is fine.
20 THE WITNESS: I want to look at which area of the 21 amendment.
22 MR. WETTERHAHN: Take a look at the amendment 23 and determine whether you relied on it.
24 THE WITNESS: Is there somebody who knows the 25 date of this amendment.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 2344433 WASH!NGTON. D C. 20005 (202) 2344433
33 1 MR. McDERMOTT: It is on tho lcat p293.
2 MR. WETTERHAHF: February 21, 1980.
3 THE WITNESS: Okay.
4 MR. WETT :
5 W<
co pany amendment.
/ Thatisthesafetyevaluationg,,/p_
Take a look at it and see if you g
6 looked at that.
7 THE WITNESS: Okay.
8 MR. LOGAN: Could we go off the record.
9 (Discucsion off the record.)
j 10 MR. LOGAN:
l Back on the record.
11 BY MR. McDERMOTT:
12, Q At this point Mr. Danak you have had an 1
13 opportunity to review the ---
14 A There are more questions if I could look.through 15 again.
16 0 Certainly. The question is basically when you 17 realized that these administrative controls had been in 18 place for a long time was tnat with knowledge that they 19 were considered in the original safety evaluation for the 20 system?
21 A No.
22 0 Okay. So ---
23 A The only thing even when this thing came out if 24 I looked at this we were in violation even if I looked at 25 the old codes. That was where I was before.
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..-- . 34
-- l - Q So.you cro saying tcking.tho Wootinghousa NSAL 2 concerns and going back in time?
3 A Going back in time. It was kind of way down.
4' I tried when I got the license I improved upon that. If I 5
used the Westinghouse information even the day -- even 6
without the Westinghouse information and the toch spec it 7
< was indicated when we made the submittal we felt that we 8 could go up to 423 PSI. That was part of the original 9 design basis that was submitted to N.R.C.
10 There were several cases identified noL 423 but like 11' 446 and at that point we said 446 was when this plant was-12 licensed. Even 446 wasn't meeting the requirements. At 13 that time it was down below. The day the plant was 14 licensed it was like I am talking about little .7 PSI, but 15 when the plant was -- even without-any changes the day it 16 got licensed if I looked at it even without this 17 Westinghouse 93 information not having any PSI my basic 18 thing was not -- the set point was less than 446 for both 19 units.
20 Q Okay. I am not aware of what you are 21 describing. All I have to go on is what is described in 22 the safety evaluation and that tells me that when this 23 i amendment was added to the technical specifications, that 24 the G curve limit was 460 PSI and the POPS system 25 WW\W as it was reviewed and approved for a mass addition '
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. 35 1_ trcnsient rcculting from the injoction of a safety -
2 injection pump into a cold solid reactor coolant system 3 would be limited to 446 pounds by a single PORV.
4 A If you look at the original one, this is the 5 amendment. The plant started in '77. This is like 1980.
6- MR. WETTERHAHN: Mahesh, are you saying that 7 that amendment was placed -- was granted or applied for 8 because there was a problem in the original design?
9 THE WITNESS: No. I don't know the background of 10 why this amendment was ---
11 BY MR. McDERMOT'." -
l 12 O The amendment was issued because the POPS system )
13 for a low temperature over pressure protection was not 14 initially part of the technical specifications for unit i 15 one. It was added after the technical specifications were 16 originally issued. That is where this amendment came 17 from.
18 A In that case I would have seen this later I
'p(
19 because this was the original one. I am. privy to that. -
$h 20 0- All we wanted to do was just clarify whether.or 21 not you were aware that the administrative controls that 22 you were relying upon to make the transient less limiting 23 were administrative controls that were in place when the 24 system was originally reviewe and approved by the N.R.C.
25 A From day one the administrative controls were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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i not near boing cut off.
} h 2 O Can you tell me about what actior.s were taken to 95 l
3 revise the mass addition transient itself subsequent to 4 April?
5 A Down the road?
6 O Right.
7 A At that point we found out that we are admitting 8 it. First my action was close this DEF and issue another 9 letter telling that I am'in compliance based on the new 10 interpretation.
11 Q Was that in the May 26, 1994 letter from Berrick 12 to Wiedemann?
13 A Yes, that is the one. So once I wrote this 14 letter, I also closed the DEF in that we are in full 15 compliance now. As was mentioned in this time frame we 16 had a couple of things we knew. Since we had talked about 17 using RH3 we kind of like in the Engineering Department we 18 kind of like started making some calculations taking the 19 RH3 and we found out if I use this RH3 do I get some 20 benefit.
21 So that calculation was done like in May and that was 22 done using RH3. So after this before this letter was 7 ,
23 written to Joba Wiedemann.it was like before that letter 24 we kind did some calculations taking credit for RH3 using 25 the Gothic Code.
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37 I 1 O Okny.
Can ws clerify though at this point you 2
didn't believe you needed to rely c,n RH3 becausa you had 3
, the May 26th letter which discussed the concept of having 4
a pressurizer bubble whenever you were in the RCP's.
5 A still kind of in this letter we said we exceed 6
by .7 PSI and I had mentioned that we ha'd RH3 also. It 7 was related. We knew that we already had this calculation 8 kind of done. There are some numbers in this May -- this 9
letter which is signed by John Wiedemann and it references 10 and uses a couple of numbers which we later on calculated 11 using RH3. The purpose of mentioning those was because 12 our interpretation that we had .7 PSI, if you read page 13 three of that letter ---
14 BY MR. LOGAN:
15 Q What letter is this again?
16 A This isCSD a letter from Howard Berrick to John 17 Wiedemann MEC 94 and in this letter it says it is based on 18 the informal calculations using Gothic helping re-estimate 19 the peak pressure.
It is informal because the calculation 20 was not signed off when this thing was done. I had some 21 reliance on RH3 for the .7 PSI.
22 BY MR. McDERMOTT:
23 Q But only for that .7. At what point did you 24 realize that the bubble theory was not acceptable and that 25 you needed to consider the reactor coolant system water NEAL R. GROSS COURT REPORTERS AND TRANS:%3ERS 1323 RHOOE ISLAND AVENUE. N W (202) 2344433 WASHINGTON D C 20005 (202) 234-4433
38 1 solid?
- 2 A When we did this calculation, we did this l
3 calculation using RH3 it got signed off sometime like 4 June. So we submitted this calculation to Licensing 5 telling that now you take this calculation and why don't 6 you submit a license, change request to take credit for 7 RH3. So they are looking at this calculation. When we 8 were doing this calculation, we said since we were 9 admitting all of those things, we were trying to find out 10 is there any other bond. t' that point we figured out that M 11 even though we assumed the reactor coolant pump is not 12 running, we had good credit coming from RH3. We can 13 change the design basis and see that it had a bubble 14 initially and then we lost the bubble and then it occurred 15 and we lost the bubble and eventually it became water 16 solid. So since the calculation which we did was reviewed 17 by Licensing and they are telling that if you are making 18 this assumption kind of taking this kind of conservatism 19 and taking credit for RH3, why we should not do one for 20 the current case which we had even though we had closed 21 the issue.
22 Q okay. When you changed what the mass addition 23 transient would be to one that I understand you believe is 24 more realistic and took credit for some of the 25 administrative controls limiting the mass edition to the NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. O C 20005 (202) 23< 5433
_ _ , ._ _ . _ _ - . _ _ _ _ . - _ . _ _ _ __ _ . = _ .
lli
. ). ^
1 rocctor vaccol, wco that noccapary to do that to justify-2 that the system could perform its function that'it was 3 operable?
4 A As I said after Licensing kind-of we talked to 5
Licensing thgy looked at this calculation and one of their ,
6 recommendations'we had met with Licensing and they told us 7
that based on this'we should write another incident report 1
8 or not an incident report but another problem report 9 telling that we identified a new scenario where we 10 initially had the bubble with the reactor coolant pump 11 running and,then you lost the bubble once it became-water 12 solid and that could be the more limiting case.
13 As soon as we did this calculation, we reviewed what 14 Licensing it was kind of after the meeting so immediately 15 I initiated another Encident or a problem report telling 16 we had found out a new scenario which we had not '
17 considered before.
j= 18 Q How wa,s that problem report then dispositioned?
19 A That problem report once we issued it we said we 20 had to close this one.
At that point we said let's re-i 21 calculate this more realistic again like using procedure.
22 The original design basis used SI pump but we-found out 23 the tagged SI pumps when they go why penalize ourselves 24 with 780 GPM of flow. My real maximum runoff from the -
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40 l' Ao only 560-GPM.
~-'
2 So we looked at the 560 GPM and kind of like found 3 out that with 560~would I exceed my Appendix G code and at 4 that point we found out.the figure of 560 GPM we do not 5 really exceed it.
6 Q- So at that point you transitionet from the 780 '
? GPM of the intermediate head safety injection pump'that 8
was used in the original analysis and now you are assuming 9
that the system has to mitigate the injection of a high 10 head or charging pump at 560 GPM. So you are making the 11 transient less limiting ---
12 A Less limiting.
13 O Did you do a 50.59 safety evaluation for that 14- change?
15 A Do. We had done the calculations. We had not 16 done a 50.59- Licensing when they told us to kind of look 17 at.it, they aaid kind of make the calculations for the 18 reduced f1cw with a more realistic flow if you could come 19 out okay. We took that since we were within the design 20 basis'because my flow is not going to exceed 560 GPM, as 21 long as we are not going to violate the tech spec so we 22 didn't at that point consider writing a 50.59, 23 We assumed like originally when we had 780 this was 24 -like don't call it any particular number. 780 was much 25 higher than even the SI pump. We-configured and we used NEAL R. GROSS COURT REPORTERS AND TRANSCRtBERS 1323 RHOOE ISLAND AVENUE, N W.
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. . . . . . . . . . . . . . ~ . . . , . . . ..% yv.... e,aa waL n we u m,e !
2 this'lowar numbar you will ba fine. .J 4
3' Q So please go~back^for me because my question was 4 if you now assumed a less limiting mass addition rate than 5- why is that not a change to'the design basis?-
6 A It is a change to the design basis system, but 7 based on Licensing told us to calculate this we like '
8 normally that kind of call if I had to change the design 9 basis Licens'ing was actually involved.- T' hey would have 10 told us and we would have done us. If they had sent us a 11 letter to do that kind of calculation, we said okay here 12 is this calculation and with this, this is what I get.
13 0 So are you telling me that the decision as to 14 whether or not this changed the design basis that decision 15 was up to the Licensing Department?
16- A It is not up to Licensing. It is everyone's 17 decision. Since this was already -- Licensing was already 18 part of it, we are kind of and I w&s under the impression 19 that.with the reduced flow I am coming out okay and we 20 didn't proceed to write the 50.59.
21- Q In the April -- let's go back to the April 20th 22 meeting. Up until-that point you were still using and 23 still assuming the design basis mass addition transient 24 described'the-tech spec basis; is that correct?
- 25 A Yes'because at that time we had not done the NEAL R. GROSS COUAT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON, D.C. 20005 (202) 2344433 t
4 +1.-n p .g -ny av-.- - ,.. , ,_,e , ,w,, y ., , , w ,-
42
! I calculations with Gothic. When we did this at this time 2
frame we didn't have any numbers using the alternate 3
method so we were relying on what was original design 4
basis based on 780 GPM.
5 0 And really you didn't have to change that 7.80 6
GPM assumption until after the pressurizer bubble fell 7 apart.
8 A Fell apart right.
9 O Were you of the opinion that a 50.59 evaluation 10 should be done for that type of change?
11 A Yes, it should be done.
12 MR. WETTERHAHN: I am sorry. What date are we 13 at?
14 MR. McDERMOTT: We are talking about the change 15 that came about when the problem report was issued saying 16 that the bubble theory should not be accepted.
17 THE WITNESS: That is under a more realistic 18 transient. Originally it was under tech spec. We don't 19 have to go that route based on what we used for the RH3 20 calculation, Licensing told us that.
21 BY MR. McDERMOTT:
22 O If you were going to take a literal-23 interpretation of your bases in your tech spac, why didn't 24 you have to consider during this entire time the injection 25 of the intermediate head safety injection pump into a cold NEAL P. GROSS i COURT HEPORTERS AND TRANSCRIBER 5 1323 RHOOE ISLAND AVENUE. N W
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colid rccctor coolent cystem if you are going to take the 2 words literally.
3 A Yes.
4 Q And that was not done.
5 A With the 460 we used 460. The thing which came 6 out like up until May 26th that was done. The cold water 7
solid LCS with the SI pump of 480, we still were admitting qg 8 because it was 446 and the only thing we took that we 9 didn't have to penalize ourselves for was running the 10 reactor coolant pump. Ac that point we were admitting the 11 . original design basis and we closed that.
12 0 Okay. I will just try to just clarify for 13 myself here what I think you were telling me. Up until 14 April the understanding was that the 780 GPM injection 15 -could be mitigated by ---
16 A Up until after we took the code case. Once we 17 found out that we cannot take credit for the code case, 18 that point we kind of tried to reinterpret the issue and 19 the tech spec and we looked at interpretation that since 20 it is based on water solid LCS, we don't have to penalize 21 ourselves with running the reactor coolant pump.
22 O So from December of '93 until April you were 23 relying on the code case. In April of '97'you ) Wrealized
)3 H 5
?
f 24 that you can't rely on the code case so we switched to ---
25 A The tech spec interpretation.
NEAL R. GROSS COURT REPORTERS AND TRANSCRI8ERS 1323 RHODE ISLAND AVENUE. N W (202) 234-4433 WASH!NGTON O C. 20005 (202) 2:4-4433
., . 44 1- .Q Yes in-considering-the bubble.. Then the bubble '
.2 is. good until the problem report was issued and that 3 problem report was' issued when?
- 4 A- Tha't was issued like September 27th.
5l Q Of 19947
'6 A '94 right.
. i 7 Q So in September of 'P4 you began to rely on a 8
new set of numbers for mass addition and.that is where we-9 got into the-discussion about whether or not the 50.59 was 10 required.
11 A That it right.
12 Q And-your understanding in the September time f
- 13 frame that we are discussing that no 50.59 safety 14 evaluation was done.
15 A That is right. !
16 BY MR WETTERHAHN:
17 O' Did you do a calculation in that time frame?
18 A Yes, we did-a calculation. As I mentioned we 19 finished the calculation.on May lith. That was with the
- 20 RH3-and in this time frame we also did a calculation like 21 the second set of calculations was. finished in like 22 December, but we had this number this.560 GPM. Basically 23 at that point when we did this RH3 calculaticn, we knew 24= the-pressure-was coming down.
25 Q Okay, but as of September you had preliminary.
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l
.~ calciulations that - considered the use of RH3.
2- A ~No. We had a final calculation. The '
3:
calculation for this RH3 was closed on -- that was .
r 4 finalized and signed on June 8, 1994.
5 Q- Okay. I am not aware of that.
During my
-6 inspection when I as);ed about that calculation I was told 7
in the mid December time frame that that calculation was 8 not yet reviewed and approved.
9 A
- This is the calculation. This I have a copy. .
10 This was signed and closed. As I said it was started up 11 in May. It took longer to verify, but the results that 12 calculation was finished in June. That is why I said 13 here is the results of this.
14 MR. LOGAN: What document is that?
15 MR..McDERMOTT: This is -- I am looking at 16 calculation S-C-RC-MDC-1358 REVO and it is titled LTOP 17 event with RH3 valve. Its approval date is 6/13/94 and it 18 is checked off.
19 MR. LOGAN: May I see it.
20 BY MR. McDERMOTT:
21 Q Okay. So by September you had a calculation to 22 support RH3 even though that was not part of the POPS 23 system but you knew it'wac there.
24 A' We knew it was there. '
25 0- As far.as calculations, calculations for the NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHODE IS:.AND AVENUE. N W.
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46 1
roviosd mass cddition transient that were relied upon
-2 after September after the problem-report when were those 3 calculations finalized?
-4 A That was~the REVO was done in December.
5 Q Perhaps that was the calculation that 1 was
~6 recalling a few minutes ago that were not finalized at the 7 time of my inspection.
8 A~
This was the second-calculation. -The first one 9
'was done before the inspection but the calculation using 10 this 560 GPM it was not finalized until -- it was issued 11 ot4 December 16th.
12 MR. LOGAN: What year? ,
13 THE WITNESS: '94.
14~ MR. WETTERHAHN: Do you have a copy of that?
15 THE WITNESS: Yes it is one or two pages.
16 MR. McDERMOTT: My on site inspection actually 17 ended three days after that date and those were the 18 calculations that ---
19 MR WETTERHAHN: Let's just find out if you have 20 that.
21 BY MR. McDERMOTT:
22 O Okay. The calculation we are discussing is i - 23 calculation S-C-RC-MDC-1413 REVO. It is checked off as 24 final and its approval date is signed 12/16/94. My 25 understanding and the title of this calculation of LTOP NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE tSLAND AVENUE, N W.
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47 1 ; events which one PORV.
My understanding of what this 2 calculation was to show was that once you had revised what 3 was considered to be injecting into the vessel in a lower 4 mass addition rate ---
5 A Right.
G Q ---
in September, that a single PORV could meet 7 its desian basis.
8 A With a reduced flow of 560 GPM which !3 the run 9
- 08. di o k flow. N 10 0 so that was taking credit for the administrative 11 controls.
12 A Right. ,
12 MR. WETTERHAHN: Can I take these.
14 BY MR. LOGAN:
15 Q Mr. Danak, do you have a chronolcgy of these 16 events that you brought with you?
17 A Yes, I do.
18 MR. LOGAN: Could I take a look at that please.
19 MR. WETTERHAHN: Let me take a look at it first.
20 MR. LOGAN: It might help us.
21 MR. WETTERHAHN: Show it to him.
22 MR. LOGAN: Let's go off the record for a minute 23 ,clease.
24 (Discussion off the record.)
25 MR. LOGAN: On the record. We have had an NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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I I 48 1 opport. unity te look Ct Mr. D nck'c chronological index of 2 principle LTOP documents. Mr. McDermott, which numbers 3 were you referring to?
4 MR. McDERMOTT: We were just discussing the 5 calculation that was approved on December 16, 1994 that is 6
item 14 on Mr. Danak'.s list and I would just like to 7 clarify that that was the revision that changed which 8 pumps could be injected.
9 'IHE WITNESS: R'ight based on the charging pump.
10 BY MR. McDERMOTT:
11 Q And I woulce also lika to just ask you again was 12 a 50.59 evaluation done for that?
13 A That is the only thing that we discussed was 14 50.59 when we lowered it to 560. We already discussed 15 that.
16 0 Yes we have already discussed that. I am just 17 reiterating. We discussed that. That was the calculation 18 we were talking about and that there was no 50.59 19 evaluation done in conjunction with that change to the 20 design basis.
21 MR. WETTERHAHN: To the best of your knowledge.
22 THE WITNESS: Yes. .
23 MR. McDERMOTT: Okay.
24 MR. LOGAN: Okay. If we could just get a copy 25 of the chronology to us.
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49 1
MR. WETTERHAHN: Cartcinly. W3 wall transmit it 2
to you as soon as we get back to Washington. r 3 MR. LOGAN: Thank you.
4 BY MR. LOGAN:
5 Q Mr. Danak, I would like to bring you back again 6 to this meeting in April and in your discussions with 7
those and others at that meeting did you hear anyone talk 8
about the merits of sending forward an incident report 9
based on possible penalties that might be imposed or the 10 shutdown of the plant that might result from that incident 11 , report?
12 A No.
13 o Did you hear anybody in particular say that if 14 the plant were to have to be shut down it would be a loss 15 .of about a million dollars a day whereas the fine the 16 N.R.C. would levy would only be a couple of hundred 17 thousand?
18 A No.
19 Q Have you ever heard anyone make that statement 20 either in jest or in ernest?
21 A Never.
22 Q Never at all?
23 A I heard when I was talking to Mark.
24 Q Mark made th:t statement?
25 A Mark did.
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50 2 BY MR. WETTERHAHN: -
2 O Did I ask you w') ether you had heard that 3 statement?
4 A Pardon me. ,
5 O In preparation my question ---
6 A Yes.
7 0 And you gave the same answer to r.e?
8 A I gave the same answer that I never heard it.
9 This is like because he was going through it with me.
10 BY MR. LOGAN:
11 Q But that didn't come up certainly at that 12 meeting from what you are telling me?
13 A Right.
14 0 And you have never heard anyone else at the 15 plant ever make statemente like that; is that correct?
16 A That is correct. No one kind of like no one was 17 gcis- t's like put their nose in. Outsiders really don't IP understand the whole thing.
19 MR. LOGAN: Let's go off the record for a 20 minute.
(
21 (Discussion off the record.)
22 MR. LOGAN: Back on the record.
- 23 MR. WETTERHAHN: Do you want to add something.
24 THE WITNESS: No , I think I understand. He knows 25 that. I think.there is nothing -- I just went through all NEAL R. GROSS COURT REPORTERS AND TRANSCRISERS 1323 RHODE ISLAND AVENUE, N W (202) 2344433 WASMtNGTON. D C. 20005 (202) 234 4433
51 1
of the documents knowing that I had open my flies and find 2
the documents and put in the prospects
- My memory is not 3
that sharp either. I just kind of ran through it and just 4 listed the documents and put my thoughts to it.
5 MR. WETTERHAHN: Okay.
6 BY MR. LOGAN:
7 0 Let me ask you if you have seen two other 8 documents Mr. Danak. The first one is an April 22nd 9
document from Mr. Lashkari to Mr. Morrison. The second one 10 is a January 30, 1994 document from Mr. Lashkari to the 11 Technical Department manager. They are each two pages 12 long. If you would look at them briefly.
10 A No, I have not seen those.
24 O Just take a look at them.
15 (Pause while witness reviews the documents.)
16 Q Having had an opportunity to look at those two 17 documents Mr. Danak ---
18 A This I looked at right now. I have not looked 19 at them before.
20 0 You haven't --
prior to this meeting you have 21 not seen either of these documents; is that correct?
22 A That is correct.
23 MR. LOGAN: That is all of the questions that I 24 have right now.
25 MR. McDERMOTT: Just one more before we go.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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52 1 BY MR. McDERMOTT: i l
a 2- Q In November of 1994 when the POPS issue was l
- 3. reported to the N.R.C., according to the 50.72 the report 4 said that the single PORV could no longer mitigate the
- 5 transient. I just wanted to ask you which-transient that 6 was.
- 7 A It was the PDP pump. The net.' transient which we f 8 found out that was reported. As soon as the report went ,
9 out, the PDP was already in service. Then at the start of 10 the charging pump, if I had an SI and the PDP was running 11 and I had a safety injection, the charging pump would come ,
12 on and PDP would keep on running and my let down would 13 isolate. That required 560 plus a coolant of one PDP pump.
14 It was 560 plus 100 GPM. When we looked at that,.,we 15 couldn't make that kind of conclusion.
16 Q But just to clarify it that the additional flow 17 from-the positive displacement pump the PDP was added to I i
- 18' the revised mass addition transient that was relied upon 19 starting in September. That was not in effect on the 20 original POPS design basis, j 21 A We didn't consider PDP before. When we got the l
22 ASME code letter this is what happened. One of the 23 managers the science managers he kind of mentioned about 24 how do you add this PDF. At that point we said okay. We 25 didn't consider PDP. That is when we went back and found f
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.. 53 1
out that W3 had ths PDP.
2 O- Okay. I just-wanted to clarify that the design 3 basis that was violated by the addition of the PDP was not !
4 the original design basis.
5 A That is-right. It was t.he one you had already 6 revised once in September. -
-. 3 7 A Right.
8 MR. McDERMOTT: Okay. Thank you.
9 MR. LOGAN . Thank you for coming.:
10 THE WITNESS: Thanks.
11 MR. WETTERHAHN: Thank you for staying late.
12 (Whereupon, at 4:45 p.m. the interview was i 13 concluded.)
14 '
15 16 17 18 '
'19 20 ,
21 22 23; 24 25:
r NEAL R. GROSS COURT REPORTE9S AND TRANSCR$ERS
^ 1323 RHODE ISLAND AVENUL N W. !
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i
, CER7IFICATE i
Thio 10 to certify that the attached-proceedings s
before the United States Nuclear Regulatory Commission in i the matter of Name of Proceeding: Interview of Mahesh Danak :
Docket Number: Not assigned ;
Place of Proceeding: Hancocks Bridge, New Jersey 1
were. held as herein appears, and that this is the original l l
tranceript thereof for the file of the United States y Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the r
court reporting company, and that the transcript is a true ;
and accurate record of the foregoing proceedings.
A '14 Barbara Burke Official Reporter Neal R. Gross & Co., Inc.
. +
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. COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
l (202) 2HM33 WASHINGTON. D C. 20005 (202) 2MM33
--,_l- -. - - = - - - - - - ~ - - - ~ ~ ~ - - - - - - ~ ~ ~ ~
- - - ~ ~ ~ ~ ~ ~ ' ~ ~ ' ~ '" ~~~
7b ,
t Y .
t TO: D. Smith Principal Engineer - Nuclear Licensing i
FROM: K. O'Gara Licensing Engineer '
SUBJECT:
EVALUATION OF REPORTING REQUIREMENTS AND ROOT CAUSE i ASSESSMENT ASSOCIATED WITH PRESSURIZER OVERPRESSURE PROTECTION SYSTEM (POPS) ISSUES (IR 95-343) l DATE: kil6, 19 '
The Offsite Safety Review (OSR) Group initiated Incident Reports95-343 dated 04/04/95 and 95-398 dated 04/13/95. IR 95-348 documents two (2) instances where PSE&G failed to report to the NRC in accordance with 10CFR50.72/73 that the Salem POPS was outside of its design basis. The two instances are related to evaluations performed by Nuclear Mechanical Engineering -(NME) to address the~ POPS setpoint non-conservatisms that were identified by Westinghouse in NSAL 93-005B dated March 15, 1995. IR 95-398
' documents four occasions where PSE&G failed to perform a 10CFR50.59 Safety evaluation when the original design basis of the POPS was changed to address the - setpoint non--conservatisms.
The purpose of this memo is to document Licensing's position with regard to the reportability of the 2 instances cited by OSR in IR 95-343, and to determine if 10CFR50.59 Safety Evaluations were warranted as identified in IR 95-398. This memo also provides a discussion of the root causes that may have contributed to these deficiencies occurring.
IR 95-348 Westinghouse identified a concern that the pressure differential I associated with the operation of RCP(s) during the-mass addition
. transient was not considered. The initial POPS analysis for Salem Units 1 and 2 did not account for the pressure differential between the mid-plane of the core and the location of the pressure sensors located at the Reactor Coolant System hot legs.
~
with the RCPs in operation. To quantify the effects on Salem, specific pressure differences associated with RCP operation were ,
calculated for 1, 2, and 4 RCPs operating. The results of these calculations provided-pressure differences of 31, 39, and 73 psig for 1, 2, and 4 RCPs, respectively.
These values include a 2.0
.psig correction for transmitter-elevation differences.
Evaluation of the Westinghouse results was documented in a memo from NME on 12/30/93. "
L cAsna -1 .95-013 EXHlBIT h
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i e
'4 2 1
OSR concluded in IR 95-343 that on 12/30/93, Salem Units 1 and 2 were outside of the design bases for POPS when considering the {
pressure differential associated with the operation of the RCPs.
The allowable peak pressure limits determined in accordance with !
10CFR50, Appendix G for Salem Units 1 and 2'are 450 and 475 psig, 8 respectively. These limits are reflected in the Pressure-Temperature curves contained in T/S Figures 3.4-2 and 3.4-3 for Units 1 and 2,-respectively. The calculated peak pressore for both units for the mass addit 4on transient was 446 psig at that time. If you add the pressure differential associated with the t operation of a minimum of one RCP, the peak pressure would be 477 psig. NME relied upon ASME Code Case N-514, which had not been approved for use by the NRC, to address the increase in the maximum pressure due to RCP operation. Administrative controls to limit 2 RCPs in service were also implemented. Without Code .
-Case N-514, both plant's pressure. limits would be exceeded. ;
Therefore, OSR' concluded that on 12/30/93 the design basis for ;
POPS could not be met based on the Westinghouse analysis results, and this should have been reported to the NRC in accordance with 10CFR50.72/73.
On May 26, 1994, NME completed further evaluation of the POPS '
issue. The results of this evaluation concluded that the pressure differential associated with the RCPs in operation did ,
not need to be considered since the RCPs are not operated with the. pressurizer in a water solid condition. The results of the NME evaluation determined that for the mass addition transient, the Unit 1 peak pressure would be 450.7 psig. This exceeds the pressure limit for Salem ":dt 1 (450 - prig) by 0.7 psig.
Therefore, OSR concluded that at this time Salem Unit 1 POPS was outside its design basis, and this should have been reported to the NRC in accordance with 10CFR50.72/73.
To support Licensing's evaluation of the reportability of the two instances cited by OSR in IR 95-343, the following additional ,
information is provided:
On September 27, 1994, NME documented further evaluation of the POPS nonconservatism issue and evaluated the mass addition transient assuming that the RCPs could be in operation prior to an-inadvertent SI actuation resulting in the pressurizer going water solid. This evaluation was performed using a flow rate associated with the CCP since both IHSI pumps would have power removed.
On November 17, 1994, PSEEG did notify the NRC that the Salem Unit 1 POPS was considered outside of its design basis. This was due to a new analysis assumption that the
, PDP may be running during a mass addition transient that .
EXHJBIT N PAGE Of 0F1PAGE(S)-
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3 i
l
' resulted from an inadvertent SI actuation. Under this new !
analysis assumption, the Unit pressure limit of 450 psig would be exceeded. This deficiency was reported to the NRC under LER 94- l
- 17. The Unit 2 pressure limit was still maintained.
The NRC issued a Safety Evaluation Report (SER) for Salem Unit 1 i to add POPS to the Technical Speelfications on 02/21/80. This SER documents assumptions that were utilized in the POPS analysis for Unit 1. Although the SER is not applicable to Unit 2, similar analysis assumptions were used in support of the Unit 2 operating license. The NRC SER discusses the administrative controls in place to remove power to the SI pumps to limit the affects of the mass addition transiert. However, the mass addition transient analysis was completed assuming the worst case l
condition that the higher IHSI pump flow would be injecting into a water solid pressurizer. Also, the SER discusses operation of the RCPs with a bubble in the pressurizer. This was administratively controlled to limit the affects of the mass addition transient. However, the mass addition transient analysin was completed assuming the worst case condition that the pressurizer was water solid during this event. This assumption is contained in the current T/S Bases. -
IR 95-343 was supplemented by memo OSR 95-012 dated April 10, 1995.
This memo documents that PSE&G was aware that POPS was outside of its design basis as early as September 29, 1993 by a Letter from Westinghouse. The IR states that reportability-should have been addresses by PSE&G at this time. The analysis results provided by Westinghouse formed the basis for the memo generated by NME on 12/30/93.
Generic Letter 91-18 discusses the use of 10CFR50.59 Safety Evaluations to address degraded or Non-conforming conditions. Gu 91-18 states that the 50.59 process may be used as part of the Corrective Action Program in lieu of restoring the affected equipment to its original design. The 50.59 process may be used as long as such a change does not require a License Amendment or result in an Unreviewed Safety Question. GL 91-18 does not relieve the Licensee of the responsibility to report the original --
condition in accordance with 10CFR50.72/73 or other reporting mechanisms. rg/ /
A copy of the applicable Section of GL 91-18 is attached for your information. (It is noted that further Afk
' discussion of the completion of 10CFR50.59 Safety Evaluations to address this issue is contained under IR 95-398.) I Based on the above discussion and review of the NRC Safety Evaluation Report For Salem Unit 1 dated 02/21/80 that added POPS
- to the Unit 1 Tech.-Specs., it should be concluded that both Salem Units were outside of their design bases during the period EXHlBIT PAGE d OF[PAGE(S)
_ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ . . . _ _ _ _ _ . . _ . _ . _ _ . _ _ . . _ _ ~.
) 4
'l of time between September, 1993 and the dates that the T/S bases i was changed for Unit 2 (12/21/94) and for Unit 1 (2/06/95) for purposes of reporting in accordance with 10CFR50.72/73. This conclusion is consistent with GL 91-18.
The notification to the NRC for Unit 1 being outside the design bases only covers the period of time between November 17, 1994 and the date that the Bases was changed. Also, this notification only addresses the issue rega'rding operation Of the PDP.
IR 95-398 Between the time that NME completed the initial evaluation of the POPS non-conservatism issue in response to Westinghouse NSAL 93-005B on 12/30/93, and the time that PSE&G documented the changes to the POPS Tech. Spec. Bases for Unit 2 or reported the PDP deficiency for Unit 1, tht rollowing analysis assumptions contained in the SER were revised without the completion of a 10CFR50.59 Safety Evaluation as documented in IR 95-398: '
The NME memo of 12/30/93 discussed administrative limits on the maximum number of RCPs that uld be inservice when the RCS temperature was below 200'F. his changed the design basis as contained in the NRC SE dated 2/21/80.
The May 26, 1994 memo from NME was based on a Computer' Code (GOTHIC) which was not reviewed and approved by the NRC in the SER. The SER conclusions were based on the LOFTRAN code provided Dy Westinghouse. Also, the number of RCPs was again reduced to a maximum of one without completing a 50.59 SE.
On September 27, 1994, the lower flow rate of the Centrifugal Charging Pump (560 gpm) was used to re-analyze the peak pressure from the mass addition transient. This differed from the NRC accepted design flow of 780 gpm as discussed in the NRC SER.
On November 17, 1994, the POPS design transient was again revised to address Positive Displacement pump (PDP) operation which was also not cor,sidered in the NRC SER.
Also, it is noted that the May 26, 1994 memo from NME did not consider the affects of RCP operation because the RCPs would not be started with the pressurizer in a water solid condition.
This is also different than the assumptions contained in the NRC SER dated 2/21/80 although not included in the scope of IR 95-398.
1 l
EX T /
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I *
- i 5 ;
6 '
i As discussed above, Generic Letter 91-18 discusses the se of !
10CFR50.59 Safety Evaluations to address degraded or n-
, conforming conditions. GL 91-18 states that the 50.59 process may be used as part of the Corrective Action Program in lieu of restoring the affected equipment to its original design. The !
50.59 process. may be used as long as such a change does not ;
require a License Amendment or result in an Unreviewed Safety' Question. Therefore, it is agreed that any changes to the POOS analysis should have received *a 10CFR50.59 SE to document the changes to the POPS design basis as documented in the SER. This ,
would include changes to the T/S basis which were completed in t
accordance with 10CFR50.59.
3 Root Cause Assessment Each of the issues identified in IR's95-343 and 95-398 can be attributed to failure to follow procedures or the failure meet !
current NRC regulations. Both of these failures are considered '
weaknesses in human performance. The factors that may have contributed to these weaknesses include:
- Inadequate understanding of the POPS Design Basis that was reviewed and approved by the NRC.-
Inadequate understanding of what is considered "outside of
- design basis" for reporting purposes.
- Inadequate understanding when an IR/DEF is requireo, or when an '
issue should be entered into an appropriate Corrective Action Program.
Inadequate understanding when a 10CFR50.59 SE should be prepared. '
I
- Not properly prioritizing the review of issues which may have safety significance or require further operability reviews (i.e.,
i Evaluation of POPS setpoint non-conservatism using the guidance i
of GL 91-18).
- Not knowing that certai.1 ASME Code Cases require NRC approval
- prior-to their use in accordance with NRC regulations.
, Based on my knowledge and involvement in the-events related to i IR's95-343 and 95-398, the fact that LLR or engineering did not become aware of the NRC SER for POPS until the Mid-December 1994 timeframe when the Unit 2 T/S Bases was revised supports the conclusions above. L&R or engineering should have known or have been able to accurately determine what constituted the design / licensing bases-for the POPS mass addition transient, r
EXHIBIT -
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' Other factors include statemento by engineering that they are not i i
responsible for the design / licensing bases of plant systems. I find this totally inaccurate because engineering completes 10CFR50.59 SE's frequently to address changes to the plants. .
Engineering must be familiar with their areas of responsibility in order to accurately complete SE's. It is this type of attitude that also may have contributed to the issues in the'IR. i a a,& m-1 i -
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l ATTACHMENT 1 !
SUMMARY
OF SYNERGY REPORT FINDINGS
[INDING 1 Use of the GOTHIC computer code in r'eanalyzing the POPS-peak pressure had not been reviewed and approved for use by the NRC.
The LOFTRAN computer code was acknowledged as acceptable in the SER issued by the NRC. Therefore, use of the GOTHIC Code could ,
be considered outside the design (licensing) basis of the POPS '
and a 10CFR50.59 Safety Eval ation should have been completed.
FINDING 2 Failure by Engineering to initiate an Incident Report documenting that the POPS was outside its design (licensing) basis when Engineering received a letter from Westinghouse (9/93) presenting
.the plant specific results for Salem. These results indicated that the existing P/T limi.J would be exceeded without changing the current POPS setpoint. ,
FINDING 3 Based on Finding 2, PSE&G should have reported this deficiency to the NRC in accordance with 10CFR50.72/73 for the plants being outside the Design basis.
FINDING 4 Engineering disposition in December, 1993 of the Westinghouse plant specific analysis results relied upon an ASME Code Case which was not approved by the NRC for use at Salem.
FINDING 5 r Although not discussed in detail, reference is made to a drift IR prepared by Salem Technical documenting the design issue that was not issued. The may have addressed the Reportability finding -
discussed above. (It is noted that the failure to issue this IR may be considered a failure to follow procedure.)
FINDING 6 Licensing was aware of the design deficiency and should have ;
initiated an TR which would have documented a proper reporting determination. (It is noted- that a Licensing had draf ted an IR which was not issued.)
r EX BR /
4 PAGE OF k PAGE(S).
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4 ,
ATTACHMENT 1 (Cont'd) i i
SUMMARY
OF SYNERGY REPORT FINDINGS I FINDING 7 The May 26, 1994-Engineering memo allowed a " minor exceedance a of the P/T limits by 07 psig. This is outside the NRC approved, licensing basis of the POPS. Changes to the Basis supported by the GOTHIC computer code shou,ld have been completed in accordance 10CFR50.59. (See Finding 1) '
FINDING B ;
Changes to the flow rates used in the. POPS analysis in 1977 .
should have been evaluated in accordance with 10CFR50.59. This includes both the realistic HHEI flows and the Centrifugal Charging pump flows that were governed by T/S. This should have been considered a change to the licensing basis.
FINDING 9 ;
I Since :hanges to the POPS design basis were necessary to continue i~
to ensure the P/T limits were not exceeded, operation of the plant could be considered outside the design basis and this should have been considered for reportability (i.e., since 9/94 when the realistic flow rates were used.
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1 EX IBIT PAGE ;_
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P EXHIBIT 20 l
l Case No. 1 95 013 Exhibit 20
rr ic w*,
. 4 FORM WC.Mk-AP.55-0006-1 WUCLRAR CEPARTMENT INCICENT REPORT FORM I
COMNITNENT NUMBER INCIDENT REPORT NO.
USE CONTINUATION EMPPTS IF NECESSARY SECTION REPORT I (Initiator)Rs
SUBJECT:
Pn Lled A - L ,m k<m UNIT S3,HC): DATE OF INCIDENT: 4 / 20 / 9t/ TIME:
SUMMARY
OF EVENT (IT EST ACTUATICN, INCLNDE SOE PRINTOUT):
f%u. S..,R0arkaA REPORTED BY: Mo%p DEPT: 44. A PHONE EXT: /J 7o
RX PWR AT TIME OF EVENT: 4 UNIT LOAD: MWe Op Con / Mode REPORT MADE PER ECG7 (Y/N): (IT YES, ATTACH ECG COPY)
LCO #: A/S #: DATE IN: TIME IN: W.R.#:
INITIAL CAUSE DETERMINATION: EQUIP DESIGN PERSONNEL PROCEDURAL OTHER:
REPORTABLE: YES/NO, REASON l
SNSS/NSS SIGNATURE: DATE: / /
COMMENTS:
1 OPERATIONS MANAGER REVIEW : DATE: / /_
Wuclear Common Page 1 of 4 EXHIBIT NO ter, s cAsne. 1-95-013 PAGE / OF 7 PAGE(S).,
p'.,
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- Westinghouse identified"in letter PSE-93-204 dated March 15, 1993 (NSAL 93-005B) a potential non conservatism in the calculation of the pressurizer overpressure protection system (POPS) setpoint (375 Psig) that effects Salem Units 1 and 2. The pressure difference from the wide range pressure transmitters (PT403 tnd PT405) which sense hot log pressure to the reactor vessel midplane (where the Tech. Spec. heatup and cooljown pressure / temperature (P/T) limits are definedi vas not considered in the Westinghouse analysis.
The Tech. Spec. hcatup and cooldown curves are determined in accordance with the requirenents of 10CFR50, Appendix G and ensure reactor vessel integrity. The POPS protects the RCS from exceeding the Tech. Spec. P/T curves by opening the PORVs during cold overpressure transients (RCS Temperature below 312 *F) . The current heatup and cooldcwn curves (Tech. Spec. Figures 3.4-2 and 3.4 3) POPS limits are approximately 450 and 475 psig for Salem Units 1 and 2, respectively. The Salem POPS analysis calculated a maximum peak pressure during an overpressure transient of 446 psig with the PORV set at a pressure of 375 psig. Further analysis was required to show that the pressure difference between the RCS hot leg and the midplane of the vessel plus the maximum calculated pressure (446 psig) did not exceed the Tech.
Spec. P/T curves.
The results of this evaluation by engineering are provided in letter MEC-93 917 dated December 30, 1993 (Attached). In summary, the calculated maximum pressures assuming 1 or 2 RCPs in operation compared to the Tech Spec P/T curves are as follows:
Unit RCPs in Service Max. Press. Tech Soec Limit 1 2 485 450 1 1 477 450 2 2 485 475 2 1 477 475 Based on the above, when the non-conservatism is removed by adding the pressure difference calculated, che limits of both Salem Unit'n P/T curves are exceeded. DEF # 94-0060 dsted 4/19/94 was issued to evaluate this issue.
/fAf' exsi n cd29 PAGE OF 7 PAGE(S)
l.
AsidentifiedinMEC93917additionalmarginontheTech.2pec.
curves can be gained when operating with POPS (RCS less clan 312'F)by taking credit for ASME Code Case N514- This Code Case states that the LTOP systems shall limit the mavd. mum pressure in the vessel to 110% of the pressure determined us satisfy. Appendix G of Section XI, Article G 2215. Crediting the Code Case will allow the maximum pressure f or POPS to be increased to 495 psig and 522 psig for Salem Units 1 and 2, respettively. However, utilization of the Code Case will require NRC approval prior to jmplementation. This Code Case has been relied upon by another utility under these circum pst -
[4L ,} w G l~tl 4* , Also, Procedure revisions ^to liRTI the number of RCPs in 6j 4pf ' operation to 2 while in Mode 5 will ensure that the naximum pressure will not be exceeded when credit is taken for Code Case
%k N514.
Edgineering is in the process of completing plant specific analysis of the POPS utilizing the RHR relief valves (RH3).
Westinghouse WCAP 11640 allows pAants to credit the RH3 valves for LTOP applications if the Autoclosure Interlocks for valves RH1 and RH2 tied to PT403 and 405 (> 375 psig) have been removed to prevent the inadvertent isolation of RH3. These interlocks have deleted from both Salem Units. The RH3 setpoint along with the valve capacity were generically evaluated by Westinghouse to provide the Appendix G protection during low temperature overpressurization events without relying on the PORVs. Although the plant specific analyses for Salem 1 and 2 have not been completed at the present time, the results are expected to produce acceptable results that the present Tech. Spec. P/T limits would be satisfied assuming only one RCP in operation.
Thes,e analyses do not credit Code Case N514.
Based on the above, reaacnable assurance exists that the current Tech. Spec. P/T limits would be met when considering the pressure difference between the midplane of the Reactor Vessel and the location of PT403 and 405. Therefore, it is judged that this issue is not an immediate operability or safety concern.
ffE$'
4 EXHIBIT N PAGE $ OF [PAGE(S)
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1 e
Westinghouse identified in letter PSE-93-204 dated March 15, 1993 (NSAL-93-005B) a potential non-conservatism in the calculation of the pressurizer overpressure pr6tection system (POPS) setpoint (375 Psig) that effects Salem Units 1 and 2. The pressure difference from the wide range pressure transmitters (PT403 and PT405) which sense hoc leg pressure to the reactor vessel i midpl .2e (where the Tech. Spec heatup and cooldown i prer are/ temperature (P/T) limits are defined) was not considered ir 3 Westinghouse analysis.
Th. Tech. Spec. heatup and cooldown curves are determined in acc idance with the requirements of 10CFR50, Appendix G and ensure reactor vessel integrity. The POPS protects the RCS from exceeding the Tech. Spec. limits by opening the PORVs during cold overpressure transients (RCS Temperature below 312'F) . The current heatup and cooldown curves (Tech. Spec. Figures 3.4-2 and 3.4-3) POPS limits are '450 and 475 psig for Salem Units 1 ano 2, respectively. The Salem POPS analysis calculated a maximum peak pressure during an overpressure transient of 446 psig with the PORV set at a pressure of 375 psig. Further analysis was required to show that the pressure difference between the RCS hot leg and the midplane of the vessel plus the maximum calculated pressure (446 psig) did not exceed the Tech. Spec. P/T curves.
The results of this evaluation by engineering are provided in letter MEC 93-917 dated December 30, 1993 (Attached). In summary, the calculated maximum pressures assuming 1 or 2 RCPs in operation compared to the Tech. Spec P/T curves are as follows:
Unit RCPs in Service Max. Press. Tech. Soec. Limit 1 2 485 450 1 1 477 450 2- 2 485 475 2 1 477 475 -
Based on the above, when the non-conservatism is removed by adding the pressure difference calculated, the limits of both Salem Unit's P/T curves are exceeded. DEF# 94-0060 dated 4'/19/94 was issued to evaluate this issue.
As identified in MEC-93-917 additional margin on the Tech. Spec, curves can be gained when operating with POPS (RCS less than 312*F) by taking credit for ASME Code Case N514. This Code Case states that the LTOP systems shall limit the maximum pressure in the vessel to 110% of the pressure determined to satisfy Appendix EXH1TTcM/)
PAGE
.-.0F 7 PAGE(S)
l G of Section XI, Article G 2215. Crediting the Code Case will allow the maximum allowable pressure (Tech. Spec. P/T limits) for l POPSrespectively. to be increased to 495 psig and 522 psig for Salem Un and 2, This Code Case has ,
require NRC approval prior to implementation.
been relied upon by another utility under these circunL ances.
i Also, Procedure revisions that have been implemented to limit the number of-RCPs in operation to 2 while in Mode 5 will ensure i s t'a k e n that the maximum pressure will not be exceeded when creditAs a pru ;
for Code Case N514.
is revising the relevant procedures to limit 1 RCP operating during Mode 5.
Engineering is in the process of completing plant specific (RH3).
analysis of the POPS utilizing the RHR relief valvesthe RH3 valves Westinghouse WCAP 11640(>allows 375 psig) plants to creditfor LTO RH1 and RH2 tied to PT403 and 405 These interlocks' to prevent the inadvertent isolation of RH3. The RH3 setpoint along I havethe with been deleted valve capacity from both wereSalem generically Units. evaluated by Westinghouse to provide the Appendix G protection during low temperature the PORVs.
overpressurization events without relying so 2 have not been completed at the present time, the results are .
expected Spec.
to produce acceptable results that the prese in operation.
These analyses do not credit Code _ Case N514.
Based on the above, reasonable assurance exists that the current Tech. Spec. P/T limits would be met when considering the pressure difference between the midplane Therefore, of the Reactor it is judged Vesselthat andthis the location of PT403 and 405.
issue is not an immediate operability or safety concern.
However, Salem 1 and 2 are considered outside of their design basis per 10CFR50.72 (b) (1) (ii) for reporting purposes.
EXHI R eNd)
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LICENSING EVALUATION OF DEF 94-0060 Westinghouse identified in letter PSE-93-204 dated March 15, 1993 (NS AL- 9 3 - 005 B) a potential non-conservatism in the calculation of the pressurizer overpressure protection system (POPS) setpoint (375 Psig) that effects Salem Units 1 and 2. The pressure difference from the wide range pressure transmitters (PT403 and PT405) which sense hot leg pressure to the reactor vessel midplane (where the Tech. Spec. heatup and cooldown pressure / temperature (P/T) limits are defitted) was not considered in the Westinghouse analysis.
The Tech. Spec. heatup and cooldown curves are determined in accordance with the requirements of 10CFR50, Appendix G and ensure reactor vessel integrity. The POPS protects the RCS from exceeding the Tech. Spec. limits by openin'g the PORVs during cold overpressure transients (RCS Temperature below 312'F) . The current heatup and cooldown curves (Tech. Spec. Figures 3.4 2 and 3.4-3) POPS limits are 450 and 475 psig for Salem Units 1 and 2, respectively. The Salem POPS analysis calculated a maximum peak pressure during an overpressure transient of 446 psig with the PORV set at a pressure of 375 psig. Further analysis was required to show that the pressure difference between the RCS hot leg and the midplane of the vessel plus the maximum calculated pressure (446 psig) did not exceed the Tech. Spec. P/T curves. ,
The results of this evaluation by engineering are provided in letter MEC-93-917 dated December 30, 1993 (Attached). In summary, the calculated maximum pressures assumir3 1 or 2 RCPs in operation compared to the Tech. Spec P/T curves are as follows:
Unit RCPs in Service Max. Pregg. Tech. Soec. Limit 1 2 485 450 1 1 477 e 450 2 2 485 475 2 1 477 475 Based on the above, when the non-conservatism is removed by adding the pressure difference calculated, the limits of both Salem Unit's P/T curves are exceeded. DEF# 94-0060 dated 4/19/94 was issued to evaluate this issue.
As identified in MEC-93-917 additional margin on the Tech. Spec.
curves can be gained when operating with POPS (RCS less than 312'F) by taking credit for ASME Code Case N514. This Code Case states that the LTOP systems shall limit the maximum pressare in he vessel to 110% of the pressure determined to satisfy Appendix EXylBIT SO Page 1 of 2 PAGE (o 0F 7 PAGE(S)
o i
. i G of Section XI, Article G-2215. Crediting the Code Case will allow the maximum allowable pressure (Tech. Spec. P/T limits) for POPS to be increased to 495 psig and 522 psig for Salem Units 1 and 2, rest.ssetively. However, utilization of the Code Case will require NRC approval prior to implementation. This Code , Case has been relied upon by another utility.under these circumstances.
Procedure revisions that have been implemented to limit the number of RCPs in operation to 2 while in Mode 5 will ensure that the maximum pressure will not be exceeded when credit is taken for Code Case N514. As a prudent measure, Salem Operations Dept.
is revising the relevant procedures to limit 1 RCP operating during Mode 5.
Engineering is in the process of completing plant specific analysis of the POPS utilizing the RHR relief valves (RH3).
Westinghouse WCAP 11640 allows plants to credit the RH3 valves for LTOP applications if the Autoclosure Interlocks for valves RH1 and RH2 tied to PT403 and 405 (> 375 psig) have been removed to prevent the inadvertent isolation of RH3. These interlocks have been deleted from both Salem Units. The M13 setpoint along with the valve capTeity were generically evaluated by Westinghouse to provide the Appendix G protection during low temperature overpressurization events without relying solely on the PORVs. Additional plant specific analyses for Salem 1 and 2 have been completed and the results have determined that the present Tech. Spec. P/T limits would be satisfied assuming either 1 or 2 RCP(s) in operation utilizing RH3. These analyses do not credit Code Case N514. .
O tu Westinghouse Owners grcup mittals to the NRC (WCAP-11736-A and letter OG-89-01 dated 01/ /89) identify that the RHR relief valves will be available to mitigate potential overpressure transients, and thus re oval of the ACI provides a positive impact on overpressure mitigation. The NRC in a SER to the WOG dated 08/08/89 cencluded with'the above that the removal of the ACI will aid in LTOP protection of the RCS. This WCAP and NRC SER were referenced as part of the plant specific submittals to the NRC in support of Salem License Amendments 95 and 71 for Salem 1 and 2, respectively. Therefore, credit can be taken for the use of RH3 for LTOP protection ince the function of the valvo has been included as part of revious licensing submittals.
uML dr PcAh, Based on the above, the current Tec . pec. P/T limits would be met when considering the pressure difference between the midplane of the Reactor Vessel and the location of PT403 and 405. Removal of the ACI for RH1 and RH2 allows.the use of the RHR relie'f valves for LTOP protection as documented in the letters submitted to the NRC in support of the ACI removal. Therefore, it is judged that this issue is not an operability or safety concern.
EXHIBIT Od PAGE
[OF 7 MGE(S)
i Sfficial Transcript cf Prococdings g
NL' CLEAR REGULATORY COMMISSION
Title:
Interview of A. Carolyn Taylor Docket Nurnber: (not assigned) l Location: Hancocks Bridge, New Jersey l
Date: Monday, Februaly 27,1995 8
Work Order No.: NRC-150 Pages 1-14 R
NEAL k. GROSS AND CO., INC.
Court Reportern and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 5 (202) 134-4433 ,
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