ML20204F572
| ML20204F572 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/26/1983 |
| From: | NRC |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8305020163 | |
| Download: ML20204F572 (192) | |
Text
____ _ _ _ _ _ _
ORIGINAL 1
l
] UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
COMMONWEALTH EDISON COMPANY (Byron Nuclear Power Station Units 1 and 2) Docket No.
50-454 OL 50-455 OL 6/(dt ( ,h[ tti L b pN' e nLaza i , e i~ Y '
yuax
[(J LL NY h . /
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Location: Rockford, Illinois Pages: 5964-6156 Date: Tuesday, 26 April 1983 TAYLOE ASSOCIATES Court Reporters 16251 Street, N.W. Suite IW 8305020163 G30426 Washington, D.C. 20006 PDR ADOCK 05000454 (202) 29F3950 T ppg
5964
['"#)'-1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
x 3 :
In the matter of: :
4 COMMONWEALTH EDISON COMPANY :
5 :
(Byron Nuclear Power Station, : Docket Nos. 50-454 OL 6 Units 1 and 2) : 50-455 01 7 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 8
9 Eighth Floor Courtroom Winnebago County Courthouse 10 Rockfrod, Illinois Tuesday, 26 April 1983 12 Hearing in the above entitled matter was recon-
,_s 13
() 4 veneved, pursuant to adjournment, at 9:00 a.m.
15 IVAN W. SMITH, 16 Administrative Law Judge 17 A. DIXON CALLIHAN
- " * " 9 18 RICHARD F. COLE 19 Administrative Judge 20 APPEARANCES:
21 On behalf of the Licensee:
JOSEPH GALLO, Esq.
Isham, Lincoln & Beale 1120 Connecticut Avenue, N.W.
Washington, D. C. 20036
- 24 l
25 l
l
5965
(")T
,,_ b-1 1 On behalf of the Licensee (continued) 2 ALAN P. BIELAWSKI, Esq.
MICHAEL GOLDFEIN 3 Isham, Lincoln & Beale Three First National Plaza 4 Chicago, Illinois 60602 5 On behalf of the NRC Staff:
6 STEVEN YOUNG, Esq.,
Office of the Executive Legal Director 7 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 8
On behalf of the Intervenors DAARE/ SAFE and 9 League of Women voters DAVID C. THOMAS, Esq.
10 77 S. Wacker Drive l
Chicago, Illinois 60606 BRYAN SAVAGE, Esq.
12 Emergency Planning Group 13 r~s
() 14
. DIANE CHAVEZ BETTY JOHNSON 326 N. Avon Rockford, Illinois 15 On behalf of Westinghouse 16 FRANCIS X. DAVIS, Esq.
17 Westinghouse Electric Corporation
, P.O. Box 355 18 Pittsburgh, Pennsylvania 15230 19 20 21 22 23 24 25
5966 b-3 1 C O N_ T E N T S_
t 2 WITNESSES: DIRECT CROSS RECROSS REDIRECT BOARD 3 John Blomgren Thomas Timmons 4 Wilson Fletcher l 5972 Michael Hitchler. l
- 5 Lawrence Butterfield
6 7
8 9
10 11 i
12 1
13 O
O 14 15 16 17 18 19 20 21 22 a
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24
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4
- 5967 c
. 1 P39qEEp1HsS
- f*
(, 2 JUDGE SMITH: Good morning.
3 .MR. GALLO. I have a preliminary matter, iour 4 Honor.
1 5 JUDGE SMITH: All right.
- e. MR. GALLO: Judge Smith, my colleague, Mr. Miller, 7 indicated that last week there was still a possibility that 4
a Mr. Levine would be heard this week with respect to his 9 reubuttal testimony on what we call the Class 9 contetions.
io On last Thursday Mr. Levine had his hand operated l'
11 on. I talked to him yesterday sud he is still feeling a 12 ~ considerable amount of distress as a result of that operatica, j 33 and I concluded it is not'possible to bring him this week.
}
14 So I would request that~we could reschedule him.
15 1 believe we are supposed to reconvene about May 23rd.
8 ie -
JUDGE SMITH: We are waiting for Mr. Thomas' r7 availability to make: that final. All other necessary people
'ia for the week of May 23rd have indicated that is a good time,
-is but hir. Thomas has not.
I'
'20 MR. GALLO: I see. I would request that I be
, 2 permitted to call him to the stand the first opportunity
?
22 at'the next time we reconvene.
[ 23 JUDGd SeiITH: Mr. Thomas, are you free for that 7s 24 week of May 23rd?
< \
') 25 MR. THOMAS: Yes. At this point I seem to be l
l
c
! 5968 j
i free that week.
f'rN
() 2 JUDGE SMITH: We were rather fortunate in having 3 the many people involved all being free that week. So that 4 is good. We can nail that down then. All right.
s That does mean, however, that we will have to
- e change our plans Having split proposed findings, we were 7 going to close the record as to all issues, except emergency a planning and hydrology. So now we will have to leave open
, the Class 9 issue, too.
4 io MR. GALLO: I am afraid that is true, Your Honor, 4
si yes.
- 12 JUDGE SMITH
- Even so, there is' plenty else for
- /~T ,3 us to be doing in decision-writing.
i4 MR. GALLO: Is there a schedule on findings of is fact, Your Honor?
is JUDGE SMITH: Yes, there-is a stipulated schedule 4
i7 which we will enforce, but we will enforce it in this way.
is We will have to clarify.the staff's position. We will have I
19 a schedule for the findings of-fact on the issues as to which 2o the record is closed at the end of this week, and then a i
ai schedule for the issues which will be concluded the week i
- 2 f May 23rd.
23 MR. GALLO. Thank you, 2, MR. THOMAS: What is this schedule for the findings?
(fI
25 JUDGE SMITH: The parties have stipulated to it.
4
,w -r * - ., ,, +, - - - - - - - - y c - - - ,
5969
- I don't recall. I think it is a flat 30 days, isn't it, O)
(m, 2 after the initial proposed findings?
3 MR. GOLDBERG: Thirty days for all parties but 4 staff who have agreed to use best efforts to file in 40 days.
5 JUDGE SMITH: 'And then we requested and received e from the parties an agreement to come in with proposed findings 7 for the procedural historical background of the case which a will save us a lot,of time. I think Mr. Miller was going 9' to prepare something and give it to the intervenors and the io staff for approval and then see if you could submit a joint it effort along that line.
12 MR. THOMAS: Is this 30 days from the time from 13 the time that the testimony and the issues is concluded,
[ )'
'Q/
e4 or 30 days from this week?
is JUDGE SMITH: Thirty d.ys from the end of this
'i6 Week. We had explored the possibilty of having staggered 17 schedules which would have meant a lesser period than 30 is days for the issues that had already been heard. That just l 19 did not Work out.
2o MR. THOMAS: That is what I wanted to clarify.
21 JUDGE SMITH: So we will be looking at proposed 22 findings at the end of May, due at the end of May.
i.
23- MR. GOLDBERG. 'Just a final word on the schedule fy 24 for May 23rd. As I indicated last Friday, there is a witness
( l
~
as . availability problem for one of the staff hydrologists who i
1 w w g, -w -
- g g- .n +-==e -- -m =n- *gn- -
5970 t is available either Monday or Friday. So in scheduling f
(s),/ 2 Dr. Levine, I think if all parties could try to bear that 3 in mind that he can only appear either Monday or Friday so 4 that will influence it, I would image the scheduled appearance 5 of Dr. Levine during that week.
6 MR. THOMAS: Who is that?
7 MR. GOLDBERG: Mr. Codell is available only Monday
- e. and Friday of that week and whose testimony would have to o be heard on one of those' days.
4 to JUDGE SMITH: What is the posture of the parties 11 with respect to the issue embodied in Mr. Levine's rebuttal 12 testimony?
/I~') 13 MR. THOMAS: Ii intended to address that at some
- \/
I4 point. I did not now whether you wanted to take that up
- 15 now or at some other point. Having perused Mr. Levine's to testimony, I do feel that
- it is really proper for rebuttal
, 17 testimony.
is I also intend to ask the Board for an opportunity 19 to take Mr. Levine's deposition which could be done now that 2o he 1s not testifying this week.
2: However, probably that would be best put in l 22 writing. I don't know what the Board's feeling about it i
l 23 is. This microphone I don't think is on.
i
- 24 (Discussion off the record.)
\
J 25 JUDGE SMITH: Back on the record.
+
__. , . _ _ __ . . ~ - _ - -
i 1-5 5971
-1
.- MR. THOMAS: I do have some objectionsoto a
i Mr. Levine's testimony which I could either present orally
~
3 at a later time or send in writing.
4 JUDGE SMITH: Objections to the testimony or s
objections to the timing of the testimony? Objections related to the need-for discovery, is that it?
7 MR. THOMAS: Yes, partially the need for. discovery and partially just the nature of the testimony. It does not seem to me it is really rebuttal testimony in the proper sense of the word.
! MR. GALLO: It seems to me, Your Honor, that
- objection should be made, if at all, at the time of the offer.
It is premature now.
JUDGE SMITH: As to the nature of the testimony- [
15
, I agree. But as to his request for an opportunity for deposition for discovery, that should be made as early as I
possible.
MR. GALLO: I would agree with that.
! JUDGE SMITH: Let's proceed then. Any other preliminary ousiness?
MR. THOMAS: Nothing, Judge, other-than with regard 22 to the nature of the proceedings today, if there are no objections.
'NJ
/} Mr. Savage was involved in a line of questioning 4
yesterday, which I believe he is fairly close to completing.
5972 If there are no questions, I would ask that Mr. Savage be b(,,/ a allowed to complete the line of questioning that he was 3 involved in yesterday at which point I will assume the 4 questioning for the intervenors for the duration of the s proceeding. I think it would be more efficient.
e JUDGE SMITH: All right. I think so.
7 Hearing no objection, we will proceed on that a basis, o Whereupon, to JOHN BLOMGREN 11 THOMAS TIMMONS 12 WILSON FLETCHER is MICHAEL HITCHLER 14 AND is. LAWRENCE BUTTERFIELD is having been previously duly sworn, were further examined 17 and testified as follows:
to JUDGE SMITH: We are going to allow perhaps 10 i
19 or 15 minutes following lunch to formally rule on the 2o survey. So bear that in mind in your sheduling today.
l 2 MR. SAVAGE: I hope not to take longer than an 22 hour. I hope that would be a long time to take.
23 CROSS-EXAMINATION (Resumed) fg 24 BY MR. SAVAGE:
i *
, . %)
- 25 Q Mr. Timmons, I have questions for you again. Let
, e y e- 9mg ygy--g- ,-g- ->c-- w-- #
5973 i me try to put the examination from yesterday in perspective m
k,,) a and you can tell me if you disagree with my characterization 3 prompted by the through-wall leak in a tube at Ringhals.
4 Krsko was shut down in 1981 after a few hundred hours of 5 operation between 30 and 40 percent power and conducted some 6 ECT testing. There were no indications of significant tube 7- wear. Westinghouse recommended that Krsko be operated for a 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> at 50 percent power and that was done. In January e of '82 it was shut down again.
H) Some eddy current testing was carried on.
11 Accelerometers were placed in four tubes, but no tubes were 12 removed and no evidence of significant-vibration. Then for
[v ) is another 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> at approximately 70 percent power Krsko L4 was operated and in May of '82 it was shut down and there is .vas eddy current testing. One tube was removed and you found us that approximately six percent of the wall had been degraded 17 by Vibration. You placed more acceleroroeters in selected to tubes in part at least to search for the boundary of the
! 19 Vibration.
end 1 2o 21 t
22 23 i
25 l.
B 2 pv 1 5974
() _1 Let me go one step further. After that, I assume 2 that Krsko was operated -- after it was shut down in May-3 Westinghouse or the owner of the utility made the fix. P.ight?
4 They modified the feedwater system so that 70 percent of the 5 feedwater could go into tee intake and 30 percent through 6 the auxiliary intake. That's correct, isn't it?
7 A (Witness Timmons) During the time period of 8 June, early' July of 1982, the Krsko plant was modified so 9 as to allow 30 percent of the main feedwater to continuosly 10 go to the auxiliary feedwater nozzle through the feedwater 11 bypass system. So there was only 70 percent of the feedwater 12 going through the main nozzle in that operating configuration.
13 Q Between July and October the plant was operated s_) 14 for approximately 1,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> again. Is that correct?
15 A Yes.
16 Q And now it was operated at times at least up to 17 100 percent power with various feedwater configurations, 18 including 70-30, 90-10, and 100-zero?
19 A That is correct.
20 Q On page 12 of your testimony, as revised 4/25/83, 21 you state in the paragraph that beains on page 11, the second 22 full sentence on page 12, it begins, "It was also observed 23 that operation of the Krsko steam generators at or below 70 24 percent main feedflow did not produce any signfiicant tube 25 vibration."
. x U
o2 pv 2 5975
( ) 1 What does "significant tube vibration" mean?
2 A Tube vibration that was evaluated by engineers 3 in Westinghouse to be of a level that, based on experience 4 and observations of vibrations, that would not lead to tube 5 wear greater than the plugging limit in a given operating 6 period.
7 Q The plugging limit is what? 40 percent of the 8 tube wall?
9 A That is correct.
10 0 So the term "significant tube vibration" means 11 tube vibration that will not lead to deterioration up to the 12 plugging limit in any length of time in which it could not
_ 13 be detected?
ks m 14 A Would you repeat your question, please?
15 Q The tube plugging limit is 40 percent of the tube 16 wall. So the term "significant vibration" means a kind of 17 vibration, a kind of vibration that would produce 40 percent 18 deterioration of the wall in a period of time that it could 19 not be detected?
20 A A significant tube vibration in my mind means 21 the level of tube vibration is such that you would not get 22 enough wear on the tube to go beyond 40 percent of the tube 23 wall during the operating interval that had been chosen.
I-24 Q So you are referring only to the operating interval 25 of 1,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />?
A k)
I
b 2 pv 3 5976 (m
(,) 1 A In this particular instance, yes.
2 Q So the conclusion really then is that operatino 3 at 70 percent'of the main feedflow does not produce signifi-4 cant vibration where significant vibration means a vibration 5 that would produce degradation of a tube wall in excess of 6 40 percent within a 1,500-hour period?
7 A I-n the period of February to March of 1982 it 8 was Westinghouse's judgment based on information that was 9 available that operation at Krsko at 70 percent power for 10 1,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> would not result in tube wear greater than 40 11 percent.
12 Q You are not saying, are you now, that it would 13 not produce a vibration which would ultimately lead to f-~
-I 14 tube degradation at 40 percent over whatever period of time?
15 A I am only saying it would not lead to wear 16 greater than 40 percent in 1,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, that time period 17 being between February and May of 1982.
18 Q I think you have answered my question.
19 With respect to the tube that was removed in 20 May of '82 and on which you found that 6 percent of the 21 wall had been degraded, that is a tube that was degraded 22 to 6 percent of the thickness of the wall for a period of 23 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> plus, where the plus is the 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> that we 24 really do not have a number for?
25 MR. GALLO: Objection. I must object to
/3 i !
V
o2 pv 4 5977
'x 1 counsel's constant testifying and constant characterization 2 of the witness's testimony as he thinks he understands it, 3 as a predicate for his other questions. The record soeaks 4 for itself, and it is improper for counsel to keep essentiall3 5 writing his findings of fact between questions. He should 6 just ask questions and not make statements.
7 I object to any further action in that respect.
8 MR. SAVAGE: I am trying to emphasize the fact.
9 JUDGE SMITH: The emphasis is not a good reason.
10 Placing the question in context, if necessary, is a good 11 reason.
12 MR. SAVAGE: Essentially, I want to emphasize
-s 13 the context.
s- 14 MR. GALLO: All he wants to do is write his 15 brief today.
16 MR. SAVAGE: That's not what I want to do.
~
17 JUDGE SMITH: I think Mr. Gallo has a legitimate 18 Point. I don't think prospectively it is going to be easy 19 to enforce, but I think you should be sensitive to his 20 point. Emphasis is not a legitimate reason for restatino 21 the testimony; context is, if it is necessary in context.
22 MR. SAVAGE: Let me put it this way. I don't 23 have to recite the number of hours all the time.
I 24 BY MR. SAVAGE:
25 Q Given the amount of time that Krsko had operated (n) s_-
.u a ;y v >
t 5978 i (O) y up to May of 1982, do you find the fact that the tube to be 2 rem ved had a 6 percent of the wall degradated, do you find 1
3 that to be significant?
4 A (Witness Timmons) Significant in what sense?
5 Q Let me see if I can put it a different way.
6 Is the -- when you found that the tube wall 7 in that tube was degradated to 6 percent of its thickness, 8 did you calculate what the rate of wear would be for that 9 tube in order to determine when it would reach 40 percent 10 and have to be plugged or when i might reach a through-wall?
11 MR. GALLO: Objection. Is it a compound 12 question.
13 JUDGE SMITH: Was it compound or alternative?
O (s,) 14 MR. SAVAGE: I think it was alternative. I will 15 ask them one at a time.
l 16 BY MR. SAVAGE:
17 0 Did you calculate the tube wear rate for that 18 tul!?
19 A (Witness Timmons) I did not calculate a tube 20 wear rate. I am sure somebody did. The way that we have l
L 21 correlated tube wear with vibration.is a very complex l 22 function. That includes the amount of time that is spent 23 at each individual power level, operation at higher power 24 levels. That is, 90 percent or 100 percent main feedflow l
L 25 through the main nozzle contributes much more significantly
'O
,O l
'r
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-5979
) I to the wear function than operation at 30 percent, 40 percent, 2 50 percent, or 70 percent. It is a strong function of the 3 amount of flow. And therefore, since the plant had operated 4 primarily at 70-30 or 70 percent at that point in time, but 5 had also operated at power levels up to and including 100 6 percent with all of the flow going through the main nozzle.
7 But those other power levels were taken into consideration 8 in evaluating the wear rate or the amount of wear that that 9 particular tube had suffered.
10 0 Thanks. That was a lot of good information for j 11 me. I am confused about one thina. I am talking about the 12 tube removed in May now. Had Krsko operated at 100 percent 13 power by that point?
14 A Yes. They had operated for some periods of time 15 up to and including 100 percent power.
end t. 2 16 Q Do you know how many hours?
17 i 18 i
19 20 21 22 23 24 25 l
3-1 5980 l
1 A Probably 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 100 percent. I think there were three to five days at 90 percent. There was a period 3
of time, it may have been up to two weeks, at 75 percent 4
power.
s Q Do you have any idea how many more hours it would 6
have taken for that tube to reach 40 percent degradation 7
oper4 ting at the same level in ranges of power that Krsko e
operated between Jan24ry of '82 and May of 82?
9 A !!o , I don't.
i io
- O I think the question we left off with yesterday 11 was one about the rate at which tubes becen.c degraded. I 12 think Ihad asked You whether there is a threshold percentage O
ss for wall degradation at which the rate increases. In other
' e4 words, if you were to draw a graph of tube rate degradation is as the percentage of the wall degradated, the curve would 16 go up. The rate at which degradation occurred would be faster.
17 Do you know if that is true?
18 A The information correlations that we have established 19 indicate that as tube wear progresses on a given tube wear ao site that the rate of through-wall penetrations decreases 21 with time. One would expect that as a tube wears that more 22 surface areas comes into contact so that the volume removal may 23 De constant but the depth of penetration per unit time I
y- 2a
.i j decreases.
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_ - . . _ . . _ _ _ . .- ~ _. _ _ . . - _ . . __ . _ ,
3-2 5981 i
Is the rate of the wear over time, does that O 2 Q
increase as the percentage of the wall decreases?.
3 A To the best of my knowledge, and based on the 4
information that I have seen, the rate of through-wall s
penetration decreases with time and as %. increases.
6 MR. SAVAGE: Excuse us for a second.
7
-JUDGE' SMITH: Why would the volume of the material a
remain constant? The volume of the removal of the material, 9
was'that one of your observations, too?
10 WITNESS TIMMONS: No. The volume of metal' 11 removed is a. function of the amount of energy imparted to 12
. the tubes. So the volume of metal removed per unit of time would be about constant since the energy input would 14 be about constant, but the depth of penetration per rate l 15 of per unit time decreases.
16 JUDGE COLE: As you get more wear ort a -tube, might 17 that tend to increase.the vibration and subsequently cause 18 a greater rate?
19 4
WITNESS TIMMONS: That is a very complex function.
2o-.
It includes the interaction of the tube with numerous baftle
! 21 plates and the amount of energy it takes to keep the tube 22
~in contact with all of the baffle plates and a lot of other 23 functions, wear mark sites, a number of sites, the amount 24
~
of energy put into the tube, the amount of energy it takes i 25 s
3-3 5982 1 to move the tubes. So that is it in contact with the plate.
2 It is a very complex function and the observation from field
- 3 experience ~ indicates that for a given site the volume removal 4 per unit time is somewhat of a constant per site, but the s depth of penetration tends to decrease with time because 6 you have got more surface area in contact.
7 WITNESS FLETCHER: Judge Smith, may I comment a on that, please?
9 JUDGE SMITH: It does not seem to add up.
to WITNESS FLETCHER: The classical behavior of it interaction between two moving parts such as in a wear process 2 is as material is removed what happens is the area of inter-rw action increases. The increase in this area then provides
() is i i4 for the application of the load over a larger area and thereby is it does decrease the unit load per area such that the force
+
is that is applied to the interacting parts decreases with time
.i7 as the area increases. The volume of material is removed te from a larger area, but the depth of penetration into the is tube wall decreaes as the area increases.
1 2o So you have volume, you have area and you have 2 the interacting loads. All of that sums up to a decrease 22 with time in penetration into the tube wall, and that is I
2a exactly what was found by the analysis of the data derived 24 from the operating plants, Ringhals and the Almarez plants,
.( s 25 .that with time the depth of penetration into the tube wall i
,,- - ~ . . .- ., . - . - , - - .~.,_ - - - . - - . _ _ _ _ _ _
3-4 5983
' would decrease.
\s / JUDGE SMITH: In this instance what is the direct 8
cause of the penetration in the tube wall?
d WITNESS FLETCHER: The direct cause is wear. It 5
is the interaction between the tube and the tube support a
plate. That sliding motion between those two members then 7 removes metal.
a JUDGE SMITH: All right.
JUDGE CALLIHAN : When you refer to area, which as
")
you just said as I understand it, increases with time with wear, is that the real area or is it the apparent area or 12
.the projected area?
rx 13
( ) WITNESS FLETCHER: It would be the area increase v
'd with time. Let me see if I can explain that.
'8 JUDGE CALLIHAN : Just define an area for me as
'8 you use it.
'7 WITNESS FLETCHER: It would be in units like square centimeters.
HB JUDGE CALLIHAN: Yes, of course, but ---
2o WITNESS FLETCHER: The area would be the area 21 that is in contact between the two members. That area begins, 22 first, if.you consider a round tube in a round hole, the
.23 first point of contact would be line contact. That would 24
("%)
be at one end of the spectrum and provide a very small area
%/ ** ,
of interaction. Now as the tube and the tube support plate
3- 5 5984 ,
I hole continue to interact, then that line contact would g a enlarge.
3 JUDGE CALLIHAN : In an axial direction?
4 WITNESS FLETCHER: In an axial as well as circum-s ferential diretion, moving from the point of contact, left e and right, if you will, to either side circumferentially.
7 JUDGE CALLIHAN. Just to clear my original question, a which apparently is. moot, by real and apparent area I meant o what one sees on the one hand or what-may develop because to of porosity taking place. That was my distinction between
- real and apparent area.
i 12 WITNESS FLETCHER: No, sir, I was not referring
[ is to anything such as porosity. The wear scar in fact is
\/}
I4 quite smooth. So the real and the apparent area would be is virtually identical.
16 JUDGE CALLIHAN: So the space between the purturbing j 17 member and the tube,-the support plate, is that is what it is be,.then increases, and hence the content area increases 19 because of a penetration in an axial direction?
20 WITNESS FLETCHZR: That is correct, sir.
21 JUDGE CALLIHAN: Thank you.
22 BY MR. SAVAGE:
23 Q Mr. Timmons, I would like to show you a letter
-s 24 from Mr. Hal B. Tucker who was the Senior Resident. Inspector
)
'~'
25 of the McGuire Nuclear Station. It is a letter to Mr. Harold
- .~. -.- - . . . . - - . . -- . . . . - - . - . - . . . - . = . . - . . ~ . _ _ _ -
3-6 5985 i R. Denton,. Director of the Office of the Nuclear Regulatory
- n' Commission dated December 15th, 1982, and the re is McGuire 3 Nuclear Station, Docket No. 50-369. This letter was Xeroxed ;
4 from the original in the Public Document Room by ois. Chavez.
i s I want.you to look at two' sections marked D and 4
't e E and familiarize yourself with them and tell me'if they
'7 are inconsistent With what you and Mr. Fletcher just described.
a (Documented handed to counsel.)
o (Pause.)
end 3 to
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12 3 /N
- U i
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15 16 e
17
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18
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i 20 28 I
22.
23 f
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5986 I)
(_- 1 MR. SAVAGE: I apologize for not having copies.
2 WITNESS TIMMONS: I don't think Mr. Tucker would 3 like to be demoted from senior vice president at Duke Power 4 to senior resident inspector.
5 . MR. SAVAGE: And I certainly did not want to be 1 6 the one to do it.
7 (Laughter.)
8 MR. SAVAGE: I correct myself.
9 (Counsel conferring.)
10 BY MR. SAVAGE: ,
11 0 There are two sections marked " Calculation of 12 Tube Wear Rate" on page 2, and the others were projection 13 for additional 75 percent power operation. Subparagraph 2 7-~s
%- 14 of calculation of the tube wear rate, there is a phrase, 15 "Once tube wear progresses to the point that the total metal 16 removed is approximately 10-4 cubic inches. This corresconds 17 to approximately 12 percent through-wall, and then the wear
(
i 18 rate increases."
19 I want to know what that means, if you know, 20 and whether that was what is described in that letter, if 21 that is consistent with the description you just gave and
- 22 Mr. Fletcher?
23 (Witnesses conferring.)
24 (Pause.)
25 JUDGE SMITH: Gentlemen, you can indicate when
,- m (s,)
,m. p -
r . -- =-- - * - -*-
5987 (A)
, 1 you are ready.
2 WITNESS TIMMONS: Unfortunately, it is a long 3 lettar and contains a great deal of technical information.
4 JUDGE SMITH: This is the letter that pu offered 5 last night?
6 MR. SAVAGE: Yes, it is.
7 (Pause.)
8 MR. SAVAGE: If you would rather have time to 9 look at it and do not want to comment on it now, we can 10 skip it. I don't want to put you in the position of making 11 comments you are not really prepared to make. That was the 12 point of offering it last night.
13 MR. GALLO: If counsel will recall, he never 14 provided a copy.
15 WITNESS TIMMONS: I would have to go back and 16 look in more detail particularly at the eddy current results 17 provided in the table at the back of this where it compares 18 eddy current eddy current results from three different 19 Operating periods, two of which included periods of time 20 of 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> or so at 75 percent main nozzle flow in the 21 unmodified condition for the Maguire Unit D-2 steam 22 generators.
23 Westinghouse, as I mentioned in my testimony, 24 had made a correlation that 50 percent main nozzle flow 25 in the D-2 or D-3 and 70 percent flow in a D-4 would give O
> i
__ m . _ _ _ .__ _ ... . .
5988 rs
. (_) 1 you negligible wear over a 1,500-hour operating ceriod.
2 75 percent flow for Maguire is 25 percent higher than 3 50 percent. And if you add 25 to 75, that is like operating 4 Krsko at 100 percent.
5 From what I can look at preliminarily, they used 6 a bounding calculation based on one tube that had indicated 7 by ca eddy current the largest depth of penetration.
8 Beyond that, it would take me a period of time to digest 4
9 the information.
4 10 BY MR. SAVAGE:
11 Q I understand that. I appreciate it. I am sorry 12 for making you go through all that.
13 Tell me, is the rate of tube wear tube-dependent?
A ks- 14 Can you get a constant for tubes in an area? Does it depend 15 on where the particular tube is 16 A (Witness Timmons) That depends on the flow field 17 that the tube sees. Different tubes see different flow 18 fields, and therefore it is somewhat position-dependent.
19 Q Are flow fields wide enough to include two or 20 three tubes that would have the same rate or number of tubes 21 that would have the same rate?
22 A The same rate as what?
23 Q Tube degradation.
24 A There might be tubes in symmetrical locations 25 which would have the same flow field, where you would
5989
(~%
g ,)
5 i postualate that they would have the same wear rate.
2 The flow field by tuo adjacent tubes is similar, 3 but not exactly the same.
4 Q Let's move on. Am I correct in reading from your 5 testimony that the plant was shut down again in November of 6 '82? Is that correct?
7 MR. GALLO: What plant?
8 MR. SAVAGE: Excuse me.
9 BY MR. SAVAGE:
10 Q The Krsko plant was shut down in November of '82?
11 A (Witness Timmons) In_ late October, early November, 12 .the eddy current was done.
13 0 You removed two tubes then and inserted one 14 expanded tube, is that correct?
15 A We removed two tubes and expanded a tube which 16 was already in the steam generator.
17 Q Now, you testified that the tubes you removed 18 had wear from .001 to .002 mils. What percent of the wall 19 is that?
20 A .001 divided by .003 is 1/43rd, which is 2 21 percent.
22 0 2 percent of the wall. When did the plant becin 23 again? When did Krsko start up again?
24 A I don't remember the exact date. It was sometime 25 in November, p
G
5990
'(}
i
, ,/ 1 0 And the recommedation from Westinghouse was to 2 run for 4,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> at up to 100 percent power?
3 A To run for approximately 4,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> at power 4 levels such that the main nozzle flow was 70 percent.
5 Q And so it has not been shut down again since 6 November, is that correct?
7 A That is correct.
8 0 The tube that you expanded, did you insert an 9 accel'erometer in it?
10 A That was a tube that had previously had an 11 accelerometer installed in it. That accelerometer was
'12 removed to allow the tube to be expanded a t the appropriate 13 locations. An accelerometer was reinstalled in the tube 7_.
- )
\/ 14 following the tube expansion.
15 0 So you have been gathering data now from that
, 16 accelerometer?
17 A We have gathered data. When you put an 18 accelerometer in a tube, you take the plant and you operate 19 it at various flow configurations either 100 percent through 20 the main nozzle or 70/30 or 80/20 or 80/0. You take the 21 readings for a short period of time in order to ascertain 22 the vibrational characteristics of the tube because they 23 do not change very much.
24 We have had experience where we have taken 25 readings over extended periods of time in the same tube, 4
/
( I
(/
b 4 pv 6 5991 fN
- ( ,) i the same steam generator at similar power levels,and the 2 vibrational characteristics remain essentially the same 3 over long periods of time.
4 So it is not necessary to continuously monitor.
5 It is kind of a one-time reading. You take the data and 6 you go back and evaluate the data to ascertain the 7 vibrational char.cteristics of that particular tube.
8 0 With the data you are getting from the accelero-9 meter and the expanded tube, do you have enouah information 10 yet to calculate a wear rate for that tube at whatever 11 Percent power and feedwater configuration?
12 A I think that sufficient information exists to
_s 13 be able to calculate a wear rate. I do not know if we
-- 14 have specifically done it for that tube. The level on 15 vibration is such that based on my knowledge of the 16 correlations, I would say that the amount of wear that the 17 expanded tube would have for an extended period of time end 4 18 would be very, very small. ,
19 20 21 22 23 24 l
25 l
i w f-L l
5992
/'N
(,) 1 Q Part of the fix for Byron is the expansion of 2 tubes. And I am assuming that the only expanded tube in 3 an actual full-scale model D-4 steam generator is the 4 expanded tube at Krsko. That is correct, isn't it?
5 A In an actual operating plant, model D-4 steam 6 generator, that is the only tube that has been expanded.
7 O So there is some special sionificance to the 8 way this tube is going to perform with respect to gathering 9 data to test your fix?
10 A That is correct. We are using that data from 11 the Krsko plant to compare to the data that we are 12 obtaining from our 16-degree model to determine if the 13 16-degree model gets the same information that the plant I
%/ 14 does.
15 Q Isn't it true that you don't have that data 16 yet to compare to the 16-degree model?
17 A Don't have what data?
18 Q The data you need to know from actual experience 19 to confirm the predictions of the model.
20 A We have established a wear correlation. It is 21 based on the vibration data, in part. We have vibration 22 data from the expanded tube at Krsko. We have vibration 23 data from expanded tubes in the 16-degree model. The data 24 from the 16-degree model correlates exceptionally well with 25 the data from the Krsko plant, both for expanded tubes and
(
s_-)
i t
.o a yv 4 5993 1 for nonexpanded tubes.
2 One would expect that based on the ability to 3
replicate the plant with the test model, that you could 4
use the information from the test model to predict the 5 future behavior of the steam generator.
6 Q Right. But you have never looked at the expanded 7 tube in Krsko? You have not seen it yet since it has been 8 operating. You have not pulled it out and looked at it and 9 measured it and done the metallurgical tests on it?
10 A No, we haven't. The tube is still in the steam 11 generator.
12 Q Now, when you placed -- let me ask you a couple 13 of questions about the accelerator in the expanded tube.
V 14 Does it impede or stop the flow on the primary side?
15 MR. GALLO: Does what impede or stop the primary 16 flow 7 17 BY MR. SAVAGE:
18 Q Does the existence of the accelerometer in the 19 tube?
20 A (Witness Timmons) In order t o install an 21 accelerometer in the tube, it is necessary to cut the tube 22 at the U-bend on the secondary side and to install the 23 accelerometer from the top of the tube and ' lead -- pull 24 the lead through a penetration side of the steam generator 25 and to plug the tube on the primary side, so that you don't
o a pv J 5994 l'
(M) 1 get primary to secondary leakage.
2 Q Does that change the flow pattern in any 3 significant way?
4 A It does not change the flow pattern on the 5 secondary side of the steam generator where the excitation 6 of the tubes occur.
7 Q Does it affect it on the primary side?
8 A There is no flow on the primary side. We have 9 done testing to indicate to us that the vibrational 10 characteristics of the tube remain the same for tubes 11 that have been instrumented with accelerometers as opposed 12 to tubes which have flows through the primary side and 13 primary pressure on the them. The effect of the pressure h.
t- / 14 and flow in the primary side of the tube is essentially 15 negligible with respect to the vibrational characteristics 16 of the tube, 17 JUDGE COLE: Have you run experiments to 18 determine that, sir?
19 WITNESS TIMMONS: Yes, we did. We have had tubes 20 that were pressurized with accelerometers and then tubes that 21 were filled and unpressurized. The vibrational characteris-22 tics of the tube are essentially the same. The response of 23 the tube and the frequencies and amplitudes are essentially 24 the same.
25 JUDGE COLE: Thank you, m
l k
g ,,,i t BY MR. SAVAGE:
4 %_/ 1 2 0 Has the testina that you describe to determine 3 that there is no change been done in a preheater section?
4 A (Witness Timmons) In the preheater section?
5 0 Of the steam cenerator.
6 A The steam generator. No, it was done in the 7 laboratory.
8 0 In the laboratory, never in the steam generator.
9 How reliable do you think these accelerometers are?
10 A I think that the information relative to 11 accelerations of the tube given by the accelerometers 12 very reliably tells us what the tube is doing in terms 13 of vibration.
I,_s\
\ms/ 14 Q And how have you tested that? How have 15 you tested the reliability or the accelerometer?
16 A I don't think I see where you are going.
17 0 The accelerometer gives you data, and you want 18 to see, I imagine, if the data is accurate. Do you compare 19 the data from something else,like eddy current testing?
20 A Eddy current test data and accelerometer data 21 are just independent and very different. Accelerometer l
22 tells you how the tubes move. The eddy current tells you 23 whether there is metal removed from the surface of the tube 24 and whether there is through-wall penetration or part-wall 25 degradation. They measure two different things.
-~
O I understand. Are y ou confident that the I - \/
b 5 pv 5 5996 1 accelerometer is sensitive enough to measure what are 2 significant vibrations for the tube?
3 MR. GALLO: Objection. Asked and answered. He 4 said it was terribly reliable.
5 JUDGE SMITH: Wait a minute. Let's hear the 6 question back.
7 (The reporter read the record as requested.)
g JUDGE SMITH: That has been asked and answered.
9 MR. SAVAGE: I am not asking about reliability 10 now. I think there is a distinction with respect to --
11 MR. GALLO: I will withdraw the objection, 12 Your Honor.
g3 13 BY MR. SAVAGE:
'N- 14 Q Do you see it, Mr. Timmons? If you do not see it, 15 then maybe there isn't one.
16 A (Witness Timmons) The accelerometers are 17 installed. They.are very sensitive. They detect very low 18 levels of vibrations. I think that the levels that they 19 detect are capable of detecting are below the level of 20 vibration which would cause any wear.
21 Q Just a few final questions. The expanded tube 22 now, it does not touch the baf fle plates, the baf fle 23 support plates, does it?
24 A It is in very close proximity in terms of the 25 diametral gap between the tube and the baffle plate. I think i
v
o 5 'ov 6 5997 1
/T hs,j 1 I can guarantee that at certain times during operation, 2 that it is in contact with the baffle plate.
3 0 I don't know if this information is proprietary, 4 but I want to ask another question. Does the expanded tube 5 vibrate or just expand?
6 A There are indications from the accelerometers 7 that there are extremely low levels c f vibration in the 8 tube.
9 0 Do these vibrations create wear at the point of 10 the baffle support plate?
11 A I would not expect that that low level of 12 vibration would result in any significant wear for a very I
13 extended operating period.
O k-s 14 0 I did not want to know --
15 A A matter of years.
16 0 I keep interrupting you. It does create some 17 wear, though, right? There is wear going on? There is some 18 degradation of the tube however small?
19 A There could possibly be some. I don't know for 20 a fact that there is.
21 Q Because the expanded tube is more rigid, it can 22 vibrate less than the nonexpanded tube. When the flow of 23 the feedwater comes past it and hits it, is there an 24 increase in the frequency of vibration as opposed to the 25 amplitude?
()
O
oa pv o 5(198 (v) 1 O At this point we really do not know at what 2 rate they are going to wear, do we?
3 MR. GALLO: Wear? From what?
4 MR. SAVAGE: Wear from the condition they were 5 in when they were put into the condition that they are in 6 at the end of any length of time.
7 MR. GALLO: I object to that question.
8 JUDGE SMITH: Are you still talking about 9 flow-induced vibration?
10 MR. SAVAGE: From flow-induced vibration.
11 JUDGE SMITH: Do you still object?
12 MR. GALLO: No.
_ 13 WITNESS TIMMONS: Would you repeat the question?
I i
/ 14 BY MR. SAVAGE:
15 0 Isn't it a fact that is just going to be a 16 certain amount of time before these tubes wear at the point 17 of the expansion in the baffle plate as a result of 18 flow-induced vibration to a point of 40 percent through-wall 19 and have to be plugged?
20 A (Witness Timmons) There may be some tubes that 21 wear to the point that they have to be pluaged. I don't 22 know how many there are. We have done some preliminary 23 projections, and we are continuing to do those. The number, 24 I would expect to be very small.
25 Q Isn't it true then that the fix is a fix to buy ps
.a e
5999 r~
k,,s)-. 1 A The response frequency of the tube does chance.
2 The response frequency is higher and representative of the 3 tube which is fully supported at both baffle plates.
4 Q Does that,'in turn, increase the internal stress 5 on the tube?
6 JUDGE SMITH: Does what increase? The increased 7 frequency?
8 MR. SAVAGE: The increased frequency.
9 BY MR. SAVAGE:
10 0 Does that affect the tube by providing some 11 additional stress to it that was not there before?
12 A (Witness Timmons) We have done structural
- 13 analysis to the tube for the condition that is represented
\-- 14 by an expansion at the appropriate locations. And the 15 results of those analyses and evaluations indicate that 16 the change in_ stresses is very, very small and that the 17- fatigue usage factor remains below 1.0.
18 Q Isn't it true, Mr. Timmons, that it is just a 19 matter of time before the plugging through-wall percentage 20 of these expanded tubes is reached, whether that time be 21 20 or 30 or whatever the amount of years?
22 A I would expect that some small number of tubes 23 might have to be plugged over the lifetime of the plant.
24 I don't know exactly what that number is, but'I expect it s
25 to be small.
O
- . e. .
6000 O's,,/ 1 time and not to remove the problem from the design of the 2 generator?
3 A The modifications that are envisioned for-the 4 Byron plant have been done to ensure that there is no safety 5 concern with operation of the generator, that the cenerator 6 can safely operate for extended oeriods of time and that
.7 there is no significant wear that will occur that could 8 cause a safety concern.
9 Q You mentioned a question or so ago that there 10 may be some tubes that would have to be plugged in the group 11 ,of expanded tubes. Is that correct?
12 A I said that there may be some tubes that have 13 to be plugged due to vibrational wear.
(.')
s/ 14' Q Has Westinghouse been able to. identify what 15 those tubes -- where they are? Do they have tubes picked 16 out that are likely to be these tubes?
17 A We have general locations of tubes that might 18 be susceptible to continued wear.
19 Q Do you have specific tubes picked out?
20 A I don't have specific tubes picked out.
21 0 Does Westinghouse?
22 A I cannot speak for all of my colleagues. Some 23 of them may have in their minds certain tubes picked out.
1 24 JUDGE SMITH: Didn't you drop something in your 25 premise? What tubes areyou talking about now?
O
__ _ . =~ > . _. . _ .
r\
( f 1 MR. SAVAGE: I am talking about the tubes in 2' .the outer bundle that have been -- expanded tubes is what 3 I am talking about, of the tubes that they are going to 4 expand. And-I take it those are all.in-the outer bundle.
5 BY MR. SAVAGE:
6 0 If you do not have specific tubes picked out, 7 do you have specific bundles of whatever number picked out?
8 A (Witness Timmons) We expect to expand approxi-
- 9. mately 100 tubes. I would expect that some small portion 10 of those might need to be plugged.
11 0 wouldn't plugging them after the generator was 12 in operation for months be a radioactive test?
,.- 13 A Yes, it would.
/s n (l 14 0 If you could pick out the tubes that you expected
- . 15 to have to plug of the expanded tubes, wouldn't it be a 16' good idea to plug them now and not have to do it.later 17 when it is going to be radioactive if-you knew-it was going 18 to happen even with the fix?
l 19 MR. GALLO: Is this a hypothetical question?
20 MR. SAVAGE: I am asking for his opinion.
l 21 MR. GALLO: I object to the question. There is l
l 22 no foundation that itL is fedk'.ble to predict and identify
, 23 which particular tubes will in fact be the ones that may 24 be pluggable at some future time.
l l 25 JUDGE SMITH: Maybe I added confusion. But he 4
v
6002 (O
J.
) I was asking a line of questions, can you identify the tubes 2 that have to be plugged? So then we made him back up and 3 ascertain that he is talking about dur 100 expanded tubes.
4 MR. GALLO: He said out of the 100 tubes there 5 may be a few. He did not say which ones. He testified be 6 didn't know.
7 JUDGE SMITH: The questions he asked before, 8 if they had been asked properly, would have been, can you 9 predict which of those expanded tubes have to be plugaed?
10 That's the question we need.
11 MR. GALLO: Yes.
12 MR. SAVAGE: That's what I was trying to ask him.
13 He said he did not have any in mind. He did not know
/'t
\_/ #
14 whether his colleagues might have any in mind, but they 15 had bundles in mind.
16 Right? Or something. You had groups in mind?
17 JUDGE SMITH: Let's'let the witness bail us out.
18 of our problem here.
19 WITNESS TIMMONS: What is the question?
20 BY MR. SAVAGE:
21 Q Let me put the question another way. If all of 22 the 100 expanded tubes were really plugged and the reactor 23 were operating then at' full percent power, do you know 24 what percent decrease in its capacity to produce steam 25 would be?
O.
V
7 . . . _ _
6003 1 MR. GALLO: Objection. Irrelevant.
2 MR. SAVAGE: It is not irrelevant. I want to ask '
. 3 him next why don't we just plug all the 100 tubes.
4 MR. GALLO: Why don't you just ask him that
, end'S 5 question?
l 6
. 7 8
l 9 10 11 12 s 13 14 15 16 i
i l 17 18 19 20 21 22 23 24 25 1
6004 6-1 g-S - JUDGE SMITH: Is there an objection pending?
. Q) a MR. GALLO: No.
3 JUDGE SMITH: No objection.
4 (Counsel conferring.)
s MR. SAVAGE: If there an objection?
e JUDGE SMITH: No objection.
7 BY MR. SAVAGE:
a Q Do you know by what percent if those 100 tubes 9
you have identified for expansion were plugged or replaced 10 with steel rods or something so that they could not operate 11 as tubes, do you know by what percent that would decrease 12 the capacity of the steam generator to produce steam?
.[\- )h 13 MR. GALLO: I object to that as irrelevant.
14 JUDGE SMITH: It is relevant to exposure.
Is MR. GALLO: There is no issue here about exposure.
16 There is no issue here about the economic capcity of the 17 steam generator. This man's testimony deals with flow induced te vibration. I don't know why.a question intended to elicit 19 -
the operating capacity or information concerning the operating 20 capacity of the reactor with 100 tubes plugged has anything 21 to'do with the flow induced vibration issue.
22 JUDGE SMITH: Why are we interested in flow 23 inducted vibration to begin with either because of safety
-(v or occupational exposure, one or the other?
- 2,
6005 ,
6-2 1
rS g MR. GALLO: I am not aware of the latter concern,
%)
- Your Honor. The gustion of flow induced vibration leads 3
one to consider whether or not tube bursts are going to occur 4
and how it could be avoided by'taking certain measures that 5
this witness testifies to.
6 I fail to see how a question seeking information 7
about whether or not the power of the reactor might have a
to be reduced or whether the flow would be adequate if you 9
plugged 100 tubes has to do with the issue at hand.
10 JUDGE SMITH: Mr. Savage previously asked a question ,
11 I believe, as to whether consideration had been given to
-12 simply-plugging the 100 expanded tubes plan for expansion, e
'%s or replacing them, and we do not recall the answer.
14 My memory is somehow the answer came out. Now 15 let's ask that question. Did Westinghouse-consider just 16 simply plugging or replacing the tubes instead of expanding 17 them?
18 MR. GALLO: You are talking about the approxi-19
. mately 100' tubes?
i 20 JUDGE SMITH: Yes.
21 WITNESS TIMMONS: There has been some consideration 22 given to plugging the tubes or doing something with the tubes 23 other than expanding them. The results of those evaluations
,g 24
(, ) 25 indicated that it was better to leave the tubes in service i
+ . ,- - . - - - . - , - - - .:--
6006 l i
.6-3 i
\
t to'be able to continuously monitor them over periods of time :
(
'k, 2 titan to take them out of service.
3 BY MR. SAVAGE:
4 Q Better for what?
s A (Witness Timmons) For the operation of the plant.
e for being able to monitor the tubes to see if they were ---
7 MR. SAVAGE: That was just my question that e Mr. Gallo objected to.
9 JUDGE SMITH: We.do come back to the point, is to the steam tube integrity problem in question of nuclear safety si _or excluding. occupational exposure or does it not? I do 12 not have a copy of the contention with me.
(/)'
i3 It seems to me that we have not been' litigating i4 generally on the occupational exposure, although there_has is been some incidental refernce to it.
16 MR. GALLO: 'It is.not within the scope of this 17- Contention. We have al, ready litigated ALARA concerns in is connection with another contention.
19 The only consideration in this proceeding on this 2o issue has been the question of the installation of the fix 2e either prior to startup or after startup.
22 JUDGE SMITH: What do you say about it, Mr. Savage, 23 or whomever? I don't have a copy of the contention.
fg 24 MR. SAVAGE: Would you mind if we confer for a
' Q) 25 few minutes.
I' .
6007 6-4 1
- ('N.i JUDGE SMITH: Sure.
(s ,) 2
.(Counsel conferring.)
3 JUDGE SMITH: Let's take a ten-minute break.
4 (Recess.)
s JUDGE SMITH: The question before us was whether 6
to inquire into the feasibility, the practicability of 7
plugging the proposed expanded tubes of about 100 now instead a
of later. The Board is in total agreement that we can 9
inquire into it if the purpose of plugging now is to avoid 10 in the future primary to secondary leakage.
11 The Board has been unable to arrive at a decision 12 as to whether we can inquire now under this contention into
( 13 N whether plugging now will avoid occupational exposure and 14 plugging later without leakage.
15 MR. SAVAGE: Did the Board consider Reg. Guide 16 8.8 in its consideration?
17 JUDGE SMITH. No, we just looked at the language 18
~of the contention.
19' The Board is split on it, but fragmented, let's 20 say.
21 MR. SAVAGE: That is even worse.
22 (Laughter.)
23 MR. SAVAGE: Just for the Board's information f 25 and the parties' information, when and if this issue comes
- . - ... - - - -- . . _- . =_ .
6008 6-5
~
i up again, I would like you to consider it, and it states-I a that specifications for equipment should reflect the objectives
~
3 of the ALARA program.
4 JUDGE SMITH: We do not question that it can be s addressed under ALARA. We are unanimousJon that. The e question-is if it can be addressed under the language of 7 the contention we are litigating now. If you want to reopen ,
a that record cn1 ALARA, that is another issue.
i 9- We are in unanimous agreement that it-would'have 7
io - been appropriate in ALARA.
in MR. SAVAGE: Okay. Let me pursue this line of l
52 questioning.
-O i3 BY MR. SAVAGE:
\s_//
v4 Q Could the hundred tubes you are going to identify is for expansion, Mr. Timmons, be plugged prior to operation
- is of the plant?
i7 A. (Witness Timmons) It is possible to plug' tubes is at any point,.either before or during the operation of the i
i9 plant.
l 2o Q If you plug those 100 tubes before the operation i
2i of the plant, would there be any detrimental effect on the i 22 Operation of the plant?
23 A I would have to perform an evaluation of that. If 24 you-just plugged them and operated at 90 percent flow through
' O
\' as the main nozzle or 100 percent flow through the main nozzle I
I
6009 6-6
~
1 there is a possibility that some of them might vibrate and
/^\
-(_) 2- wear. I do not know how fast they would do that. I do not 3 know how long it would be before they might wear through 4 the wall. There would not be a primary to secondary leak s if they were plugged.
e Q Is it possible before the operation of the plant 7 to replace those tubes with steel tunes, solid tubes?-
e A It is possible to do that before the operation of 9 the plant, depending on when one would plan to begin operation.
to Q Do you know whether there would be any detrimental it effect of doing that?
12 A That would require detailed safety evaluation of
i is what effect that would have on the plant.
[O 14 Q When Westinghouse was considering its fix, did 15 they consider that as an-alternative?
16 A Very early in the planned period. In November 17 and December of 1981 those types of things were considered.
is Q Do you know why that was rejected?
is MR. GALLO: Do you know what one we are talking 2o about?
2: BY MR. SAVAGE:
22 Q Do you know why the option of replacing 100 tubes 23 identified for expansion by solid tubes, that is not plugged 73 24 tubes, just solid tubes, do you know why that alternative 25 .was especially rejected?
6010 6-7 1
j3 A (Witness Timmons) At that point we had not k _s
' 2 identified 100 tubes in a D-4. We had not identified any 3
tubes in a D-4 that had significant wear. That determination 4
was made with. respect to operating D-3 plants. The cost 5
and radiation exposure were judged to be too large to permit 6
that in those plants as an option.
Q Is it true t.lat-by the time Westinghouse had e
identified 100 tubes for expansion because of vibration 9
problems that they did not then consider as an alternative 10 for those 100 tubes replacing them with solid steel tubes?
11 A I don't know of any evaluation that has been done
' 12 in the last few months of just replacing those tubes with solid steel tubes. I would estimate that would be a consider-14 able effort.
15 0 You mentioned that with respect to the hundred 16 tubes identified for expansion in an operating mode of 100 17 percent power with a feedwater configuration of 90/10 it 18 is possible. Perhaps it is likely that certain tubes would have to be plugged in that one group of 100.
20 A It is possible that certain_ tubes might have 2'
to be plugged.
22 O Would operating the plant at 100 percent power 23 feedwater configuration of 70/30 main auxiliary reduce the likelihood that any of those 100 tubes identified for 25 expansion would have to be plugged?
6011 6-8 i
/"'s A. There would be a reduced likelihood that those
\ \
%)
- tubes would vibrate sighificantly, but one has to understand 3
that.the 90/10 configuration at Byronis roughly equ; valent 4
to like 83 percent main nozzle flow at Krsky or in the test 5
models that'we operate because Byron has seven percent less 6
main feed flow to start with.
7 So that you are almost there and with the tube a
expansion you get below vibration levels that have been 9
indicated by instrumentation to be very low.
10 Q I don't know whether you answered my question.
Il Maybe you did. My question was would changing the flow at 12 Byron to be equivalent to a 70/30 flow as experimented with
'- at-Krsko reduce the likelihood that any of those 100 tubes 14 identified for expansion would have to be plugged?
15 MR. GALLO: Plugged over what period of time are
, le we talking about?
17 MR. SAVAGE: I don't know. Over the life of the-
- is plant Iguess.
19 WITNESS TIMMONS. I believe I answered that.
20 Operating at 70/30 for Byron would result-in a reduction 21 of vibration and therefore the likelihood that the tubes 22 would have to be plugged.
23 BY MR. SAVAGE:
,en 24 So the answer is yes. Do you know whether it
(/ 25 Q
6012 6-9 1
would reduce it? Do you know whether the reduction for that a
scenario at Byron would be significant as compared to the 3
fix now recommended by Westinghouse?
4 MR. GALLO: May I have that question back?
s (The question was read by the reporter.)
6 MR. GALLO: I object to the question. It is full 7
of pronouns.
a MR. SAVAGE: I think you are right.
9 JUDGE SMITH: A couple of nouns, too.
10 MR. SAVAGE: It was a bad way to put the question.
11 BY MR. SAVAGE:
12 O You have stated, have you not, that reducing --
13 s- let me preface the question. I am talking now about Byron 14 at 100 percent power with 100 expanded tubes that you have is identified, and my question to you before was as opposed 16 to 100 percent power with a 90/10 feedwater configuration 17 wouldn't 100 percent power at Byron with a 70/30 feedwater le configuration reduce the the likelihood that some of those 19 100 expanded tubes would have to be plugged, and I think 2o you answered yes. Is that correct?
21 A (Witness Timmons) I~ answered yes to the question 22 that you had_ asked. I don't know if I answered yes to the 23 question that you just asked yourself and answered yes to.
geg 24
( ,) 25 JUDGE SMITH: He did not have the 90/10 in the
6013 6 1 premise of your previous answer. Is that your point?
() 2 MR. SAVAGE: I meant to have it in there. I left 3 it out.
4 JUDGE SMITH: Is that correct, Mr. Timmons?
5 WITNESS TIMMONS: His statement was too long and e involved about 80 percent through it that I lost track of 7 where he was going and he ended with a statement and did a not ask a question. I was trying to figure out'where he 9 was. going.
1o JUDLE COLE: Mr. Savage, I would like to ask a 11 couple of questions now.
12 MR. SAVAGE: All right.
(\_e'} 13 JUDGE COLE: Mr. Timmons, you had mentioned a i4 couple of times about the equivalence of flows at Krsko is as compared to eyron and I thought you just indicated that is a certain a flow at Bryon, a certain 90/10 split or whatever i7 was equivalent to some other split or other flow at Krsko.
is Is it the absolute flow into the feedwater section or is
-is it the fraction of flow that is significant with respect 2o to a tube vibration problem?
2: WITNESS TIMMONS: With respect to the tube vibration 22 problem, it is the velocity of the water that goes by the 23 tube and velocity scales I expect are very close to linear
-s 24 with mass flow rate into the steam generator.
~~' So it is the velocity, all other 25- JUDGE COLE:
i
.m , -
m _ _ _ _ - _ . _ _. . ._ __ . _ _ . - - _ _ _ . _ . . . .
6-11
, things being equal, it would be the total rate of flow?
WITNESS TIMMONS: Yes.
3 JUDGE COLE: The Krsko steam generator, it is 4 the same type as at Byron, but is it the same size?
s WITNESS TIMMONS: It is the same type and same
, size. However, the Krsko plant is a two-loop plant as
.f - opposed to four loop, and in order to get the rated power e out of the unit it requires that the steam generator work
, a little harder and therefore the flow rates into the steam io generator are seven percent higher than the flow rates at.
,, Wyron.
12 f, nd 6 13 v
14 a 15 i
[6 I
1 17 J
18 19
'20 21 ,
22 23 24
'\
25 l
I 5
q'
-, , , ...- .. . , , - . - . - , . , . . - . - . . - . - - - - - - - . . . . . . , . . . - . . . . . , . - - . . . ~- . . . _ . . . . - , . , .
o / pv i 6015 gv
(_,) 1 JUDGE COLE: So if both plants are operating at 2 100 percent and no splits at all, the flow at Krsko would 3 be 7 percent higher than the flow at Byron.
4 WITNESS TIMMONS: That is correct.
5 JUDGE COLE: Now, sir, based upon your experiments 6 you have concluded in your testimony that no tube vibration 7 problems were demonstrated at Krsko at flow rates, at least 8 at a split of 70 to 30,or negligible tube vibration problems.
9 Is that correct, sir?
10 WITNESS TIMMONS: That is correct.
11 JUDGE COLE: So if we take the 70 percent of the 12 107, would that not be the analogous flow at Byron that
-, 13 would be comparable and demonstrate the absence of
\_ - -14 significant tube vibration at Byron? Can we make that 15 analogy, sir?
16 WITNESS TIMMONS: Yes.
17 JUDGE COLE: Then what' split would that be at 18 Byron? Can you do that arithmetic? Wouldn't it be 70 19 Percent -- go ahead, I will let you do it.
20 WITNESS TIMMONS: The 70/30 at Krsko is a higher 21 flow than 70/30 at -- higher flow into the main nozzle than 22 70/30 would be at Byron. So at Byron the 70/30 split at 23 Byron would be roughly equivalent to, say, 64-65 percent 24 main nozzle flow at Krsko.
25 JUDGE COLE: All right, sir. I am tryina to o)
(
o e pv #
. 6016 1 get the split at Byron that would be comparable to the 2 70/30 split at Krsko in absolute flow terms. What split 3 at Byron would give you the amount of flow that is 4 equivalent to the 70 percent at Krsko?
5 WITNESS TIMMONS: I. would have to do a calculation-6 to do that.
7 JUDGE COLE: It is something above 70 percent, 8 isn't it?
9 WITNESS TIMMONS: Yes.
10 JUDGE COLE: Hould it be 70 percent, above 70 11 Percent roughly?
12 WITNESS TIMMONS: It would probably be about 13 75 percent.
14 JUDGE COLE: All right, sir. Thank you.
15 JUDGE CALLIHAN: You just said, Mr. Timmons, 16 that ideally at Byron the 75/25 split is preferable.
17 -WITNESS TIMMONS: I said that 75/25 would give 18 the same mass flow rate into the main nozzle of the steam 19 generator as exists at 70/30 at Krsko.
l 20 JUDGE CALLIHAN: Is that desirable from your L
21 experience at-Krsko?
22 WITNESS TIMMONS: If you did not expand.any 1
23 tubes, it would be desirable. The tube expansion process 24 that has been arrived at by Westinghouse obviates the need 25 to reduce flow that much. It becomes an optimization process i
v V
b 7 pv 3 6017
()
,~
i between how much feed you want to bypass and the number 2 of tubes you want to expand.
.3 JUDGE CALLIHAN: Let me ask you to say that 4 again, please. Byron, 100 expanded tubes, what is the 5 desirable split of the coolant flow?
6 WITNESS TIMMONS: 90/10.
7 JUDGE CALLIHAN: Is that conducive, however, to 8 more undesirable vibration?
9 WITNESS TIMMONS: It is my opinion that the 10 level c5 vibrations at that condition would be low enough 11 that there would be no safety concern associated with it.
12 JUDGE CALLIHAN: Thank you.
13 BY MR. SAVAGE:
l3
\_) 14 Q In response to Judge Callihan's questions -- he 15 asked you what was the desirable split with the flow - -
16 you said 90/10. Why isn't it 80/20? Why 90/10?
17 A (Witness Timmons) It is the engineering judgment 18 of Westinghouse based on weighing the considerations 19 involved that it is not necessary to bypass more of the flow l
20 than 10 percent along with the expansion of approximately 21 100 tubes in order to achieve the desired level of
! 22 reduction of vibration.
f 23 0 Is your testimony that an 80/20 split or a 24 70/30 split would not give you any more significant reduction 25 in vibration so as to be beneficial?
b
( ,/
o 7 pv 4
'6018 (3)
/
1 A I do not believe that you get a sianificant 2 reduction in vibration by reducing the flow in the main 3 nozzle from 90 percent to 80 percent. I cannot argue that 4 it might be slightly beneficial, but I do not think it would 5 be significant.
6 0 Do you have any ways of measuring that benefit 7 in terms of time before tubes would have to be plugged?
8 A Evaluations could be conducted to do that. It 9 would take a considerable period of time.
10 Q Westinghouse has not done them to date?
11 A I don't believe that there is a significant 12 amount of information that has been generated to date 13 relative to the benefit accruing from a reduction from p.
s_s) 14 90 percent to 80 percent relative to the impact of that 15 kind of --
16 Q Isn't it true, sir, that 90/10 was chosen because 17 that is the flow distribution that can be achieved at Byron 18 by opening the bypass valve and not making any other 19 modification to the system?
20 A That was part of the input. However, the other 21 factors included how many tubes you would expand given an 22 amount of bypass, the optimization of those relative 23 benefits and the relative impacts of those.
l 24 0 Benefits, relative benefits compared to what?
25 Cost?
f-
%.J l
l
6019 (Oj -1 A That is one of the relative impacts.
2 Q Was there any consideration of exposure of 3 workers to radiation made in coming to this decision?
4 A Part of the impact is radiation exposure to 5 workers. The more tubes you expand in a radioactive plant, 6 the more exposure you get. In that part of an evaluation 7 you would want to minimize the number of tubes you expand.
8 However, you want to optimize that against what it takes 9 to do otherthings.
10 Q That is not where the consideration of worker 11 exposure entered into the Byron decision, because the 12 Byron tubes can be expanded before the generator goes'into 13 operation. That is correct, isn't it?
O
\s l 14 A It is correct that they can be expanded before 15 the unit goes into operation.
16 (Counsel conferring.)
17 MR. SAVAGE: I don't have any other questions.
18 And I want to thank Mr. Timmons for putting up with this.
19 JUDGE SMITH: All right. Mr. Thomas.
20 MR. THOMAS: If I may have just a moment, Judge.
21 (Pause.)
22 CROSS-EXAMINATION 23 BY MR. THOMAS:
I 24 0 Mr. Timmons', I am going to try to avoid any 25 repetition of questions.
fg In your testimony at page 4 you indicate that
! (_/ #
i I
o / pv 6 6020
(_,/ 1 in March of '82 you were appointed manager of reactant 2 coolant systems components licensing. And you currently 3 hold that position, is that right?
4 A (Witness Timmons) That is correct.
5 Q And you also indicate that in March of 1982 6 you had been assioned a collateral position as manaaer of 7 the Steam Generator Task Force.
8 A Manager-for the Steam Generator Task Force.
9 Q So you still hold both those positions at the 10 present time?
11 A That is correct.
12 Q Approximately what percent of your time is 13 devoted to the collateral position that you describe ,as p) i
\_/ 14 manager of licensing for the. Steam Generator Task Force, 15 Model D Steam Generator Task Force?
16 A My assuming the duties as manager of reactor 17 coolant systems component licensing was due to a reoraaniza-18 tion of the group in Nuclear Safety in which I work. My 19 title changed, and some of my scope changed.
20 At that point in time, the Model D program had 21 been reorganized to.a certain extent, and it became 22 necessary to assign someone full-time to work on the 23 licensing aspects of the Model D procram so that there 24 was an individual appointed to act in my stead as manager 25 of reactor coolant component licensing. I have spent O
V
o / pv )
6021 (Q,/ 1 virtually all of my time working on the Model D licensing 2 aspects.
3 Q Why do you describe that as a collateral 4 Position in your testimony?
5 A Because at that time -- I continued to hold 6 both of those positions.
7 Q What is the composition of the Model D Steam 8 Generator Task Force?
9 A It is composed of people who work for 10 Westinghouse in various engineering disciplines.
11 Q APProximately how many people and what disciplines 12 are involved?
13 A It has changed over a long period of time. I 73 i )
\/ 14 think right now there are approximately 200 people involved 15 in it. Someplace between 150 and 200 people. Disciplines 16 include structural evaluation analysis, itclude thermal .
17 hydraulics analysis testing, engineering tooling design.
18 It includes vibration experts.
l 19 Q Now, when did the Model D scale model testing i
20 program begin?
21 A The Model D program as a whole, there were 22 scale models for flow visualization that were constructed 23 in November of 1981, and there have been a number of l 24 models that have been constructed and utilized since then.
25 Major models that were used in design evaluation and design q
\m /
i
---...,s , a ,-- , - - - - -
e e - e , , - - - , , ,. e
b 7 pv 8 6022 (A,) i verification are the ones that I have mentioned in my 2 testimony.
3 JUDGE SMITH: Mr. Thomas, did you provide a 4 cross-examination plan?
5 MR. THOMAS: No. I am proceeding pursuant to 6 the plan that Mr. Savage filed.
7 JUDGE SMITH: Okay.
8 BY MR. THOMAS:
, 9 Q So is it correct then that the scale model 10 testing program Model D actually began at least in some 3
11 respects before you became manager of licensing for that 12 task force?
,, 13 A (Witness Timmons) Yes, it did. I should note, k_) 14 however, that in my duties as manager of mechanical and 15 fluid systems evaluation, which I held at that time, I was 16 responsible for all licensing for steam generating matters 17 within Westinghouse. So I had been involved in this j 18 program virtually since the day that the leak occurred at
! 19 Ringhals 3, and have been involved in engineering discussions l 20 and evaluations from that time.
21 Q When was the Model D Steam Generator Task Force 22 formed or organized?
23 A As a task force it was first organized in early 24 December as a named task force with individuals pulled out 25 of their normal positions .and assigned to work on the Model D
'O
. - - . . . . - - , , . .- ,,.,,-e,~,.._-.y-,._ .,,. ,, , . - . . . , - . , - - - - . - - , - - - - - - -
6023
(-)
q_j
. i program. Prior to that --
2 Q Early December of what year?
3 A 1981. Prior to that, those people who had 4 ordinary line responsibilities for steam generator topics 5 and steam generator evaluations were working to see what 6 the problem was.
7 Q Can you summarize what the task force did before 8 you became manager?
9 A I did essentially the same things as I did after 10 I became manager of the licensing for the task force. I was 11 doing model testing evaluation, structural analysis, setting 12 up and conducting instrumentation programs to' ascertain 13 vibrations, doing metallurgical and visual examination of C-) 14 tubes removed from steam generators, and doing preliminary 15 design evaluations and screenings to ascertain what end 7 16 modifications, if any, were appropriate.
17 18 19 l
20 21 22 23 24
- 25 x_J
~ _ .. - _ _
6024 8-1 i-(S Q What model was done'before you became manager?
(s,/ a A There was model testing done in some airflow models 3
both in .95 scale air models and .417 model testing had begun.
i 4 I think in early January construction of other models was s
ongoing at that time.
6 0 When you became manager was there any work or 7
any safety evaluations conducted kur the task force which a
you had done over again in order to confirm previous results?
9 A Safety evaluations had been done before that.
io They were done under my direction and under my normal line 11 responsibilities in my previous position.
12 The reason I was appointed manager of the licensing 1
i
-['N Ns l is model D program was to give formal recognition to the fact i 14 that the model D activities were consuming a very great portion 15 of trer time and it was necessary to formalize that to the 16 i entire organization so that the person who was acting for.
17 me in my other duties could be recognized by the rest of 18' the organization-as being cognizant of those and that those 19
! people should contact him instead of me.
20 Q Now referring to your testimony.at page 4 and 21 your enswer to; question No. 3, you state that you are 22 responsible for the licensing support activities necessary i
23 l for resolution of.the flow induced vibration issue and you
) go on to state "These activities include the collection and
/'
25
6025 8-2 -
i review of engineering information." What do you mean by a engineering information?
3 A Accelerometer data, instrumentation data, results 4 of-tests and analyses, results of calculations, inputs to s analyses and calculations and evaluations of the results e of test data and analyses.
- 7 Q As manager did you personally review this engineerin g a information that you have just described?
9 A Yes, I did.
io Q In addition to that, you state that you were
- responsible for the performance and documentation of safety i2 evaluations. Can you explain what you mean by the documenta-
h i3 tion of safety evaluations?
V i4 A Putting the words on paper, getting them reviewed is and signed off and put into files.
i6 Q Signed off by whom?
17 A The cognizant individuals such as myself in terms is of the Nuclear Safet*, Department signature required by i9 the procedures and also the cognizant engineering individuals i
l 2o in tne disciplines that'are affected by the particular i
ai safety evaluations.
22 Q You also indicate that you were responsible for 23 the definition and evaluation of applicable regulatory 1
~, 24 criteria. What regulatory criteria are you referring to 25 there?
6026 8-3 i
- i. A Criteria-that have been utilized in steam generator Ss / 2 integrity evaluations such as 1.121, 1.183, ASME Code, and 3
those type of criteria.
4 Q. Did you include Reg. Guide 8.8 in your evaluation?
5 A At times if it was-appropriate, the ALARA concepts 6
were included in the evaluations.
7 Q At what points did you deem that to be appropriate a
for consideration and evaluation?
9 A Where we were evaluating something-where it was 1o necessary for workers to be exposed to radiation in the conduct 11 of their work.
12 Q In answer 5 you' discuss the design variations O)
(,, of the model-D steam generators. At page 6 of that same i 14 l answer, at the end of the first full paragraph, you state 15 that the Model D-3 has a different impingement plate design
- than the D-2." What is different about that design?
17 A The details of the configuration of the holes
[ and porosity and those kinds of things.
l Q What are the conceptual differences in those i
! 20 l details?
, A They are essentially design details, placement 22 of holes, number of holes and that kind of thing.
Q What is the point of the design differences I
/' guess is what I am trying to find out?
U) 25 A It results in slightly different flow distributions i
- .- - - .__ .=. ,
6027 8-4 1 in the inner plenum of the split flow distributions.
/~%
k,).
s 2 Q What is the purpose of achieving those different 3 flow distributions?
4 MR. GALLO: I will object after he completes 5 _the question, e MR. THOMAS: That is the complete question.
7 MR. GALLO: Objection on the grounds that-it is a immaterial. We'are talking about the D-4 anc D-5 steam 9 generators. Counsel has carried on this inquiry about the to dif ference between the designs of the D-2 and D-3 to such it a level of detail that it is not material to the proceeding.
12 MR. THOMAS: Judge, I think as long as we are
[~' is dealing with -- I am sorry. To respond, I think as long Q.))
i4 as we are dealing with the D model, the model D steam.
15 generators and their design enhancement in the 2's , the 3's, 16 the 4's or the 5's, I think it is certainly relevant.to our 17 inquiry here.
is JUDGE SMITd: The Board agrees. We would note 19 that the question was one of materiality and not relevance 2o and we agree.
2: The objection is overruled.
22 WITNESS TIMMONS: May I have the question again.
23 MR. THOMAS. Would you read it back.
gg 24 (The pending question was read by the reporter.)
' \l 25 WITNESS TIMMONS. That is a design detail that
- - - - ,p- .- 7--. --,,-y 3 . - - - -+------i--.-.. --m. w-= m
6028 8-5 occurred I think befcre I came to work-at Westinghouse. I (O ,j a
~
am not sure what the designer intended to do in changing 3 the design from the D-2.to the D-3 impingement plate. All 4 I know'is that the specific designs result in different s flow patterns in the inlet pass.
s BY MR. THOMAS.
J 7 Q You do not know what the reason for.that was?
s A (Witness Timmons) No, I don't.
9 Q If you knoW,. is one impingement plate design to more effective in reducing ficw induced vibration?
11 A I think in the D-2 and D-3 steam generators the 12 -impingement plates result in redistribution of the incoming
()
Q.)
is feedwater. As a result of that, there are flow induced i4' vibrations in tubes in both steam generators, both types 15 of steam generators. I cannot make a quantitative assessment i
16 relative to the amount of vibrations between the two designs.
t 17 Q Now, further down, in' fact in the next sentence,
- se . you say that in the counterflow type, and'you refer to 19 Attachment 4, the incoming feedwater enters the inlet water 2o . box and impinges on a wall that directs the water outward i-l l 2i to fill the water box volume and downward to the preheater 22 inlet pass.
23 Looking at Attachment 4 and referring you to the f- 24 horizontal arrow just in front of the feedwater nozzle, do 25 you see what I am talking about there?
l r
i I
y n-, ,,e-- ,. . _ . _ .. , , . , , - , , _ _ . , , , . , . . . . .w.- m,.2 . . - , . , _ . ,, , .- . . . . , . _ _
6029 6
A The,horizonatal arrow ---
l (]/
\s , 2 Q Directeo away from ----
3 A The device that is inserted-into the center of d 4 the representation of the inlet nozzle?
5 Q Right. Then there is what appears to be a long 6
wall.
7 A That is correct.
e Q It appears that the top of that wall is located 9
, some distance above the point where the water from the feed-io water nozzle impacts upon the wall. Is that correct?
11 A That is correct.
-12 Q~ So when you say outward in the testimony that I fs. _- 13 just referred you to, do you mean upward?
14 A The feedwater nozzle coming into the steam 15 generator has an inside diameter of about 14 inches. The 16 impingement wall has a width of about three feet. So that l 17
.the water coming into that inlet water box impingers on the back wall and. spreads outward to fill above it and to the 19-l sides of it. So that it hydraulically attempts to fill the 20
- space available in that inlet area.
21 r Q Is that what you meant by outward when you 22 L
described the water?
23
, A Yes.
()
24 Q At any rate, some of this water is going to go
~'
25
- y------s m-w ? --?"' #
f
6030 8- 7' 4
e upward,-isn't it?
O
( ,/ 2 A Yes.
s Q Since that is attached above the feedwater nozzle
^
_4 there, some of it is going to have to change its direction s then and move' downward to the inlet pass; isn't that right?
6 A I am not sure what.you are trying to get at. The 7 feedwater spreads out. Some goes up through the top of the i
a water box and the rest of it goes down and through the inlet i
o area of the first pass.
io Q Okay, the water comes out of the feedwater nozzle is and hits what you have called the impingement wall here, 12 right?
i3 A That is correct.
i4 Q Some of it is going to go up toward the top of is the box?
4 is A That is correct.
l i7 Q Are you saying it can pass through the top there?
is A There are. holes drilled in the top of the box l
l is to allow water to go through the top.
2o Q That is what I was trying to understand. So the l
l 2i top is not solid here.
22 A It is a solid plate with several holes drilled 23 in it.
24 JUDGE SMITH. The diagram really then should have as an arrow passing through ---
. . _ . .. .. . . . . . . _ . . - ~ ~ . . . - . .
l.
6031 4
'8-8
, t p MR. THOMAS: Just'through the top of that. !
Gi n JUDGE SMITH: To be consistent with his testimony.
3
- MR. THOMAS: That is right. I 4
BY MR. THOMAS:
5 4
Q What degree of turbulence,.if any, if caused from
! e
- . the water hitting the impingement wall and going up and
-7 down as you have described it? There is turbulence produced i
a t
there, isn't there?
9 i A- (Witness-Timmons) Some turbulence is produced,
, to jend8 11 1
12 i
, '13 i
14
! 15 i
[ 16
[.
17 18 19 20 21 22 23 1 24 25 l
. . . . , . _ _ . . _ , .- _ . . . _ _ . _ . ~ . . _ _ _ _. - .-
6032 O.
(_,) 1 Q The turbulence that is caused by the water hitting 2 the impingement wall, directing your attention to that 3
water which would go down as indicated by the arrow on the 4
diagram, does that turbulence increase when it changes 5 direction from going down and starts going to the left as 6 you look at the diagram?
7 A I don't know what the level of turbulence change 8 is. There is still some turbulence associated with the 9
fluid flows as it enters the tube bundle at that area.
10 Q That was my next question. The tube bundle is 11 located just on the other side of that impingement wall, is 12 that' correct?
13 (q
\ J' 14 A That is correct.
Q Is the process we have just described of the 15 water hitting the impingement plate, is that the source of 16 the turbulence in the D-4s and the D-5s?
17 A That coupled with the churning of the flow as 18 it enters the inlet path.
19 Q Just for the record, because this attachment is 20 not labeled, is the inlet path that area where -- that we 21 were just describing where you have the curvina arrow 22 pointing down on Attachment 4?
23 A That's correct.
24 JUDGE COLE: There are two curved arrows 25 pointing downward.
O QJ
b 9 pv 2 6033
?
(, ,/ - 1 MR. THOMAS: Okay.
2 BY MR. THOMAS:
3 Q The one between the impingement wall. What is 4 the name of the wall on the other side?
5 A (Witness Timmons) The wrapper, the steam 6 generator wrapper.
7 Q At the point where the turbulent water enters 8 the inlet path is there a positive or a negative wave 9 interference at that point?
10 A I am not sure what you mean by " positive 11 or negative ~ wave interference."
12 O I will strike that, withdraw what question.
13 I think it has already been answered.
\/
) 14 Does the water that enters the water box from the 15 main nozzle enter at a constant rate from one moment to 16 the next?
17 A Constant within the capability of the feed cumps 18 to supply water at a constant flow rate.
19 Q Does the -- I take it then from your answer that 20 because it is a pump and the pump oscillates, there are 21 some spurts involved. Is that correct?
22 A Them are some oscillations in flow and pressure 23 that do occur in the delivery cf the feedwater into the 24 steam generator.
25 Q Do you know if the main feedwater nozzle has a ns_-
o9 pv 3 6034
(/~)
v i flow restrictor on it?
2 A Yes, it does. That is the representation of the 3 curved arcs inside the nozzle there.
4 Q What is the purpose of that device?
5 A It is a device that is installed in the steam 6 generator to restrict the outward flow of water from the 7 steam generator should a double-ended main feed line break 8 occur where water would come out of the steam generator 9 through that nozzle and out through the postulated main 10 feed line break. And that reduces the rate of flow out of 11 the steam generator during that occurrence.
12 Q Referring to your testimony at page 7 where you
-, 13 are still discussing the design differences, this time
\m / 14 between the D-4 and -- well, this is not design difference,.
15 but you indicate that D-4s and 5s are equipped with a 16 T-shaped blowdown pipe to minimize the accumulation of 17 sludge on the tube sheet.
18 How wide is this T-shaped blowdown pipe?
19 A Approximately as wide as two tube steam generator 20 tubes plus the space between the tubes.
21 Q Where is the main feedwater nozzle with respect 22 to this lane, this T-shaped lane?
23 A If you look at Attachment 5, which is what we 24 refer to as a tube sheet map, every intersection of horizontal 25 and vertical line represents a location where a tube would t
v
o y pv 4 6035 7
/O
( ,) i be within the outline of the circles. The T-shape in the 2 center is that T-shaped lane that I referred to. To the left 3 lof the T-shaped lane there is an arc that represents the 4 location of the wrapper of the steam generator.
5 The space between that wrapper and the first 6 or 49th row of tubes is the location of the inlet plenum 7 where the feedwater comes in. So the feedwater comes down 8 the inlet _ plenum into the first path of the steam generator 9 location where the. stem of the T is located.
10 Q Referring again to Attachment 5, what are the 11 boundaries of the preheater section?
12 A With respect to Attachment 5?
13 Q Yes.
O
- \_ I 14 J A Attachment 5 represents one symmetrical path of 15 the steam generator, either the cold leg or the hot leg.
16 / And since these are U-tubes that go around in a U-shape and 17 the other end of the tube goes into the opposite side of the 18 steam generator, if this were to represent the cold leg of
! 19 the steam generator, the preheater is such that every tube 20 located on this representation is located in the preheater
( 21 through the cold leg portion of the steam generator in the i
22 preheater area.
l 23 JUDGE COLE: May I ask a question at this point?
l
! 24 Mr. Timmons, you indicated with respect to Attachment 5 in l
[ 25 your testimony that each place a line intersects is a i
k s_-
oy pv a 6036 1 location for a steam generator tube. What are the souares?
2 WITNESS TIMMONS: The squares represent what I 3 refer to as stay rods which are used to hold the support 4 plates in place during a tubing operation.
5 JUDGE COLE: Thank you.
6 WITNESS TIMMONS: So there is no tub 3within the 7 white space.
8 JUDGE CALLIHAN: Even more basically for the 9 record is Attachment 5, an elevation or a plan view.
10 WITNESS TIMMONS: A plan view.
11 BY MR. THOMAS:
12 Q Where Attachment 5 indicates nozzle, what nozzle
-~ 13 is that referring to?
14 A (Witness Timmons) That is the primary side 15 nozzle from the reactor coolant system into the channel head 16 primary side of the steam generator.
17 Q Referring you back again to Attachment Number 4 18 and the baffle plates, how are those baffle olates attached?
19 A I believe they are welded to the wracoor or to 20 the impingement plate at the locations, at various locations 21 around the circumference.
22 JUDGE CALLIHAN: In Attachment 4, which I presume 23 now is an elevation, where is the centerline of the steam 24 generator?
25 WITNESS TIMMONS: The vertical plate shown in the
\
b_9 pv 6 6037 f)
(_,/ 1 drawing that starts above the flow ~ distribution baffle at 2 the bottom of the inlet path and extends up with nothing 3 attached to it at the top represents the centerline of 4 the steam generator.
5 JUDGE CALLIHAN: So the centerline of the steam 6 generator is the center of this diagram?
7 WITNESS TIMMONS: That's correct.
8 BY MR. THOMAS:
- 9. O Directing your attention again on 4 to the --
10 well, after the inlet path then there is an arrow pointing 11 up. Is that gap that is depicted on the diaoram there, is 12 that a gap or is it a round hole?
,_ 13 A (Witness Timmons) It is a gap.
I
\
{ s- 14 0 With regard to the baffle plates, what holds them i 15 uo from the weld on out? Are there any spacer bars there 16 or any supporting bars?
17 A As I mentioned in reference to Attachment 5.
18 Q Are those the squares that you were talking about?
l 19 A The squares.
I 20 Q Okay. Are pu familiar with a baffle plate which 21 became loose at Cook Units 1 and 2 in 1980? Are you familiar
- 22 with that?
23 A No, I am not.
24 Q Mr. Fletcher, could I address the same question 25 to Mr. Fletcher?
n v
b $ pv'l
[
6037-A (A) y A (Witness Fletcher) Mr. Thomas, I was just trying 2 to recall. I really do not recall the event without more 3 information. I am straining my_ memory tx) recall. I just 4 do not have a recollection of that.
5 Q Are we talking about the same baffle plates? Do 6 you have that degree of recollection?
7 A That is the first thing, I guess, that confuses 8 me. The Cook units are a different model steam generator, 9 and they don't have baffle plates as we refer to platea 10 in the preheater. They do not have a preheater model steam 11 generator. They have tube support plates.
12 Q Okay.
13 (Counsel conferring.)
b
(,s/ 14 Q Mr. Timmons, referring to your testimony in 15 answer 6, where you discuss how the major design differences 16 affect tube vibration, and referring to page 8, you indicate 17 that the presence of the T-slot in the tube bundle produces 18 a pathway for flow to preferentially enter and permit some 19 amplitude of vibration of a few additional tubes on either 20 side thereof. Do you see where I am referring?
l 21 A (Witness Timmons) Yes, I do.
22 Q What is the degree of amplitude of v2 ration 23 which occurs on either side of this T-slot?
24 A Specific numbers for the amplitude would be 25 proprietary.
m
b 9 pv 8 6038 Y
(/,,).
1 Q In your opinion, is it significant -- does it 2 produce significant tube vibration, as you have used that 3 term in your testimony previously?
4 A For a few of those tubes along the T-slot, the 5 vibration levels would be significant.
6 0 Is this the location of the 100 tubes that we 7 are talking about that are going to be expanded at Byron?
8 A It is perhaps the location of some of them.
9 0 When you say "perhaps," can you explain what 10 you mean by "perhaps"?
11 A I would expect that perhaps the first few tubes 12 along the T-slot might be expanded along with some in the
_ 13 outer rows.
, \ms 14 Q Areyou saying that the 100, he specific 100
.15 tubes to be expanded, have not yet been identified?
16 A There have been preliminary identifications of 17 which ones might be expanded, but further definition of 18 exactly which ones and the selection of the final tubes 19 that would be expanded is scheduled for sometime in June.
20 Q How many tubes have been identified at this 21 point as being potential tubes to be expanded?
r i end 9 22 A About 100.
23 24 25 n,
x_
- , - - . . ~ . - - . , - ,. . - , , - - - . . - -
6039 10-l' 1
'(~'S Q Does this mean that when the final decision is
'(_,/ -2 made, did you say in early June?
3 A' 'Early to mid-June.
4 0 Does this mean that when the final decision is made 5
that there could be more than 100' tubes that would be expanded?
6-A Based on the state of the engineering test of the 7
data I would expect that there might be a reduction in the 8
numberfas opposed to an increase in the number. I think that 9
engineering personnel believe that they have bounded the so number with a number like 100 and they are proceeding to get 11 more detailed testing information which would allow them 12 i to reduce.that number.
l
('T
\/
,3 0 I take it your answer to my question about whether 14 the specific. tubes are going to be plugged, whether those
! is have been identified yet, that the answer would be no to 16
- that question; is that correct?
{ 17 MR. GOLDEERG: Did you mean expanded?
- te MR. THOMAS
- Yes, I am sorry.
19 WITNESS TIMdONS: Yes. The specific tubes to 20 l
l- be expanded have not yet been put in a document and signed 21 off by the enginering personnel responsible for doing that 22 task.
23 JUDGE SMITH: Is your testimony that the candidate s~J as tubes and the boundir.g have been identified?
, - . _ _ - . _ _ _ _ --, - m ,.
6040 10-2 4
8
,. . WITNESS TIMMONS: Yes,JI believe they have.
g(. 1 2
BY MR. THOMAS:
3 A I~would address t' hat question at this point to d
Mr. Butterfield. I am sorry, I don't know which person he 5
is.
e Is Commonwealth Edison aware of the preliminary 7 nature of this recommendation regarding expanded tubes?
e A Yes.
(Witness Butterfield) 4
- With regard to the nature of the identification Q.
") of the hundred tubes, is that contained in a document of some type?
12
, Q We have had presentations made to us by Westinghouse A 13 where they have showed candidate regions for these expanded 4
1 1 u/
'd tubes. They_have' prepared a preliminary doc ment on tube
'5 expansion which I believe has enclosed in it the same se information. I would have to look at the document again
'7 to see.
is O What is the date of that document? How recent 19 is it is what-I am trying ---
20 A Within the last week.
2: I take it from what you say that Edison has not Q
22 had an opportunity to verify if any way the matters presented 23 to it by Westinghouse.
s 24 A g Commonwealth Edison's primary interst is resolving s_/ as whether the fix will perform the function that it was intended
6041 10-3 to do. We have been'in receipt of information, both verbal f
/
I
\ s)'. 2
.and copies of'transpare.ncies that were given in these 3
verbal presentations which have led me to the conclusion 4
that the modifications will pertorm the intended' function,
' 5 that is,. reduce the-flow-induced vibration.
8 The exact tubes, their locations, are an engineering 7 detail-that are still undergoing evaluation. When that a is completed, then we will look.at that also.
Q- But it has not been-completed yet and you have
") not looked at it yet, right?
1 A That is correct. i 12 (Counsel confer.)
/~\ '3 Q Mr. Timmons, referring back again to Attachment
(\~-)
5,.would you identify for us, please, all locations of
'5 candidate tubes for expansion?
?
[
"5 A (Witness Timmons) I believe we have kept-that
'7 information proprietary. The tubes are primarily in the
"' outer row 49, some in row 48 and some along the T-slot.
'S MR. THOMAS: Excuse me, Judge. I was not here.
~,2o I know there was a discussion regarding the procedure 2i for proprietary information.
I 22 JUDGE SMITH: If you feel that you have to have 23 the answer ---
24 MR. THOMAS: Am I to save up these questions s
{"'/
s_ 25 until the end? Is that the procedure that we are following?
I _ - -
, . . . . , - _. ,__ _,_ _ _ _ _ _,, ~--. - . ~ - - - .
6042 10-4 i
JUDGE SMITH: Our, arrangement in the first place,
/-ss
'l- a N do we have the protective agreements yet? You do not need 3 .
one because you are an attorney.
4 MR. DAVIS: I have blank protective agreements-s in my possession, and the offer that I made yesterday to 6
have intervenors or other parties sign the protective agree-7 ments, it still stands and no on has signed them yet or a
has approached me yet.
9 Mr. Thomas did not signed a protective agreement
, io that was proposed some weeks ago by Mr. Gallo at an' earlier si stage of'this proceeding.
12-JUDGE SMITE: Normally we would not require
- (,j 13 attorneys to sign aprotective agreement. They would.be i4 subject to simply our order. That is my experience. I 15 think that is the tradition.
j- is MR.-GALLO: Judge, I would like to make it clear 17 that Mr. Thomas'did not refuse to sign the agreement. We 18 simply did not have a copy at the time that he was available with pen in hand. So we have not been able to match the 20 two so far.
21 MR. DAVIS: I am sorry for that misapplication
- 2
~
of the term " refused."
23 JUDGE SMITH: So the arragement is that if you N feel you have to have the answer, we will schedule a session.
("'l
(" - as We will collect all of the questions that will involve vee- g y w gr ry - ,-7-iw.- ,%y .m , - - -
t y - -
10-5 6043 i proprietary answers and we will schedule.a session for s
l 5 .
- (,/ a in-camera.
3 It just occurred to me, just as we sit here, that 4 there may be another way also, that you could simply ask 1
l s during a break what the answer is and see if you really need e it since you are already covered by a proprietary agreement.
l 7 There is no use of scheduling in. camera sessions a to have everybody leave the room and then find out the answer i 9 is useless.
I n3 MR. THOMAS: I have no problem with that. I am l
,, not saying that we have made a determination that would i l
12 necessarily need that answer. We have now hit upon two l or three questions where the answer has been that it is
, -.{"'s) .
i3
,4 proprietary, and I just wanted to know the procedure that
! is we should be following in dealing with that.
t I
! is JUDGE SMITH: You should be keeping a count of i7 them and then,make a motion or a request for an in camera is- session if you need it.
I ig MR. THOMAS: All right.
2o BY MR. THOMAS:
l 2, Q I want to address this question to either
,2 Mr. Butterfield or Mr. Tinunons , whoever is in a position l
23 to best answer it. That is with regard to the preliminary
,- 24 nature of the Westinghouse recommendation for the fix or
( l 25 the modification at Byron. Whan was the modification or
6044 10 '
-t the proposed modification first communicated to Edison
/~
(T ,/ z' .in writing or has it been communicated in writing at this 3 -point?
4 'A (Witness Timmons) I believe there was a letter
~
5 sent to Edison.last week. Prior to that there had'been a e . number or oral communications and-presentations to Common-7 wealth Edison personnel starting in the time period between a February 8th to 15th and extending until the present.
E 9 Q Of 1983?
io A 1983.
1 Q Approximately how many oral-presentations have 2 there been beginning at that period of time through the present
' f)
! is time?
, s- /
I 14 A (Witness Butterfield) I think I have-been in is three or four oral presentations.
is Q And you were the person at Edison who would be 17 responsible for this area?
i-is A If I may go back a little bit in history, the 19 problem has been known by Commonwealth Edison dealing with l
l- 2o the flow induced vibration for quite a while.
2: In the normal mode of operation this is handled 22 through the project team and the vendor in this case was I
2 23 Westinghouse. Late last year it was decided that we should
_gs '24 provide some special attention to it because the project k'
25 team is involved in many more routine operations.
10-7 1
I was. brought into this project or into the' scope
(% ~
3s-)L a of-the project about February 8th to 15th, about the time 8 of the first presentation by Westinghouse'and I have been d -involved in it every since.
[ s. A (Witness Timmons) Those were.only presentations 6 ' directed toWard3 the specific recommendation that Westinghouse 7 was making at that time. There have been other presentations s at which Commonwealth Edison personnel had been in attendance
-9 nad have received information that dates back to. February I
to of 1982.
f II Q When you say specific recommendations, do you mean i 12 for Byron? Is that what you mean?-
() 83 A Yes. There-have been other generic meetings at id' which Commonwealth Edison people were in attendance and
! 15 received information relative to the model D program in 16 general and also with respect to the counterflow portion of f 17 that program.
l
! is end 10 19 20 21 22 23
'% 24 J 25 l...,. . -
. - - - .-, . - - . - - - - - = , - - , -- - -. -- -
~6046 B-ll-b - 1 1
\_/ 1 With regard to the letter, what is the'date of O
2 the letter, who is the letter directed to and who is it from?
3 MR. GALLO: Objection. Why is that materia?
4 MR. THOMAS: It is material because I wish to 5' identify it. I think the letter should be produced. We are 6
talking about a letter proposing a specific fix dealing with 7
the very problem at issue here. And I would like to examine O
the letter to see if there are any differences between the 9
letter and the testimony. That seems to me to be a very mat-10 erial document. .I did not know of its existence before right 11 now. I don't know if other people did, but I didn't.
MR. GALLO: I just think it is inappropriate to
,, 13 use cross-examination for discovery purposes. These witnesses
\- / 14 are representing the Company position, and there is no evi-15 dence of any inconsistency being elicited on this record. I 16 think it is just a frolick to continue pursuing the date of 17 the letter and all of that sort of thing.
18 MR. THOMAS: Judge, my response would be that I 19 would think that the Applicant would have a duty to make 20 the existence of a letter like this know, and I am not using 21 cross for discovery. It just so happens that -- I am sure the Board is aware of my position.
23 MR. GALLO: Well, your Honor, the duty to disclose 24 has been satisfied by the introduction of Mr. Butterfield's 25 testimony which was violently objected to yesterday by
^
t
-t N_
6047
/%
( j'b-2 1 counsel for the Intervenors.
2 JUDGE SMITH: I don't see any duty or breach of 3 duty. I do not think it turns on that. The information 4
happened to be developed now, and it was not developed before ,
5 I don't think anybody has failed in any.responsibilitics.
6 MR.-THOMAS: I do not wish to make a discovery 7 issue out of it. I would again move for production of that 8 letter.
9 JUDGE SMITH: I will overrule the objection. It 10 is overruled, 11 BY MR. THOMAS:
12 O I think the question was: What was the date of
! 13 the letter?
- G
_ 14 JUDGE SMITH: Go ahead.
l 15 MR. THOMAS: Rather than asking the specific ques-16 tions, may we have that letter produced?
17 MR. GALLO: I will have to discuss it with my 18 client. Right now I refuse to produce it unless ordered by 19 the Board. I see no relevance. He is indulging in some 20 exercise, fantasy that he believes that if he gets the letter 21 perhaps he can impeach the testimony of one of these witnesses ,
22 I do not understand that. That should not be per-23 mitted. It is simply a diversion.
l l
The real task at hand is l 24 to cross-examine these witnesses on the basis of their testi-25 mony.
( es
(
l l
i ..
h-6048 II 3
L' V 1 JUDGE SMITH:
Let's break for-lunch and return'at '
2-. -1:05 and then we will rule.
s 3- (Whereupon, the proceedings were recessed for 4 lunch'at 11:50 a.m. to return at 1:05 p.m. the same day.
E-11 :
1 -5 t
4- 6 7 :
8 l i
i i 9 r
- . 10 "
- 11-l 12 1
e 13 14 .
15- .
16~
i I-17 !
e 18
- 19 20 21
- 22
. 23 24 l.
25 0
. , . . . , . - - , _ _ .,__....m.- ,_,._.--.,-,-,,.,_-r_..,.,,,,,__
,,__-ty, ye,, -r _
--.__v. , _ _ _ , . . , , - -
I '
~6049
{. , AFTERNOOU SESSION t (1:15 p.m.)
2
-3 MR. GALLO: During the luncheon recess I discussed j
4 the letter that was the subject of Mr. Thomas' inquiry prior s -to lunch, and I find in fact that.the letter has not'been
- e received by Commonwealth Edison.
t 7 Now what the situation is that Mr. Timmons thought '
s or had seen a letter in draft within the Westinghouse
- 9 organization and had assumed that it had been sent to i
10 Cormionwealth Edison.
11 In fact, it is my understanding that it has not l 2 yet been sent and that is the current status. There is no 13 letter to produce at this point.
84 MR. THOMAS: What he says illustrates even acre
~
'5 the experimental status of the proposed recommendation or 16 the fix and how up in the air this whole thing is.
17 JUDGE SMITH-. Now wait a minute. Now you are a
is arguing. The issue before us is can I order Mr. Gallo to 19 produce a latter hedoesn't have.
2o MR. THOMAS: Is that what you are saying, that 21 you don't'have it. Ee said there is no letter. As he 22 said, there is no letter, but there is a document which I 23 understand has been prepared and has presumably been signed 24 off,
(..- as The fact that the Commonwealth Edison hasn't i
t l
- l. =. _ _ _ _ _ . _ . , _ , , . . _ . _ . _ . - - .._.t.,_,,. _ . _ . , . , _ ._ . _ . . - . - , _ _ . .
6050 12_2 t
i received it yet, if that is the case, is not relevant to
(~%
i g, a the question of product 3on of the document. -
8 JUDGE SMITH: It is relevant to my authority to d
direct anybody to produce it.
s MR. GALLO:
_ Does Mr. Thomas doubt my representation a that the letter has not been received?
7 MR. THOMAS: No, no, I am not doubting that.
- e JUDGE SMITH
- There apparently is a letter in 8 draft form. Is that what we have learned?' Who is the 10 author?
11 MR. THOMAS: Let rae ask Mr. Timmons some foundation l 32 questions. In fact, that is what I was doing at the point 83 where an objection was made.
(%w)
+' 84 dhereupaa,
'5 - JOHN BLOMGREN
'6 THOMAS TIMMONS 4
' '7 WILSON FLETCHER te '
MICHAEL HITCHLER f
l r _
l 19 AND 2o LAWRENCE BUTTERFIELD
- j. 23 having been previously duly sworr., were further examined
- 2 and testified as follows.
23 CROSS-EXAMINATION (Resumed) 24 BY MR. THOMAS.
2s Mr. Timmons, when we broke for lunch we made Q
...A 4 _
6051 12-3' 4
-i reference to a letter'and one of the questions I asked about
.p
'-(,) a that was to whom'was the letter directed?
3 A -(Witness Timmons) I think the draft of the letter 4 I saw was directed.to one of the project managers of the s Byron project for Commonwealth Edison. I- believe it is e Mr. Deress.
7 Q Mr. --- ?
e A Mr. Deress.
i j , O Can you spell it for the record.
io A D-e-r-e-s-s, ii Q Was this draft over your signature?
- 12 A No.
Q. Who from Westinghouse?
I . s-f~} i3
- i4 A It was being sent from the Westinghouse Project is. Office to the Commonwealth Edison Project Office.
ie Q Who was signing off on it for' Westinghouse?
i7 A I believe it was either Mr. McGuffin or Mr.Kortier, i
is Q Was the NRC copied in on the letter?
, -i9.
lat I know of.
2o Q Or involved in the distribution of the letter in 23 any way?
22 A N . This was merely a letter from Westinghouse 23 to Commonwealth. Edison putting in writing the fact that 2, the Westinghouse proposed modification that had been discussed O as with them had been recommended to them orally. It was just
6052 12 -t a-letter reiterating that and confirming it in writing.
() .a Q If you know, did Commonwealth Edison request 3 that letter?
4 A I think Westinghouse had planned to send the letter
- 5 ~just to put it in writing, the fact that-we had discussed i
! e it with them and that was the recommenaation. It was just 7 to put the recommendadtion in' writing to them.
o O And this was the first time that the recommendation j e nad been put into writing, to your knoweldge, to Edison,.
1 to that is? -
in A The first time that our Project Office would-have 12 transmitted a document to Commonwealth Edison delineating
. , 13 what the recommendation was. We have sent.other things to I
t4 them that contained elements of their recommendation.
is Q But I mean in terms of describing the entire is proposed recommendation, this would be the first then, right?
17 A We sent them copies of slides from oral presentations 1
l is for their use that contained in thera descriptions of the
.i , recommendation in the background that pertained to it i
2o Q Did you review that letter yourself?
! 2 A No, I did not review the letter. I saw it. I 22 Q In what context did you see it?
23 A I was talking to the Project Engineer. He had 24 the letter with him and he was in the process of redrafting 25 a previous version of the letter and inserting comments and l
i.
-_...,e-. - . . , . . , . - .
12-5 6053 that kind of thing.
( ,)
A 2 Q And the events you were describing were going on 3 last week?
4 A That is correct.
5 Q Do you know when the letter is to ce sent?
e A I thought it was going to go out last week. But 7 if not last week, it would be this week c: next week.
a Q To your knowledge, does the letter contain any 9 details regarding the proposed modification which are not to contained in your testimony?
11 A The draft that I saw does not contain any details 12 tnat are not contained in my testimony. It would be like a one or a two-paragraph letter that says as we discussed I~
v
} is 14 in our meetings, the recommendation is to expand 100 tubes is and divert 10 percent of the feedwater.
te Q To the best of your knowledge, are there any 17 . differences between the modification Contained in the is letter and your testimony's 19 A No, there are no ditferences that I Know of.
i l
! 20 MR. THOMAS: Judge, then I think under the 21 circumstances I would simply move that when and if the 22 letter is sent, that we receive a copy of it.
23 JUDGE SMITH. I don't know. We hope to close 73 24 the record on this issue this week.
I,
)
l 25 MR. THOMAS. I know, and I was aware of that at
12-6 6054 i the time this. matter came up, but I think that given the
, (f a present status of this issue, that it seems apparent to me s from the testimony that there are still ongoing discussions, l 4- experiments, tests, and so forth and so on. I think this s is an issue. It is difficult to close the record on it
, without just arbitr.arily. cutting it off.
7 JUDGE SMITH: Do you object to giving a copy of e the letter to counsel when it is received?
g MR. GALLO; No, Your Honor.
io JUDGE SMITH: You would then have to understand i
,, that if the record is closed in the proceeding, you would t
12 then have to make a motion to reopen based upon the letter T ,3 before you could use it because we could act use the contents i
.)
g of any such letter in our initial decision unless the record is were reopened, and that- is why I was not especially eager te to -- it is moot now since he nas agred to offer it.
,, MR. THOMAS: ,I realize that, Your Honor, but I
,, think, although this does involve necessarily some anticipation ,
[ ,, I think that our position is going to be on this issue just ,
l 2o so the Board is aware of it that given the present flux l
! 2, f the situation that it is simply not going to be possible n .for close the record on the issue this week.
23 We have the question of identification of the 24 tubes to me. The testimony demonstrates amply that there as are-still a number of matters that are up in the air regarding this proposed modification.
end 12 '
l
_ _ . _ . - _ - - _ _ _ ~ .
u 1., ya 1 6055
() 1 Q
BY MR. . THOMAS:
Mr. Timmons, when the recommendation of the f 2
3 m dification reaches its final form, is there any particular 4
type of document which you can identify to us that will be :
5 used to transmit that to Commonwealth Edison?
6 A (Witness Timmons) The final form of the y recommendation to expand approximately 100 tubes and then ,
- l. 8. bypass 10 percent of the feedwater, the definition of the g specific tubes that might be expanded and the exact number i 10 is an engineering design detail within that.
- - Q How will the engineering design detail be 11 l
12 transmitted?
~
, 13 A I w uld assume it would be through the field 14 modification procedures that are transmitted to Commonwealth 15 Edison for review prior to the implementation of the 16 modification.
{
L 17 Q Do you contemplate any other written communications 4
-18 between Westinghouse and Edison regarding the proposed l
i 19 modification other than the letter that we have just 20 . discussed?
21 A I am sure that over the next several months there l 22 will be numerous written communications transmitted back l
23 and forth between Westinghouse and Commonwealth Edison 24 regarding details of preparation for the modification 25 design details, design evaluations, reports that present O
l
6056
/% '
(,sl l results of evaluations, engineerina details, and reviews.
2 O What if those reports result in an alteration of 3 the recommendation? That is certainly a possibility, isn't 4 it?
1 5 A It is a possibility. But at this point in time 6 we have done a significant amount of testing both in the 7- model and reviewed a lot of data from operating plants.
8 Based on those evaluations, we made that recommendation, 9 Testing that is ongoing, yet to be completed, is confirmatory 10 from the standpoint of quantifying the exact amount of 11 benefit, being able to identify specific individual tubes 12 that might or might not need to be expanded, thinas of that 13 nature.
f-~s
14 But if this additional testing does result in a Q
15 modification, how would Westinghouse notify Edison of that?
16 A Probably by letter and by some sort of a meetina, 17 an oral presentation.
18 Q Mr. Butterfield, has Commonwealth Edison made l
19 any formal notification to the NRC of the proposed modifica-20 tion of Byron?
21 A I believe there is a (Witness Butterfield) 22 letter in the record committing Commonwealth Edison to l 23- installing the modification prior to startup.
24
( MR. GALLO: There is also Mr. Butterfield's l 25 testimony.
I-l l
O l
I I
b 13 pv 3 6057
() 1 JUDGE SMITH: We have also counsel's acknowledoment.
2 that the testimony is in the form of a commitment to die NRC.
3 That happened yesterday.
4 MR. THOMA'S: Okay.
5 JUDGE SMITH: Are you concerned in the fact of a 6 commitment or the details of a commitment?
7 MR. THOMAS: I am concerned more with the process, 8 not with the fact. I am not questioning the fact. I am 9 concerned with the process.
10 BY MR. THOMAS:
ll Q A letter you were referring to, Mr. Butterfield, 12 in your testimony is the April 12, 1983, letter from
, 13 Mr. Tramm to Mr. Denton. I have a copy if --
14 A (Witness Butterfield) May I see a copy?
i l
'15 Q Do y ou know the one I am referring to?
16 MR. GALLO: Yes.
17 (Document handed to witness.)
l 18 (Pause.)
19 WITNESS BUTTERFIELD: Yes, that is the letter 1
20 I was referring to.
21 BY MR. THOMAS:
22 Q Mr. Timmons, when do you anticipate conclusion 23 of the test program?
24 A (Witness Timmons) We currently have a design 25 review for the Westinghouse schedule May 12 and 13. We O
V l
- . .. c. .
. 6058
() l expect those portions of the test program necessary to 2 verify the design and to allow Westinahouse to make a final 3 determination of the efficacy of the fix would be completed 4 at that time. I expect that there will be additional testing 5 at certain plants after modifications are installed. So 6 there might be some ongoing testing beyond that?
7 Q Would Byron be one of those plants?
0 A Insofar as Byron would conduct eddy current 9 testing to verify that the tubes were not wearina, I would 10 expect that would constitute part of the test program.
11 Q What did you mean when you talked about additional 12 testing at various plants?
13 A I believe Westinghouse intends to install
/
3..)/
% 14 accelerometers in the first plant in order to confirm that 15 the vibrations seen in that plant are representative of 16 those seen in the test models in Krsko so as to confirm 17 that for the D4 that the modification is the same as -- has 18 the same results as the test model.
19 Q Won't Byron be the first D4,at least in this 20 country?
21 A I think at this time it appears another plant 22 would be first.
23 Q What plant is that?
24- A Commanche Peak Unit 1.
25 Q Are you doing the same thing at Commanche Peak bO e
f e
e a
.. c 6059
' <~
, d 1 as at Byron?
2 A We have made the same recommendation to them as 3- Byron.
4 0 The 90/10 split?
5 A That's correct.
6 Q And the 100 tubes more or less?
'7 A That is correct.
8 By what date do you anticipate that the results O
9 of the Westinghouse test program will be communicated to 10 Commonwealth Edison?
11 A We have already communicated some of the test 12 results to Commonwealth Edison through the slides.
13 I am referring to -- you indicated May 13, I Q
14 think, or May 12 or 13, for completion of the testing 15 program. When do you think the results of that would be 16 commjnicated to Edison?
17' .A Our current schedule indicates we would have the 18 -- a report summarizing the vibration testing available for l
19 Commonwealth Edison and for the NRC sometime around the 20 t*beginning of June.
21 Q Mr. Butterfield, to vour knowledce, will the l
2
! NRC have to do an SER sign-off on this after you receive 23 the results from Westinghouse?
24 A As I understand it -- and (Witness Butterfield) 25 I have not read the Byron SERs as they exist today, but this O
o 13 pv O' 6060 1 is an open issue - the NRC will have to sign off on that ,
! 2 OPen issue. Whether they issue a-separate SER or not, I i
- 3 am not clear.
4 0 At any rate, the sign-off would have to take 5 place after this report was received from Westinghouse, I
6 obviously. Right?
end 13 7 A That is correct. ,
! i 8
4 2
- 10 1
11 l 12 i 13 l
14
! 15 l
16 r 17 18 19 20 21 22 23 24 25 l
r
. _ ~ , . _
14-1 6061 i . .
. e- 0 Mr.'Timmons, with regard to completion of the
\_,/ E testing program, you indicate in your testimony I believe 4 3 on- page 15 and 16 that Westinghouse was planning to remove 4
one tube'at Krsko after 4500 hours0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br /> of operation. Is that s
correct?
e i A (Witness Timmons) That was not my intent and I 7
, do not.see those words in my testimony.
a Q. You recommended that the operating interval at 9
70/30 at Krsko be increased.to approximately 4500-hours, io i right?
- - A Westinghouse did make that recommendation to the t i2 utility.
i O 13-14 0 And when was that recommendation made?
A Last November.
15 Q Has that 4500 hours0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br /> expired yet?
I is -
A Not it has not.
17 l Q Do you know when it will?
i 18 A I believe they are currently scheduled to shut
- ia down sometime in June of July.
l 20 Of this year?
O 21
, A Of this year.
22
- Q And what are Westinghouse's plans with regard 23 to the expanded tuce at that time, at the time that it shuts A -
24 downt 25 A I have not seen any nians to do anything with 1
e, - - - . . . ,- . - - , ,_..----.,_-,m - - - - - -- _ _ _ _ _ _ -_ _ _ _ --
14-2 6062
, that tube at this time.
r- -
k ,x) a Q As the Manger of this task force, do you have any 3 intention of examining that tube to see what the effect has 4 been of the 4500 hours0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br /> of operation?
s A I don't manage the entire task force, for one thing.
4 e' I am'the Manager of Licensing.
7 O I am sorry. I don't mean to expand or reduce your e authority.
, A That would be a significant expansion.
,o Q Let me ask you this guestion. Don't you feel that i, examination of that expanded tube af ter 4500 hours0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br /> of operation 12 would be prudent in the sense of providing additional informa-
/~} ,3 tion on the results of the 70/30 split at Krsko?
34 A I think that Westinghouse would have to make an is engineering evaluation of whether or not it would be the is best thing to do to remove that tubing and to look at it i~
17 outside the steam generator.
ia Our present plans include the expansion of about
,, 100 tubes at Krsko during that outage and so we will be 2o expanding other tubes in the steam generator and it might 2i be to our advantage to leave that tube as is and leave the 3 acceleromete s in it and see what effect expansion of all 23 of the other tubes around that oz.e might have on the vibrations
- 2, .that that particular tube sees.
\ Q Does Westinghouse at least plan to examine the tube 25
.1
14-3 6063 I in place at-Krsko.while the plant is shut ~down? .
_x
,) a- A I know of no such plans at this time that would 3 entail removal of the plugs from the tube in order to do 4 the eddy current testing to examine it in that fashion, and 51 since'that is a radioactive plant, we have tc'take into e consideration the radiation dose that would be received by 7 those people who would be in the steam generator to remove e- those plugs.
9 Q Do you have an opinion as to what should be done io with regard to that tube, if anything, while the K:sko plant si is shut down?
12 A At the present time, I think if I were to make is the choice, I-would leave that tube as is, leave it in the 14 steam generator with the accelerometers installed.
f i
15 Q Would you do eddy current testing on it?
16 A No, I would not. I don't personally think it is 17 Worth the additional radiut_on exposure to personnel that is would be entailed by removing the plug and doing eddy 19 Current inspection.
l- '2o Q So you would not do anything with regard to that 2 tuce?
22 A At this time.
23 Q Does Westinghouse have any plans at the present 24 time to verify empirically the scale model tests?
l 25 A Which scale model test? We feel we have already
f 4- 6064 1
empirically verified the-scale model tests by comparing
_(.
's ,[ a the test results with those seen from tubes instrumented 3' in the field at Krsko, the levels of vibration and the 4 frequency content of the vibration that has been seen from
-5 accelerometer data from Krsko. It is matched very closely e .lyr the same type of data taken in the 16 degree model..
7 Q Is the. single tube at Krsko the extent of the o empirically verification that Westinghouse is going to seek 9 for the scale model tests?
io A The empirically verification includes not only si theone. tube that has been expanded but the other tunes that 12 have been instrumented at Krsko. Over a period of the-last
~
[N 13 14 or 15 months, we have instrumented 12 tubes at Krsko at G
I4 various periods of time, and-I think the data from those 15 12 tubes comparing it to similar tube locations in the 16 i-is degree model correlates exceptionally well and shows that j 17 the 16 cegree-model exhibits vibration behavior which is i
4 is very similar to that which was exhibited by the tubes in 1
19 the Krsko plant.
2o Q Does Westinghouse plan to use the Byron modification 2i to try to secure addional empirical verification for what 22 you believe our scale model tests show?
23 A I believe I mentioned yesterday that it was my '
7-~ 24 opinion that it was not necessary to install accelerometers ,
, 25 in tubest at Byron. At the present time it is the F
[--
14-5 6065 1 Westinghouse position that we would only strument the first a plant in order to confirm that type of information, and 3 Byron is not the first plant.
4 O So that would be Commanche Peak?
s A At this time, yes. In addition, since we are doing e the modification at Krsko we will have the benefit of data 7 from Krsko probably earlier than we will have' data from a U. S. plants.
9 Q When is Commanche Peak scheduled to begin operation?
io A .I believe their scheduled fuel load date is at 11 the end of August.
12 O With regara to the experience at Krsko, how much is of the latest 4500 hour0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br /> oprating interval at Krsko was done i4 on a 90/10 split?
is A I don't have an exact number. I would expect te some place on theorder of 10 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, long enough to i7 take accelerometer readings at those types of splits.
ta Q How many tubes have been expanded at Commanche is Peak?
2o A At the present time none.
2: O liow many does i;estinghouse anticipate will be 22 expanded?
23 MR. GALLO: ?sked and answered. he has already 24 inquired as to whether or not the fix at Commanche-Peak is 25 'the same as the one or rather or not whether the recommendation
14-6 6066 1 by Westinghouse is the same as that for Byron. He already
(~
Jy_,/ 2 say the answer is yes.
3 JUDGE SMITH. In fact, you yourself said 90/10 4 split.
- t. MR. THOMAS: Okay, all right. I have no problems a with that.
4 7 BY MR. THOMAS:
e Q How many accelerometers, how many tubes at
' ~
s Commanche Peak does Westinghouse plan to install accelerometers to in?
si A (Witness Timmons) I believe the recommendation is 12 tnat four tubes would be instrumented with accelerometers.
/m 33 Q And these four tubes would be plugged, right?
% ))
14 A That is correct.
15 Q Mr..Timmons, in your testimony at Page 11 you is indicate that in December 1981 two tubes were removed from 17 a6d tube instrumentation was installed in the preheater region la of a D-3 at Almarez 1, and upon resumption of operations is in January 1981 vibration data was obtained at various power 2o levels. What power levels formed the basis for the vibration ai data that was obtained?
22 MR. GALLO: Objection. Asked and answered.
23 Mr. Savage went through this whole sequence in excruciating gg 24 detail yesterday and this morning.
25 WITNESS TIMMONS: It says January 1. It should
14-7 6067 i be 1982.
't s_j 2 BY MR. THOMAS:
3 0- So the tubes were removed in December of '81 and 4 resumed in January of '82 obviously.
I s JUDGE SMITH: Is there an objection pending?
e MR. GALLO: Yes. I objected that tne question 7 regarding the results of the instrumentation at these various s- plants was carefully and rigorously questioned by Mr. Savage.
s Mr. Thomas himself when he entered the arena to begin- the to cross-examination of this panel said he was not going to si repeat that cross-examination.
12 MR. SAVAGE: Your Honor, I believe by the time (s s) i3 we got to January 1982 that Mr. Timmons had told me that
> 14 he was more concerned with the data from the Krsko plant is because it was a D-4 steam generator and not as concerned is about the. data at the McGuire and Almarez plant or Ringhals.
i7 So I stopped asking about the data from those plants about to January 1982.
is That has not been asked and answered is what I 2o am saying.
21 JUDGE SMITH: That comports with at least the 22 memories of two of the Board members.
23 The objection is overruled.
-~g 24 WITNESS TIMMONS: What was the question again?
25
. _ _ _ _ _ _..m. _. . . __ _
14-8 6068 t
1 BY MR. THOMAS: l 2 Q .The question was what power levels was the vibration 3 data obtained from?
4 A (Witness Timr. Jns) In the data taking that occurred s in the plants that had instrumentation, the normal procedure e- was to take the data in 10 percent power increments starting 7 at a low power level and extending to 100 percent power. ;
e Q Do you know whether this was done in Almarez or o are you just answering on the basis of procedure?
Io A It was done at 30 percent, 40 percent, 50 percent, si 60 percent, 70 percent up through 100.
in Q With respect to the 50 percent. power level, was is sufficient tube vibration obtained to plot a curve showing i4 the level of vibation from month to month over a 48-month is steam generator operating period?
16 MR. GALLO: Obection. First of all, is the o question limited to Almarez, or are we calking Krsko and is McGuire?
is MR. THOMAS: No. The question is limited to 2o Almarez. The previous question was talking about ---
2i MR. GALLO: The basis for my objection, Your Honor, 22 is that again we are inquiring into details of information 23 gathered with respect to the D-3 steam generators and it 24 is simply not material in my opinion with respect to the 7%
U 25 ultimate D-4/D-5 fix.
14-9 6069 1 (Board conferring.)
/^%
'\s,) a MR. THOMAS: Judge, we have already argued this, i
3 JUDGE SMITH: You made a similar objetion before-4 which we overruled. Now is your objection this time on a s somewhat different basis?'
e MR. GALLO: The prior objection was asked and 7 answered. This one is on the basis of materiality, a JUDGE SMITH: No, the objection with respect to e the D-2/D-3----
4 10 MR. GALLO: I must confess that I cannot recall 11 that far back as to whether I made that objection or not.
i MR. THOMAS: This morning.
12
/\ is JUDGE SMITH: I don't recall the basis of our U
14 ruling either.
1 itt JUDGE COLE: I thought we ruled that there was se a sufficient relationship between the D-2, D-3, D-4 and 4
i 17 D-5 that we overruled your objection, that the vibration to problem was initially found in the D-2/D-3 and that was 19 at least partly responsible for the evolution of the 20 D-4/D-5 as I understand it.
2 MR. THOMAS: That was the ruling.
l 22 MR. GALLO: That is interesting, but it seems r
23 to me that we have a new question and we need a new ruling.
l 24 JUDGE SMITH. Okay, that was the basis. Is there
\'
25 a different basis of objection other than the issue we have h
14-10 6070 i before us this morning?
(
s a MR. GALLO: I don't remember the exact question a this morning. The baslance of the participants' memory 4 is better than mine. All I know how is that the question s involves some sort of range of data that is to be depicted e on a graph and the question is does that graph exist and 7 what does"the data'show, and it is in the context of a '
s D-3 steam generator and I don't see that it has any probative 4
9 value. I am objecting that it is immaterial.
to JUDGE SMITH: Overruled.
11 MR. GOLDBERG: I guess I anticipated the ruling,
'a but let me just say that I think at some point the relationship is between D-2, D-3 and D-4 and D-5 -- insofar as the prevalence
[)\
14 of the tube vibration problem, then the corrective modification 1
is does become more tenuous.
is This witness has testified that the vibration i'7 problem is more pronounced in the D-2/D-3 than D-4/D-5, is which corroborates earlier testimony by Dr. Rajan and also is the nature of the modification involved in the D-4/D-5 20 relative to the D-2/D-3 as also distinguishable. I don't l
2i know if we crossed the threshold of relevance, but I would l
22 say that a great deal of time spent on the D-2/D-3 configuration
- end 23 and modification probably is not going to be all that 14 24 productive.
25 i
I l - . _ _ . _
6071
() 1 JUDGE SMITH: I think we will spend more time 2 discussing it than we will developing he information.
3 You may continue, or you may answer. I don't 4 even know where we are.
5 Are you waiting for the answer?
6 MR. THOMAS: There is a pending question. Do 7 you want me to repeat the question?
8 WITNESS TIMMONS: Yes, please.
9 BY MR. THOMAS:
10 0 With respect to the 50 percent power level, was 11 there sufficient data obtained, tube vibration data 12 obtained, to plot a curve showing the level of vibration 13 from month to month over a 48-month operating period?
[,, ]
%_/ 14~ A (Witness Timmons) As is obvious from the fact 15 that it is only a year later, there is no data that extends 16 out to 48 months. However --
17 0 To plot a curve over such a period. I realize 18 it has not been 4 years since 1981. The question was, was f
i 19 there sufficient data obtained to project and plot a curve?
20 A Daring the operating interval from January of 21 '81 until the next shutdown for eddy current testing, 22 vibration readings were taken at intervals of approximately 23 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> during the 1,500-hour operation. That is, at 24 initially after a few hours of operation at 500, at 1,000, 25 and again just before they shut down for eddy current O
O
b 15 pv 2 6072
( ,) i testing. And that was done again during the next operating 2 period. And those vibration data were compared and evaluated, 3 'and the evaluation results indicated that the vibration 4 readings for the tubes of interest that were instrumented 5 for a given tube location did not change significantly over 4
6 Periods of time.
7 So one would expect that the vibration levels 8 would stay the same, the frequency content would stay the 9 same, for those tubes, given the fact that the conditions 10 in the steam generator relative to the given flow conditions 11 and whether or not a modification was in place did not 12 change.
i 13 0 What was the flow split at Almarez at these 14 test points, these 10 percent incremental points?
15 A During that period of operation, all of the flow 16 was through the main nozzle. They operated at essentially 17 50/0. -During most of the time period they did testing at 18 60/0 up through 100/0.
i 19 (Counsel referring.)
l 20 0 Mr. Timmons, yesterday you were shown a January 21 1982 letter to Nilliam Parker from Robert Tedesco. Do you 22 remember that letter?
23 A (Nitness Timmons) Yes, I do.
24 0 One paragraph in that letter -- I don't have a
! 25 copy in front of me right now, so I cannot say which -- but 7 1 l
i I
_m. , .., , ___ , _ , _ _ ,
^~
u as uw a 6073
( ,) 1 it refers to the first leak developed at Ringhals only after 2 operating in excess of ten times the operating time at 3 power accumulated to date at Maguire.
4 Do you see the paragraph that contains that 5 language?
6 MR. GALLO: Does the witriess have the letter?
7 WITNESS TIMMONS: Yes, I have the letter that 8 you gave me yesterday.
9 MR. GALLO: I am going to object to further 10 questioning from that. That letter was explored by 11 Mr. Savage, and I can anticipate the response. Mr. Savage 12 didn't ask this particular question. And I guess we can 13 go on forever all afternoon what that kind of repartee,
[_s ' '
\/ 14 and I think the opportunity to cross-examine on this letter 15 presented itself. New counsel comes to the table and now 16 has a new thought. It should be cut off. One lawyer 17 conducts the cross-examination.
18 JUDGE SMITH: I agree with your basic point.
19 There is more involved than just not covering the exact i 20 questions of Mr. Savage, but you should not cover the 21 general subject area.
22 MR. SAVAGE: The general subject area, when I 23 used the letter for cross-examination, Your Honor, was about 24 the instrumentation that would be used to gather data 25 about pipe vibration; in particular, whether something
('M
0 1.) pv 4 6074 f'")x
%_ 1 called a noise transducer was different from something 2 called an accelerometer. It was a very limited purpose, 3 and that was the only issue at that point. I never intended 4 in my cross-examination plan to raise the issue that 5 Mr. Thomas is raising.
6 JUDGE SMITH: What issue is Mr. Thomas raising?
7 MR. THOMAS: The guestion that I have is whether 8 during the last half of 1982 the .'taquire steam generators 9 accumulated enough operating time to bring the total 10 Operating time at Maguire to a level equal to the number 11 of hours accumulated at Ringhals when the leak occurred.
12 That is the question I was trying to ask. I had not even 13 gotten to it yet.
(")
l
(_ / 14 JUDGE SMITH: Okay.
15 MF. THOMAS: It is a different -- it is the 16 same document but a d'ifferent question.
17 JUDGE SMITH: So does your objection persist?
18 MR. GALLO: Yes. I would add, I don't understand 19 how this comparison that counsel is achieving to elicit iD 20 is relevant to the proceeding. I believe --
! 21 JUDGE SMITH: That's different. That's a l 22 different objection.
l 23 MR. GALLO: It is an additional objection.
24 Mr. Goldberg has pointed out that as we proceed with 25 questions-involving D2, D3 data, we get further and further
(s 1
l
'w]
b la pv 5 6075
() 1 away from the issue.
2 JUDGE SMITH: The Board recognizes that there is 3 a point where the D2, D3 information will not be helpful.
4 MR. GALLO: In my judgment, Your Honor, we nave 5 reached it.
6 JUDGE SMITH: And we understand that. You have 7 not failed to communicate your judgment.
8 (Laughter.)
9 JUDGE SMITH: We think you should bring to a 10 prompt conclusion your inquiry into the D2, D3 issue.
11 MR. THOMAS: I agree with that. I am really 12 more interested in getting to more questions on the 13 modifications at Byron, j
(i
\/ 14 BY MR. THOMAS:
l 15 Q Mr. Timmons, the question is, haveyou found 16 the portion of the letter that I was referring to?
17 A (Witness Timmons) Are you referring to the 18 paragraph that begins on the top of the page that has a 19 number 4 on it?
20 Q Yes.
l 21 A What was your question?
l l
22 Q The question, based really on the last sentence 23 in that paragraph, is: During the last half of 1982 did 24 the Maguire steam generators acamulate enough operating time 1
25 to bring the total operating time at Maguire through fi 0
- m. _
b 15 pv 6 6076
, 1 December of '82 to a level. equal to the number of hours 2 accumulated at Ringhals when the leak occurred?
3 A (Witness Timmons) I think the total operating 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at Maguire are probably far in exec >ss of the 3,000 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> total operating time that Ringhals had. However --
6 Q When the leak occurred?
7 A When the leak occurred. However, the Maguire 8 plant has operated for a very few hours above 50 percent 9 power. They operated for about 1,400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> at 75 percent 10 power, maybe 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> at 90 percent, and maybe 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 11 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> at 100 percent. So they have very few hours at 12 the higher power level.
- 13 Q Just a moment, please.
\~/ 14 (Counsel conferring.)
15 (Pause.)
16 Q With regard to Krsko and the expanded tube, has 17 Krsko steam generator which expanded tube operated for any 18 period of time with a 90/10 split during this latest 19 4,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of operating experience?
20 A I bblieve they have operated at various flow 21 combinations in order to take accelerometer data.
l 22 Q That's right. I think you said 10 or 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, 23 somewhere in that range.
24 A You have to understand that 90/10 at Krsko is i 25 really almost equivalent to 100/0 at Byron because of the
\ O l U
b 15 pv 7 6077 q_) 1 difference in flows.
2 Q Right.
3 A The equivalent would be around 80 or 85 percent.
4 Q Has a visual examination been conducted on the 5 expanded tube at Krsko?
6 A I believe I earlier responded to that question 7 by saying that, no, there had not been a visual examination 8 of the expanded tube after operation. The tube in the 9 steam generator has not been removed.
10 Q Returning to your testimony at page 16, this 11 is on the latest as revised 4/25/83, and some questions 12 regarding the scale model testing program. At page 17 you (3
13 indicate that the .417 scale model consisted of the full
'w l 14 preheater region and contains a full complement of tubes.
15 Dc you see where I am referring?
16 A Yes, Ido.
17 0 Does this mean that the model contained every 18 single tube in the preheater region?
19 A Yes, it did. That model represented the entire 20 preheater region with every tube represented.
21 Q Were there any baffle olates used in these tests?
22 A Every baffle plate was represented. The 23 impingement plate was represented, and the wrapper for 24 the steam generator was represented.
25 Q Does this mean that all flow across all tubes ]
- m 1
i
b 15 pv 0 6078
( )- 1 in both directions was modeled?
2 A That is correct.
3 Q Did this model or.ly include the section of 4 tubing within the preheat area and then at the top of the 5 preheater region?
6 A Yes, it did.
7 0 You then indicate the tube vibration data was 8 the main output from this model by using instrumented tubes.
9 How many tubes, and which tubes were instrumented?
10 A I don't have those details with me. I believe 11 that roughly someplace between 50 to 75 percent of the 12 tubes in the front row and then a decreasing number of 13 tubes in subsequent rows going back into the tube bundle
\~ ') 14 were instrumented. There was a significant number of tubes l
15' that were instrumented.
16 0 Was the decision on which tubes to instrument, 17 was that strictly an engineering consideration, or were 18 some tubes instrumented to provide a comparison to 19 instrumented tubes in operating D2, D3 plants?
1 20 A The tubes that were instrumented in this model 21 included tube locations where there was instrumentation 22 in operating plants and' also other tubes, so as to 23 be able to get a complete picture of the vibration i
24 characteristics of other tubes in the bundle that were 25 not instrumented, to get.a more complete picture of what bi V
l l
[
u a yv s 6079
['T V 1 was going on.
2 Q So your answer is that some of the tubes were 3 instrumented to provide a comparison with operating plants.
4 Is that what you are saying?
5 A That is correct.
6 0 Which plants do you plan to compare, or which 7 plants were used for comparison purposes?
8 A All of the ones that had instrumentation.
9 Q And the tubes in the operating plants which 10 were being used for comparison, were they in the same 11 locations as in the model?
12 A Do you mean the fact that the tubes in the 13 same geometrical location within the tube bundle? Yes, V 14 they were.
15 0 Yes, that is the question.
16 Were the feedwater flow configurations and the I
17 simulated power levels in the model identical to those 18 being used in the D2,D3 operating plants?
19 A The data was taken in the test model, but at 20 flows that were equivalent to flow levels seen in the plants 21 plus data was also taken at an overflow condition of 22 approximately, I think it was, 110 or 112 percent of nominal 23 flow for the highest flow steam generator.
24 0 What is the level of accuracy of the strain 25 gauges?
. . -. -- --- . = = - - -_ _ . . __. ..- ..- __
o la pv Au t
1 A I don't have an exact number. I would expect
.end 15 2 it would be plus or minus 20 percent , - something like that.
l 3 4
i i 5 1
6 l 7 t
8 9
1 10-11 12 13 s 14 l
15 i
i 16
! 17 e
4
! 18 i
2 19 i
20 l
21 I
- 22
. 23
- 24 25 3
e i
4 1
- , - -,-,-,,nn-r,,.,-,-,--, -,-,_-n--,,,- n.,-,.n..-.n---nc,,-- - . -- - . - --,,- -
6081 16-1 i
~
JUDGE COLE: Plus~or minus 20 percent of what, of whatever they measure?
3 WITNESS TIMMONS: Yes.
4 BY MR THOMAS:
5 Q 'Is that the same type of instrument that-is used 6
in the operating plants?
7 A (Witness Timmons) Not it is not.
8 Q How do tLey compare?
9 A The operating plan is piezoelectro cystyal that to detects acceleration in the tube. The strain gauge is it is strained in the tube and that was relating to the displace-12-ment in,the tube through testing and standards-that we
% used, and that was used to correlate.
14 Q Does the~different type of instrumentation present 15 some problems in correlating the two sets of-data?
16-A It presents some small amount of difficulty, 17 but'since the people who set up the model and correlated 18 the displacement in the strains with the levels of 19 displacement, they were able to_ compare quite favorably 20 with the frequency content that was observed in the plants, 21 the locations and frequencies of the peaks of vibration 22 and through that method were able to make the correlations.
23
'O Why don't you use the same type of instrumentation 24 O
in the model that is used in the operating plants?
25
16-2 6082
! t A For that particular model, because of the time
--) .
\s / a constraint and the size of the model, we chose to use 3
different instrumentation. Eventually we had put into place 4
the full scale model in Sweden that utilized accelerometers s
that-were similar to the ones that were.used in operating e
plants, and that was a full sized model.
7 0 You then indicate that additionally some flow a
velocity data was obtained in areas of interest. Where was 9
the data obtained, what areas?
so A In the inlet plenum in the depth between the tubes 11 J
in the first several rows of tubes.
12 Q The inlet and the first several rows of tubes?
) A The inlet plenum and the depth between the tubes 14 in the first several rows, is 4
Q In the next paragraph you state that the two-thirds 16 scale model included all components from the feedwater nozzle i
17 1
to the exit of the first path and the tubes were present i
18 with instrumentation within the first'five rows nearest 19 8
to the nozzle. In the deisgn of the test model how many 20 i
tubes were instrumented in the first five rows?
21 A Approximately every fourth of fifth tube.
22 Q Were any of these tubes expanded?
23 A No. This model was to represent the D-2/D-3 24
- (
configuration. The modification that was proposed and 25 has been imolemonrad in *hnen ,1_mn*e
- , - --- _s _e _e _4 , . 4 < 4 . .m. .m...,
. -- .i..
4 s
, -e. y-- , - , - - . - - - - ,
. 6083 16-3 i different.
O
. k,j) . a Q Again, was the decision to instrument certain tubes-3 to allow comparison with operating plants, or was it strictly 4 an. engineering decision?
s A I think it was strictly an engineering decision e to get a represnetative sample of data.
7 0 Were you able to determine a critical threshold a water velocity at which tube vibration begins from these j s tests related to the two-thirds scale model?
to A No, we weren't because the tubes were short
.it tubes and were essentially supported at the baffles on either
! 12 side of the inlet paths. It was a single path model.
/~5 -13 Q Were you able to determine if the critical l
U
! 14. threshold water velocity at.which tube vibration reaches is the point where the tube wear becomes unacceptable from
- is this model?
! 17 A This model merely measured the velocities that
- te resulted from the inlet flow configuration.
39 Q So your answer to that question would be no?
2o A No. The answer to the question is that we did not 2i measure a critical velocity.
22 O You also said that the model permitted the 23 measurement of steady state and also latent flow induced 24 drag forces on these tubes. Were you able to correlate O as drag forces on the tubes to the vibration level of the tubes
6084 16-4 i from these tests?
b
\ ,j a- A Yes, we were.
3 0 .Were you able to deduce from these drag force tests 4 and the water velocity tests whether vibration was strictly s a function of the cross-flow water force regardless of the
, s. water density and the velicity or whether various combinations t-7 of velocity and density could produce various Vibration levels 1
a at a constant water force?
, MR. GALLO: Objection.
- io JUDGE SMITH
- I was afraid of that.
is MR. GALLO: The question sounds. compound to-12 me. It has lots of phrases and qualifiers.
' 'l i3 JUDGE StiITH: There were alternatives, and it d
r4 could be objected to on the basis that they don't provide j .is all of the possible alternatives.
ie MR. GALLO: I franly lost track of the question.
r 17 JUDGE SMITH: Yes, that is the big problem.
Is MR. THOMAS: Let me try and make the question l
l i, simpler.
2o BY MR. THOMAS: ,
2 O Were you able to deduce from these tests whether 22 . vibration was strictly a function of the~ cross-flow water 1
( .23 force regardless of water density and velocity?
j ,~ 24 A For the split flgw program Westinghouse based l
I u 2s on the data available, in particular the data from the i
6085 16-5 4
i two-thirds scale model, was able to correlate the level of
(_f a oscillating drag forces indicative of the turbulence in that 3 region to the vibration on the wear and was able to come 4 up with methods of relating the amount of turbulence measured s by the oscillating drag forces to the vibration levels that 6 were seen in the tubes. __
7 Q So in response to the question did you determine
-s that it was a function of the cross = flow water force? Is 9 that what you are telling me?
10 A It was a function of the amount of turbulence.
11 G Then the question was, was the turbulence then
- 12 a runction of the cross-flow water force?
A Yes, it was.
!.%/h is 14 Q Was it a function of that alone, or were there
{
15 other variables which affected the turbulence or other factors is which affected the turbulence?
17 A I don't recall all of the factors that. developed is in the correlation applying a turbulent forcing function 19 'resulting from the oscillating drag forces on the tubes 2o to the flow induced vibration model. The analystical model I 2: that we used gave tube motions and tube vibrations that L 22 were entirely representative of the motions and vibrations l
l 23 that were seen from accelerometers installed in operating L
l 24 plants.
%.J 25 A '(Witness Fletcher) Mr. Thomas, may I add something i
l i
I I -. -.
6086 16-6
, 1- to that?
-~
2 O Yes.
3 A Tube motion is derived from the three. principle 4 mechanisms. One is a fluid elastic behavior as the fluid s moves past the tube, another is turbulence, and a third is e vortex shedding.
[ 7 Now the work that has been done has deteruined 1 e that the tubes are being moved by a xomplex mixture of both e turbulence and fluid elastic excitaticn. To ask a question, io is the motion due strictly to turbulence? That is an is oversimplification. There are elements.of turbulence present',
12 but there are also elements of fluid elastic instability.
/N 33 The models that have been developed incorporate V
4 these features or these principle modes of excitation of is the tube. The models that have been developed by ,
16 Westinghouse, derived and calibrated by the scale model 17 data that we have, plus the geometries involved include ,
. is the density factors along with the fluid velocity. All of is that is incorporated into the models that Westinghouse has 2o used and established as a predictive tool to determine tube 21 motion in these particular geometries.
22 Q Did the oscillating flow induced drag forces produce 23 more vibration than the steady state forces?
-- 24 A (Witness Timmons) Steady state drag forces would
( 's '
25 tend to push the tube up against the support. That is 1
I
, - - - , - - - . - ,y -
,. - ,.7
6087 16-7 i oscillating force that moves the tube once it is held sort A
( ,) 2 of in place by the steady state drag forces of the fluid.
3 0 What causes the oscillation?
4 A The oscillating forces. Which oscillation are 5 you referring to?
e Q In your testimony you refer to oscillating flow 7 induced drag forces. That is the one I was referring to.
s A Those are caused primarily by the unsteadiness 9 of the flow field in the inlet plenum of the split closed to steam generator. It is due on large measure to the presence 11 of'the impingement plate and.the flow field that that i2 impingement plate creates. As the flow comes into the L
s'~N i3 inlet plenum and is deflected on into the plenum and thereby
-\
14 goes into the tube bundle through the inlet pass.
15 Q Now was any of this data referring to the two-thirds us scale model, was any of this data directly correlated to 17 any direct measurement of the drag forces on tubes in I
te operating D-2/D-3 plants?
f 19 A No. It has not been possible to measure those.
2o Q With regard to the full-scale model which you 23 describe in the next paragraph in these tests, how many 22 tubes are in this particular model?
23 A Every tube is represented in the model through i
-s 24 the first pass. inat is, there are 4,694 tubes on that, 25 an array of aoout 5 by 2S in the first fiVe rows on one i
16-8 i
i side are full length.
'O( ,j z Q How many tubes were instrumented, approximately?
3 A I don't know the exact number. Probably every 4 fourth or fifth tube back for three or four rows.
4 s Q And these were in the first three or four rows?
. A That is correct.
7 0 Were there any changes made in the baffle plate a locations from the two-thirds scale.model test we just talked
, about? In other worde, were the baffle plate locations the io same in both tne two-thirds scale model and the full-scale i, model?
,2 A The baffle plate locations in the two-thirds scale model were located at two-thirds of the distance of the
{"'
- s. s
,3 i4 prototypical distance that exists in the steam generator.
i is In the SSPB the height between the baffle plates was proto-is typical-heights. The tubes were full diameter tubes.
i7 Q Were any of the tubes in these tests expanded i is at baffle plate locations or support plate locations?
[ i, A None of the tubes in any of the testing on split f' 2o flow models were expanded.
i 21 0 ere the full-scale model tests done in real time?
22 Do you know what I mean by that?
23 A I am not quite sure.
l 24 0 Were the tests in the full scale model done in
\( >)
^ 2s real time so as to allow direct correlation of data to that l
l
6089 16-9 L 'i n operating plants?
.i
. i, ,n)- 2 A As far as I can tell, they were done in real time.
s We did not have a space warp or anything.
i 4 (Laughter.)
s Q That is one of the problems with model tests, e isn't it, the time factor?
7 A All of the data was taken with some sort of a time ;
a trace on the recorder. Therefore the frequency in the times
, between events and the amplitudes of the vibration and other so data were taken with the same types of time' traces that were si. available for the in plant instrumentation. I am not quite end 16 12 sure what you are getting at.
13
['}
s_-
l' I4 15 16 17 i
18 20
! 21 1.
22 23 m 24
\.'
25 I _ . . . , . . . . _ .__ . , - _ . _ , . . . - . . _ . . - . - -. -- - - - - - - - - - - - ~ - - ~ m---------'---- -
b 17 pv 1 6090 (7 ~)
v' 1 A (Witness Butterfield) In some cases,when you 2 are doing analytical modeling with codes and things, you 3 do put in a time factor. You may run the case faster than 4 real time, slower than real time.
5 I am not aware of any way to do this in an 6 experimental model. So I do not understand the question.
7 JUDGE COLE: I am confused, too. Correct me 8 if I am wrong. I thought the things that were mentioned 9 in the model were velocity patterns and profiles inside 10 and vibration levels on tubes. They were not measuring 11 tube wear, which i s, of course, they would have difficulty 12 in the model. But the kinds of things that they were 13 measuring here did not require the kind of time considera-d 14 tions that you are talking about.
15 BY MR. THOMAS:
16 Is that correct?
Q 17 A (Witness Timmons) Yes, that is correct.
18 JUDGE SMITH: Mr. Thomas, we will have to take
-19 our afternoon break in time to allow the emergency planning 20 discussion.
21 MR. THOMAS: I would indicate to the Board that
'22 I have few more questions on the scale model testing, and 23 then I would be moving to the Byron fix per se. So if we 24 could go until I complete the scale model testing.
25 JUDGE SMITH: -Incidentally, is there some O
t !
v
6091
(
's / 1 confusion about the cross-examination plan? I see you 2 working from what appears to be a rather elaborate cross-3 examination plan, but the one that I have from Mr. Savage 4 is simply inadequate for the cross-examination you are 5 doing.
6 MR. THOMAS: I am not familiar with that -- that 7 familiar with the plan that is in front of Your Honor.
8 These, of course, are specific questions as opposed to 9 a general plan. I don' t know exa ctly what else to say 10 about that.
11 JUDGE SMITH: I asked if you had a cross-12 examination plan, and you said you were following
-- 13 Mr. Savage's, and now you say you are not familiar with
' 14 it and you have another one before you. So it raises a 15 question.
1 16 MR. THOMAS: I have no problem with duplicating 17 these and giving you a copy of these.
18 JUDGE SMITH: Mr. Savage's cross-examination 19 plan is of no value whatever when iau are following your 20 cross-examination.
l 21 MR. THOMAS: I will duplicate these and in the l
22 future duplicate other questions that I plan to ask too.
23 JUDGE SMITH: All right. Continue.
24 MR. THOMAS: Okay.
25
,O t 1
%J
. - . - . . _ -. ~ .. - . . - - _ . _ ..
b117 pv 3 6092 n
1 BY MR. THOMAS:
~
2 Q Again, referring to the full-scale model test,
'3 you did' indicate that some of those tubes were instrumented, 4 .didn't you?
5 A (Witness Timmons) Yes. A fairly-large number-l 6 were.
7 Q But none of them w'ere expanded, you say?
8 A That's correct.
9 Q Were the tubes that were instrumented, were 10 they instrumented in the identical location to tubes 11 instrumented in operating plants?
12 A f Yes, they were.
'i. - 13 Q Are the accelerometers and strain gauges all I
[ sj 14 located at the same vertical location with respect to the 15 tube sheets?
16 A It varies from plant to plant, and it varies 17 from model to model. In general, attempts were made to 18 .have some of the accelerometers located in the center span
!- 19 in the inlet path and then at other locations where the 20 longest span might be available as to get to the largest '
l 21 amount of vibration.
22
[ In some other cases, there were some put 23 directly at the location of the baffle plates so as to 24 get indications of what the vibrations were directly at 25 the point where it appeared that there was contact G
v
b 17 pv 4 6093 1 between the tube and the baffle. They were generally in the 2 middle of the inlet path and at the middle of the longest 3 span.
4 0 What plants did these locations correspond to?
5 Which plants were you seeking to compare?
6 A I am having a little trouble with your question.
7 I do not remember all of the locations in every plant. I 8 do not remember corresponding locations that were instru-9 mented. Ir. generally, the tubes at the Ringhals 3 plant 10 were instrur, anted at the baffle locations, so the 11 instrumentation in the SSPB model would not directly 12 replicate the location. The frequency of the vibration
~
13 and things of that nature could be replicated for those.
(o
- 14 The amplitude of this placement might not be able to be 15 replicated because the tube was constrained within the 16 baffle plate hole.
17 For plants like Almarez , McGuii e ', the 18 accelerometers were in general located either in midspan 19 of the inlet or at another point midspan of a long span 20 length. And those are the types of measurements that 21 were made in the full-scale model.
22 Was the feedwater flow conficuration in the O
23 full-scale model identical -- strike that.
24 Were the feedwater flow configurations used 25 in the full-scale model correlated to those used in (D
V
b 17 pv 5 6094 1 r" k_ x 1 operating plants; for example, 50/0, 50/25, that type of 2 thing?
3 A For the full-scale model they replicated only 4 flow through the main feed nozzle and took measurements 5 at, I think it was, 110 percent, 100 percent, and 60 6 percent of nominal full flow for the highest flow steam 7 generator.
8 Q Not split flow?
9 A No split flow.
10 Q Then on page 18, the last paragraph, referring 11 to the .95 scale air model, did the flow distribution 12 patterns observed in the air model perfectly match those 13 in the 2/3rds scale water model?
f\/\. 14 A They did not perfectly match them. They were 15 very close. The velocities in the air model were higher 16 than the velocities in the water model.
17 JUDGE COLE: But the relative patterns?
18 WITNESS TIMMONS: The relative patterns were 19 very, very similar.
20 BY MR. THOMAS:
21 Q What is the purpose of using an air model if 22 you can use a 2/3rds scale water model to give you the 23 same information?
24 A The air model became available much earlier in 25 the program and the 2/3rds model was the same 2/3rds model
/~
f
o 1/ PV 6 6095
(~'N
(,,) i that was used in the split flow part of the program and did 2 not become available for modification for use in the 3 counterflow program until September of 1982.
4 Q Regarding these test models, were the test models 5 all run at cold conditions?
6 A Relatively cold conditions. I think the 7 temperature in the water model is 100 degrees, and the 8 temperature in the air model is ambient.
9 Q Is a correlation or correction factor then 10 required to obtain hot condition data?
11 A There is correlation that is used in setting up 12 the model so as to get conditions, support conditions that 13 would be representative of the support conditions seen in tO kl 14 the operating plant steam generators,and adjustments would 15 be made to the model to give you those support conditions 16 that give you the vibration characteristics seen from the 17 Krsko plant.
18 Q How much uncertainty does this introduce in the 19 correlation?
20 A I don't know the exact uncertainty associated l 21 with that.
i 22 O Can you give me a range?
g 23 A 10 percent, 20 percent.
l 24 Q Is there a threshold for cross-flow forces
! 25 at which fluid elastic excitation begins?
G U
o le pv <
6096
, O ksl 1 A There should be.
2 O Has that threshold been observed in any of the
. .3 2/3rds scale model tests?
4 A No, it hasn't. The 2/3rds scale model, as I 5 indicated, is a single pass model with the tubes being 6 short-length tubes that exist only between the inlet and 7 the baffle plates.
8 0 What about the full-scale model tests?
I 9 A The data I have seen from the full-scale model 10 tests, I don't think that we have observed in that model 11 any indication of fluid elastic vibration for the counter-12 flow program.
(s) s 13 Q Is there a threshold for turbulence at which i 14 fluid elastic excitation begins?
15 A. I don't know the answer to that question.
16 (Counsel conferring )
17 0 Is there a threshold for water density at which 18 fluid elastic excitation begins?
19 A I don't know the answer to that question.
20 Q Is there a threshold for mass at which fluid i
i 21 elastic excitation begins?
22 A I don't know the answer to that one either. I 23 am not quite sure where you are going.
t l 24 O And the last question is the same question for 25 velocity. Is there a threshold for velocity at which lO l
i l
?
b 17 pv 8 6097 O
( ,) i fluid elastic excitation begins?
2 A Normally there is, yes. As you increase the ,
3 velocities, there is a point at which you reach a critical 4 velocity and the fluid elastic excitation of the tube 5 begins, and the amplitude of the vibration increases rapidly 6 for small change in velocity.
7 0 And has that threshold been observed in the 8 full-scale model tests?
9 A No, it has not.
10 MR. THOMAS: Judge, I think that is about all 11 of the questions I have on this scale model test, if you 12 want to take the afternoon break at this point or deal es 13 with the emergency planning.
\~/ 14 (Board conferring.)
15 JUDGE COLE: Before we leave that point, I want 16 Mr. Timmons to describe to me the phenomenon of fluid 17 elastic excitation'. What is that?
18 WITNESS TIMMONS: Fluid elastic excitation is 19 a process whereby a tube --
20 JUDGE COLE: You are talking about the tube?
21 WITNESS TIMMONS: 'Yes.
22 JUDGE COLE: Go ahead.
23 WITNESS TIMMONS: The tube in a free stream of 24 fluid at a point where-you reach the critical velocity'and 25 go beyond that, tne tube begins to vibrate and extract b
v
b 17 pv 9 6098 N
x--) I energy from the free stream, and there is kind of a 2.
self-supporting vibration due to its extraction of energy 3
from the free stream.
4 JUDGE COLE: I -thought it was a property of 5
water with which I was not familiar.
6 MR. THOMAS: I do have one other question. It 7
is not related to what you asked, but it is on the scale 8
model tests.
9 BY MR. THOMAS:
10 Q On page 19 you discuss a. single tube vibration 11 model. Was this a test facility or an analytical model?
12 A (Witness Timmons) That particular model was a 13
(S test facility. It is a tube of requisite length with
\-) 14 representations of all of the baffle locations in support 15 conditions which had a device for vibrating the tube at 16 the appropriate excitation point, and then through 17 accelerometers we were able to ascertain the vibration 18 characteristics of the tube.
i O Is this used for wear rate' determination or 20 l just for tube vibration data?
l 21
- A Just for tube vibration data in comparing modes i
22 of vibration and things of that nature, to determine l
23 l positions of support to place relative positions of support I
24 l plates and alignments and things of that nature and their 1
' 25 effect on vibration.
O_-
i
.6099
/^ l (5) 1 Q Is this a facility that was used to determine 2 the degree of expansion of the tubes at the baffle plates?
3 A I believe we did early on expaid the tube and 4 look at the vibration characteristics of the expanded tube 5 in that facility.
6 MR. THOMAS: That is all I have at this point on 7 the scale models test.
8 JUDGE SMITH: We will return in 5 minutes until for 9 an emergency planning session, and the parties who are not 10 interested in that can return at 5 after to resume the 11 steam generator litigation.
12 (Brief recess.)
13 JUDGE SMITH: Are the parties interested in i
\_) 14 further elaboration on the qualifications of the persons 15 preparing and working on the survey?
16 MR. SAVAGE: I am, Your Honor. We begin with 17 Mr. Murphy.
18 You recall that although they disavowed much 19 by way of statistical training other than lower-level 20 course, we observed that he may be more modest than he 21 should be. In the course of his public health education, 22 he would nececsarily be exposed to statistical techniques.
23 And generally, we felt he was by training qualified to 24 prepare at least the factual summary, the factual survey 25 that we are accepting into evidence.
t v
._ . _~ __
b'17 PV 11 6100
'1 But the question does not turn on Mr. Murphy's 2 expertise, because we can read the questions, too, and we 3 can determine whether they are inclined to invite bias..
4 As to Mr. Holmbeck, he is a person who sent out 5 the surveys and questionnaires and gathered them. Cer-6 tainly a survey involved in litigation and party to the 7
litigation should not participate in a surve.y process.
8 We recognize that.
9 However, with respect to Mr. Holmbeck, the 10 ef fect that his bias could have, his bias in the croceeding 11 could have -- and I mean by bias, I mean his avowed interest 12 in one direction of the proceeding in the questions and 13 answers we are accepting, which are strictly objective,
(~ 14 quantity type of questions and answers would be to do an 15 unethical thing. And that is, throw away some of the 16 results.
1 And we have watched him. We believe he is a 18 credible, principled person and wouldn't do it. So we 19 would not throw away those results simply because they 0
end 17 went through Mr. Holmbeck.
21 22 23 24 25 0
18-1 6101 i MR. BIELAWSKI: May I comment on that.
r k 2 During my examination and in the course of my 3 dealings with-Mr. Holrr. beck , I would not qccuse him of doing 4 what you just said.
5 JUDGE SMITH. I realize that, e MR. BIELAWSKI: The vices I saw, or the possibility.
7 of vice as I saw it was not so much with what Mr. Holmbeck a would or would not do with the results of the survey, but 9 it Could actually affect just whether cn not potential na respondents would respond and what their inclination would 11 be'in so responding.
12 JUDGE SMITH: The quantity of responses or the quality of the responses?
( -)
s-13 14 MR. BIELAWSKI: Both actually, but in particular is- the quantity. I don't think it has been established whether is the 50 percent who didn't respond, whether they didn't 17 ' respond for one reason or another.
is JUDGE SMITH: We will come to that. You will
- is see when we get dore that that point is not going to be l
2o relevant. If I am wrong, we will come back to it.
21 In any event, the survey at least the aspects of i 22 it, we accept it. It is not fatally tinted because of 23 Mr. Holmbeck's participation. Ne believe he did not make 24 any effort to skew the results to Mr. Cowen and we see no
,/ %)
\m/ 25 difficulty at all with respect to the preparation of the
- .-, .. . , _ , , , a ,~- - - .-..,.v ~.
A 6102 18-L t summary results.
r~
> (_)y a We do have difficulty with the introduction and 3 the summary whicn we will get into, but Mr. Cowan was 4 probably a good person locally to pick to taculate the s results. He knows how to do it.
e Also backing up with respect to both Mr. Holmbeck 7 and Mr. Cowen, the underlying-answers were available for e examination. The most important thing about this survey 9 is the relevance and here we have to go through several to documents to fully explore the relevance'.
it Mr. Holmbeck stated that the survey was relevant 12 to contention No. 3. Contention No. 3 in general relates 13 to Section 50.47 (b) (12) and asserts that the planning does V(~'h t4 not sufficiently aadress the fact that there are inadequate is medical facilities to provide the equipment and trained 16 personnel necessary to Care for Contaminated injured persons.
t r7 Medical facilities we do not equate with ambulances.
l te In the next clause in that contention that there 19 are insufficient procedures for the. screening treatment and' l
l 2o isolation of persons sustaining radiological injuries. That l 2: clause I just read is the clause that Mr. Holmbeck argued 22 was the basis for asserting that ambulances were covered as in the contention.
i .. 24 Radiological injuries as we know now clearly
' 25 from the San Onofre decision is not.the same as contaminated l
l l
l l
6103 18-3 1 injured persons.
O)
(,, a Inasmuch-as the San Onofre decision says no advance 3 arrangements whatever have to be made for the radiologically 4 exposed, that clause cannot be the basis of the relevance s in this proceeding of this survey, leaving the last clause e of contention No. 3, which I will quote now, in that there 7 is an insufficient numbJr of materials, supplies and equipment a and vehicles to provide for the transportation of injured o persons during a radiological disaster is the only arguable to relevant aspect of the survey which is to be derived from
, -t contention 3, and that is strictly a quantitative insufficierit 12 number. It is a quantitative allegation, j
/
- ')
k.J i3 So that does not cover the qualitative aspects 14 of the training and the aspects of the turvey, and this is judgment is particularly reinforced by the fact that the 16 Commitment requires the commitment of commitment P. ~ It 17 requires a demonstration that adequate emergency response is training.will have been made available to all response 19 organizations and individuals who may.be called upon to s
ao assist in an emergency. That is directors and coordinators as of the response organizations, first aid and rescue personnel, 22 local support service personnel and medical support personnel 23 and other off-site organizations identified in IPRA having f
24 mutual aid agreements.
i 25 So Decause of that commitment we must assume that i
,. -m., - . - ._ s.
18-4 " 6104 i the ambulance which are germane to this survey are adequately (3
( ,) 2 trained. That is a forced assumption because of the commitment .
3 Otherwise, that commitment would be pointless.
4 As to the aspect of the survey which does pertain s to the handling of quantitative contaminated injured, we e are givin pretty definite guidance by the San Onofre decision 7 and in that decision the Commission stated three times in a effect in the background and the introduction and the 9 discussions and the conclusions, and I will quote now from to the conclusion their view of the responsibility for the is care of contaminated injured off-site, and I will quote from 12 the conclusion which is on page 13 of the Opinion, CLI -'w)
(7 33 10. ,
i4 '"With respect to individuals who become injured is and are also contaminated, the arrangements that are currently is required for on-site personnel and emergency workers provide i i7 emergency capabilities which should be adequate for treatment l
[ is of members of the general public." Now members of the i9 general public are then coincidental beneficiaries 2o of the on-site personnel and emergency workers simply, that 2: the Commission says that whatever arrangements are currently l_ 22 required for those people are adequate for the general 23 public.
lifs 24 We do not know at this point, nor can we recall l
(/ 25 'from the record-whether the record demonstrates that there i
6105 18-5 i is adequate arrangements for contaminated injured on-site b)
(j 2; persdonnel and emergency workers. We have not arrived at 3 that yet. Therefore, we don't know if the public as 4 coincidental beneficiaries of that are adquately provided s for. So that is still an open issue.
6 However, we believe that with the limitation 7 that the Commission has imposed upon the requirements, a that arrangements beyond the EPZ would be not required and
, therefore irrelevant to the Commission requirements.
n3 Therefore, we are going to limit the survey to si the appropriate questions and answers inside the EPZ. We 12 also have to bear in mind that the evidence now points out
(}-
V
,3 that the Byron Fire Department has been engaged to satisfy i4 the arrangement aspect. Therefore, looking at the survey
- . is we have to bear that in mind. Had they responded, we would n5 almost have-to assume an ideal response.
l 37 We also want to observe with respect to televancy is that the timing of the survey was-also an important factor i, that the survey has taken place as we have observed relatively l
l 2o early in the planning process. So that also is a factor I
2 to be considered in the value of the survey.
22 Now let's go to the survey itself. I know we l
23 have discussed the standards that we have used and the ai weight that night be given to it. Just go to the survey i
j '" as- itself, beginning with the summary, and we might as well r
L ,
6106 18-6 i discuss the introduction.
bl
' s_,/ a This was prepared by Mr. Cowen. I would imagine 3 that portions of the introcution and the summary would be 4 acceptable because they are nothing more than an objective-s summary of some of the staistics.
e However, intertwined with that is so much irrelevant 7 material and several aspects of improper statments, unaCCep-a table statements that the entire summary introduction should 9 D6 rejected. If you wish, if you think io is important, io maybe you could reintroduce it. I would say that we don't is need it, particularly to the extent that the survey has been l 2 reduced. These statistical summaries are nolonger realy (n
%)
4 is valuable.
i4 As I mentioned, there are other aspects of the is summary and the introduction which make it also unacceptable, is For example, the last bullet on page Roman numeral I, the i7 Rockford Memorial is-designated as a supporting medical is facility. In the Byron Station emergency plan only two 19 ambulance services said they would take injured patients 2o there. That is misleading, or it is not misleading, but i 21 it is at leas t ar..bicuous . We do not know from that whether l 22 the others said in effect I don't care who has the decontamina-23 tion. injured responsibility. We are not going there, and 24 they simply didn't know or what.
\
i I\~)s 25 So it is not a helpful statement. It does have l
l
6107 18-7
' the propensity'for being prejudicial.
p)
(m, I might observe that that statement is I believe 3
in there three times, in the survey three times.
Then there-is another example here. One of the 8
services said they would.not take a patient unless they 8 were decontaminated. They would only serve if the patient 7
were decontaminated and the ambulance.would not have to e
enter the contaminated area.
This gets down into the single response of a single responder rather than statistical data which is involved
-in a survey, and as such it becomes flat out hearsay. But 12 those are some of the problems we have with the summary 13 (J) and the introduction. So we are rejecting that.
-'4 The methodology also has'some infirmities. For
'5 l example, the conclusion, the bias in reporting, if any, would'
'8 be expected. It would be expected that those better prepared
'7 would be more likely to respond.
is The Board thinks that that is maybe logical,.but it does not have the guarantees and reliabilities sufficient 20 to. accept it, and Mr. Cowen does not have the demonstrated 21 expertise. He may_have the expertise, but he does not 22 have the demonstrated expertise to make that a professional 23 opinion. The map, I see no problem with the map.
24 Manpower availability and training? We have
(~)'
G **
already discussed why we are -- I am speaking at page 3 now --
18-8 6108 I why we are limiting this survey to the EPX, and here again
( ) 2 in that section you have the statement that appeared in the 3 survey.
4 On page 3 you have a statement in the third para-5 graph that they would respond to an emergency at Byron only e if " patients were decontaminated and the ambulance would 7 not have to enter the contaminated area." So that is a flaw e in that section under the subsection " Ambulance Equipment 9 and Preparedness." It depends upon information which is to more irrelevant than relevant and is unacceptable for that si reason.
12 The entire section has the infirmities we stated.
[( "1 i3 That is entwined with relevant and irrelevant. The statement v
/
e4 on the last page, page 4, 69ain the statement that the services is would not take paitents. They did not designate Rockford te Memorial. We already discussed that, but that statement 17 appears there again. So even the repetition is a defect.
is Now coming to the survey results, going to 19 question No. 1 ,. we can see right down the line here that 20 we are going to take the column "EPZ." Question No. 1 l
l 2 is a nice question. How many people are active members?
1 22 There is no problem with it.
l 23 Question No. 2, how many of these people are
,_ 24 emergency medical technicians? That really goes to the i e i
\ /
25 l quality of the people. I don't think anybody has really
, . . . - . - - . ._ .- - -- . . - . . = - _ - . _. -
j 18-9 1 objected to that. We don't know what our emergency medical a technician is, by the way. This record does not say. It 3 is apparently an Illinois license or an Illinois qualification .
4 4 I don't know if there is any objection on that. It seems
'l s to be a harmless question. Unless there is specific- [
f objection, we will leave that in.
y How many ambulances does the ambulance corps l e Operate, that is clearly relevant within our ruling.
p end 18 to 11' 12 4
13 14 1
, 15 :
l +
t 16 +
i 17 i
le 19 20 21 l t 22 23 24 25
. - , _ - _ _ - . , _- _ , . _ _ - _ - , - . . _ , _ . . . , - .-.-..-.,_-,._,---.-----n,. -, ,.,-
b 19 pv 1 6110 i
f%
\ l Is your ambulance corps part of the police or 2 fire department? I think that question is satisfactory.
3 Questions 5, 6, 7, 8 all relate to competency 4 in training, and 9 relates to the conclusion we have 5 already rejected because of the bias flowing from 5, 6, 7 6 and 8.
~
7 So all of those would be out.
8 10, to what hospital would you take patients 9 who have been injured in a radiological emergency, we 10 have already discussed that being a bad question, because 11 that does not demonstrate whether they have been informed 12 and also it does not say -- it refers to radiological 13 emergencies, but it is not refined as to contaminated, 14 injured, or injured alone or whatever. So the question 15 does n_ot give useful information in the context of 16 information we need with respect to the issue that 17 is before us.
18 Question number 11 is the distance from 19 the farest point in your area to the hospital. It suffers 20 the same infirmity that the previous question on 10 does.
21 Question 12, maximum number of medical patients 22 that the ambulance corps can transport at one time is 23 relevant and is a good question within the context of our 24 ruling.
l 25 13, the maximum number of nonambulatory persons O
! C -
l
b 19 pv 2 6111 1 that you can transport at one time, this is apparently-2 nonambulatory people who are not contaminated. In 3 discussing this, we just did not know what that question 4 was going to. Maybe it is special facilities, nursing 5 homes.
6 MR. BIELAWSKI: I do not want to speak for 7 Mr. Holmbeck or Mr. Murphy. As I understand the question, 8 though, some ambulance services in the area would have 9 responsibilities and transport, say, nursing home people 10 who have just been evacuated and who may not have been 11 contaminated and in fact are being evacuated to avoid 12 contamination.
13 p)
N, 14 This question is directed to that, althouah l the issue of evacuation and nursing home people who are t
l 15 transport-dependent type people, mobility-impaired people 16 who are not injured, is an issue of a commitment.
17 JUDGE SMITH: A commitment, yes.
18 Would you agree'with that?
! 19 MR. SAVAGE: Part of what it is talking to is 20 these people's understandina of what is to ao on. I think 21 it is adequately covered.
l 22 JUDGE SMITH: So 14 would be out.
23 Written protocol, does that -- in fact, the Board 24 overlooked discussing that. It goes to the written 25 protocol that can be looked at as part of the equipment as n
V
b 19 pv 3 6112
,o 1 well as a part of the training. I don't know. I don't 2 know how much time -- 15 relates to written protocol for 3 emergency response to accidents involving other injuries 4 as well as radiation exposure. That is in affirmative 5 because of the distinction of radiation exposure made by 6 San Onofre. So that one would have to be out.
7 16, I don't know. I don't think anything is 8 going to turn on it,but it seems to be one that should be 9 in. And I see that other Board members agree with me. So 10 16, with respect to the EPZ, is in.
11 17 is a bad question. It just does not seem 12 to be relevant.
13 rm 18, do you still want 18 in? Are you looking U 14 at it, Mr. Savage?
15 MR. BIELAWSKI: I would point out with respect 16 to 18, to the extent it says anything that says that has 17 in fact contacted people or ambulance people within the EPZ, 18 there was one "I don't know" response.
19 JUDGE SMITH: So you don't object to that?
20- MR. BIELAWSKI: This is, I guess, to the extent 21 the survey shows anything in this case it shows the richt 22 services thus far have been contacted.
23 JUDGE SMITH: 18 probably should be in.
24 MR. BIELAWSKI: I think there is evidence in 25 the record for Mr. Smith and Mr. Ed that these contacts O
O i
-.r. ,
6113 1 will lead to the developmentof standard operating procedures 2 which are probably written protocol.
3 JUDGE SMITH: 19, are you aware of any efforts 4 to assign a support role to your ambulance service as part 5 of integrated response to radiological emergency. That 6 should be in by the same logic that 18 is in.
7 How many of your ambulance corps members -- this 8 is number 20 I am reading -- would respond to an emergency 9 resulting from radiological release from the Byron nuclear 10 facility? Now, my notes on it say it is ambiguous because 11 it does not make it clear whether they would refuse to 12 respond or are they expected to respond? And to me this 13 is an affirmative ~that would exclude that question.
(N 14 ~
21 is a relevant question. It is the supplies 15 necessary for treatment and decontamination in the event 16 of a radiological emergency.
17 MR. BIELAWSKI: Your Honor, with respect to that 18 question, the question does ask whether they have a 19 facility decontamination. And I think the record is clear.
20 And even the intervenor's witnesses admitted that in this 21 case ambulance services would not be requested to perform l
22 decontamination of patients that they were providing 23 services to.
l 24 As a result, I think that this question, the 25 answers to the question could leave a false impression in t f
! t w
pv 19 pv i 6114 1 the record as to the preparedness of these ambulance 2 services.
3 JUDGE SMITH: What is your view of that, 4 Mr. Savage?
5 MR. SAVAGE: Quat, tion number 217 6 JUDGE SMITH: Yes.
7 MR. SAVAGE: Read 22 while you are at it.
8 (Pause.)
9 MR. SAVAGE: What is your argument, Counselor?
10 MR. BIELAWSKI: 21 -- the argument for 21 is 11 really based on the same rationale for striking out questions 12 5 through 8 which assume, I think, there is a premise in j 13 this question, it assumes that the ambulance service will 14 recall the board to perform certain activities which the 15 plan simply does not require.
16 JUDGE SMITH: No, there is a difference. It 17 may be that the plan does not' require it, and that is an 18 evidentiary consideration. The question is, is it relevant 19 to the contention? It may well be that when we compare 20 in decision-making time with the fact that the plan does 21 not require it, then this will not be controlling.
But at this state of considering, it is relevant to the contention. But the point is, does the intervenor 24 still want it in now that they know more about the plan?
25 Now that you know as a result of the evidence at the hearing O
b 19 pv 6 6115 O
\ ,/ 1 that the decontamination would not be done by the ambulance, 2 do you still want it in?
3 MR. SAVAGE: It's got to be relevant.
4 JUDGE SMITH: Before the hearing began, would 5 it have been relevant?
6 MR. GOLDBERG: Judge, I think there was 7 evidence from a number of witnesses that decontamination 8 capability is not necessary for the ambulance services to 9 possess in order to handle and transport individuals.
10 JUDGE SMITH: That is evidence that can be 11 offered in proposed findings. We are looking at the evidence 12 at a different time frame than when we are writing a 7- 13 decision. We are looking at evidence that whether we i
\/- 14 receive relevant evidence, we do not rule on who wins at 15 this point. You see the distinction.
16 MR. BIELAWSKI: You are talking about the weight 17 of the evidence really.
18 JUDGE SMITH: Let's say that you have -- the 19 only evidence that_you had evidence which is convicing that 20 ambulance services will not be required to perform 21 decontamination, here is evidence that the ambulance 22 services do not have equipment for decontamination. You 23 haven'twonyetonyourpointthattheambulanceservices 24 are not required because we have not yet decided that.
l 25 Maybe I can look down the road and predict that you will, U(%
o 19 pv 7
,) i but right now we are just selecting evidence to go into 2 the record, relevant evidence to go into the record.
i 3 MR.BIELAWSKI: I see your point. I think it 4 would be up to intervenors to decide, based on their 5 knowledge of the plan, whether they would want to withdraw
! S that.
_7 MR. SAVAGE: Given the characterization of the 8 problem, I would want it in. I cannot look down the road 9 and make that determination, that prediction about what l 10 you are going to do.
11 JUDGE SMITH: We don't decide relevance based 12 on who is ahead so far in the hearing. We decide relevance l 13 based on how it relates to t he contention. I quess the
, 14 same thing goes to number 22; that is, protective equipment
! 15 available for radiological emergency.
16 And 23 relates to radiation survey instruments.
[
17 You haJe the same thing. You have the dialogue as to they 18 don't need them. Well, all right, that still is relevant 19 at this juncture of the hearing.
20 In the notes,we have not evaluated the notes 21 as to whether they should be in or or out. And really 22 when you are done with it, we should not take any more 23 time on it. It will be up to you to resubmit it in a way 24 consistent with our ruling.
l 25 MR. SAVAGE: I have one question about San Onofre.
- .. c. -
6117 (m) 1 Would you just state briefly why San Onofre would limit the 2 admission of the results in the survey t o the EPZ?
3 Based upon -- beginning with San Onofre, D: says that all 4 that is needed is the equipment necessary to take care of 4
5 one plant on site a-d emergency workers.
6 If that is all that is needed to take care of 7 the general public, that is a matter of judgment. We do 8 not have to look at the 70-some outside the EPZ. We then 9 select as a matter of judgment the EPZ services as being --
10 it is a question of quantitative relevance.
11 What I am wondering about is San Onofre construed 12 the regulations and apparently, given~the testimony of 13 Mr. Smith and Ed, applicant has chosen to go beyond the h
f/
x- 14 regulations and is making plans to have mutual aid agreements 15 with ambulance services in Rockford and Rochelle.
16 JUDGE SMITH: Incidentally, San Onofre does 17 require that where those agreements exist, that they be 18 identified.
19 MR. SAVAGE: That is correct.
20 JUDGE SMITH: As I read San Onofre, the 21 requirements are minimal. They take the situation as it 22 exists and they review olanning as identifying rather than 23 requiring, identify what is available in a radiological 24 emergency rather than setting up what is required except 25 where we have indicated.
O
\s-)
l L
b 19 pv 9 6118 f')
'\_,/ 1 MR. SAVAGE: My question is in a case where 2 applicant has gone well beyond the regulations. Shouldn't 3 we admit this evidence anyway because it is probative of 4 what they are going to do?
5 JUDGE SMITH: You have accepted.the testimony.
6 I guess I don't follow you. I think perhaps you could 7 have objected to them offering evidence about the place in 8 Chicago for the radiological exposed. I don't think that 9 would be a good policy on your part. I think if they 10 offered that as an inducement to get an operating license, 11 I don't think they better stop doing it.
12 MR. SAVAGE: No, I would like to encourage them.
13 MR. BIELAWSKI: Your Honor, this will take about f-~
\s / 14 2 minutes just so I can inform you of where we stand on 15 the emergency planning right now.
16 Based on your ruling and discussions that I have 17 had with Mr. Savage, it appears that we will be able to l
18 enter into a stipulation as to what portions of 19 Mr. Holmbeck's testimony which survives after all of this 20 time. They would still want to offer and they would 21 stipulate that certain points would be made on cross-22 examination or stipulate as to Mr. Holmbeck's lack of 23 expertise with respect to certain points.
24 The same goes for the evidence of the testimony 25 of the school board people and the nursing home v
b 19 pv 10 6119 h{3 1 administrators. And we believe it is possible that could 2 all be submitted into the record pursuant to stipulation.
3 And we would not have to come back in May for any more 4 hearings on emergency planning if that can be worked out.
5 We are certainly going to try.
6 JUDGE SMITH: llow we be informed of that?
7 MR. SAVAGE: I can make an oral presentation at 8 some point before the close of the hearing.
9 MR. BIELAWSKI: This week.
10 MR. SAVAGE: I will check with Mr. Bielawski 11 to make sure that he understands what I intend to do and 12 whether he agrees with it.
13 JUDGE SMITH: Go ahead.
l O 14 Now that we have clarified our ruling here, 15 are there any motions for reconsideration? It is only a 16 motion for reconsideration based on mistake in concept, 17 no t on the basis of the ruling.
18 MR. BIELAWSKI: I have a question. Whenever 19 anybody says "open issue," it gives me a little bit of a 1
20 heartburn.
21 JUDGE SMITH: It is not that you disagree with 22 our ruling; it is that we have made a mistake in concept 23 or in understanding.
24 MR.BIELAWSKI: I don't disagree with your 25 ruling. I would like some guidance from the Board. You i
o is pv 11 6120
/N
--) 1 stated that there was an open issue with respect to the 2 ability of applicant and the State to provide for -- to 3 provide ambulance services to members of the general public.
4 I don't know if I dreamed that you are asking for more 5 evidence in the record or whether just by pointing to the.
6 testimony of Mr. Ed and Mr. Smith, who identified the 7 ambulances that would be called upon to provide the 8 services requested and identified the -- the training, 9 which is basically irrelvant and also identified the fact 10 that standard operating procedures would be developed 11 along with these ambulance services to ensure thatthey 12 have the types of procedures that are required, whether 13 that is --
l rS 14 JUDGE SMITH: By "open issue," what I intended 15 to say was an " undecided matter." This evidence has come 16 at us, you know, like it'is a flood. And we can recall, 17 if we put our mind to it, any part of it, that rather 18 the evidence in its totality demonstrates that at this 19 point that you have satis,fied the requirement. We are not end 19 20 in a position to decide. That is what was meant by that.
21 22 23 24 25 m
b 20 PV-1 6121
' 1 We did want to make it clear, however, that the 2 interests of the general public is an interest protected 3 by the regulations. It is just that it is measured by 4
the arrangements made by on-site personnel and emercency 5 workers.
6 JUDGE SMITH: I see our witnesses wisely 7 escaped. Here they are, gentlemen. Do you want to proceed?
8 (Pause.)
9 JUDGE SMITH: I have been criticizing counsel 10 for overestimating the time that it takes for underestimatinc-11 the time that it takes for their presentation. I was off 12 by a factor of 5.
13 MR. THOMAS: May I proceed, Your Honor?
14 JUDGE SMITH: Yes.
15 MR. THOMAS: Judge, before I begin at this
'16 point, I have a series of questions that I propose to put 17 to Mr. Hitchler, some of which I am sure will get us into 18 .that limbo document. And we made an objection, as I 19 understand it, yesterday. Mr. Savage made a motion to l
20 strike or some sort of appropriate motion with regard 21 to this so-called EPRA, which has not been introduced into 2'
evidence.
23 I want to be clear by questioning him -- I am 24 Probably going to draw out more information from the 25 document, and I wish to do it without waiving our initial V
- . - . . - , _ - , . w
b 20 pv 2 6122 1 objection. I just want to make note for the record on that.
2 JUDGE SMITH: Do you understand the basis for 3 the ruling yesterday?
4 MR. THOMAS: Not being here, perhaps if Your 5 Honor --
6 JUDGE SMITH: It was not the document or the 7 portion of the document per se which was being received 8 into evidence. It was received into evidence because it 9 became a part and parcel of his testimony as compared to 10 a third-party document, for example, as to which a part 11 or a part of it is used as a basis for testimony.
12 See, the witness participated in the preparation 13 of that, and he could have just as easily referred to it
('}
O 14 and summarized the document. I think that should be fresh 15 in your mind. He could have summarized the document in 16 terms of questions and answers, and the question never 17 would have come up.
18 MR. THOMAS: That's true. At any rate, I t
l 19 wanted to make the record on that question.
20 BY MR. THOMAS:
21 Mr. Hitchler, have any Byron-specific accident Q
22 analyses been performed which consider first of all 23 multiple-tube rupture accidents?
4 Yes, sir.
A (Witness Hitchler) 25 And how many -- is there a title to that or is Q
n 1
4 D 20 pv 3 6123
{T w.s/ 1 there a title to that analysis?
2 A The analysis was referred to in this other 3 document, and the analysis performed a basis for my 4 determining the severe core damage frequencies that were 5 mentioned in my testimony.
6 Q What do you mean by "this other document"?
7 A The risk assessment document.
8 0 That is the thick -- all right.
9 A In addition, a number of analyses that also 10 formed the basis of my judgment have been submitted as part 11 of the Westinghouse Owners Group program for development of 12 emergency procedures and guidelines with respect to tube s
13 ruptures during steam break events and other combined
'* 14 events.
15 0 Have been submitted where?
16 A They have been submitted as supporting analyses 17 for the emergency response guidelines.
18 Q Submitted here within this hearing?
19 A Not within this hearing, but with t he NRC.
20 0 In connection with what?
21 A Westinghouse has generated recommended 22 emergency response guidelines, which is part of the 23 operating procedures for the plant. Those guidelines 24 have been forwarded to the Byron operating staff. And also 25 the guidelines have been approved by the NRC as well as O
V
6124 p
b 1 the background or backup analyses.
2 O Are those generic guidelines, or are those 3 Byron-specific guidelines?
4 A .They are generic guidelines to be used by the 5 operating staff to make them specific. In other words, 6 the g'uidelines identified trends and asks the plant to 7 implement exactly what instruments they have, those types 8 of things. Otherwise, the guidelines are generated from 9 the standpoint of types of plants, Mode 2 F or Model D 10 steam generation.
11 0 Can you indicate to us the ones that were <
12 submitted to the NRC?
13 A Yes.
V 14 0 Of course, you work for Westinghouse, right?
15 A That's correct.
16 Q And Westinghouse is the vendor of the D4 and D5 17 steam generators to be used at Byron, is that right?
18 A That is correct.
19 Q Has a Byron-specific accieent analysis been 20 performed which considers tube rupture events in conjunction 21 with a loss-of-coolant accident?
22 A No, there has not been a specific one done.
l 23 First of all, with regard to the multiple-tube Q
f 24 rupture accident where you indicated a Byron-specific 25 accident analysis has been done or performed, can you tell i
b 20 pv 5 6125 N
1 me how many tube ruptures performed the basis of that 2 analysis?
3 A The analysis was done in steps to find out what 4 where we were sensitive or where the accident trends would 5 significantly change based on the number of tubes that 6 were assumed to fail. Now, the number of tubes assumed 7 were used 1, 3, 5, 10, and I believe the maximum was 50.
g MR. GALLO: What was the last number?
9 WITNESS HITCHLER: 50.
10 BY MR. THOMAS:
11 Q What about leak rate?
12 A When we assumed that a tube failed, we assumed 13 it was the double-ended rupture as opposed to much smaller 14 rates we are seeing from an experience standpoint.
15 Q What is the gallons per minute from a double-16 ended rupture?
. 17 A Again, it depends on the pressure, back pressure 18 between the primary and secondary side. A typical flow 19 rate is approximately in the 600 to 800 gpm range.
i 20 0 Are those the figures you used, 600 to 800?
21 A The number I recall is, I believe, 650. This 22 particular diameter tube.
23 Q Now, with regard to the analysis that was done, 24 what was your result in the worst case scenario?
25 A Right now, a tube rupture accident can follow n
l U l
l
o zu pv o 6126 (cm), 1 many scenarios. The standard scenario showed that, in 2 essence, even when you went up to large numbers of 3 failures -- meaning in the 10 to 50 tube rupture failures --
4 that the results did not change very much.
5 0 In what sense?
6 A In other words, the planning for operator action 7 did change to some extent but not significantly. The reason 8 why this did not occur is that even though you may fail a 9 large number of tubes in the steam generator, what happens 10 is that the steam generator -- it acts essentially like 11 another pressurizer in the system. What will happen is 12 the primary system will depressurize faster than what the f
i 13 single tube shows. However, you will equilibrate at about IN/ )
14 1,100 to 1,200 psi very quick, which by the way is where you 15 want to be from the standpoint of procedures.
16 Now, what will then happen is that the safety 17 injection system will start to compensate, start to bring 18 you back up to pressure, but again the principle here is 19 that the steam generator still will act to seal until you
! 20 go above the safety valve set points.
21 Another comment I would like to make on this is 22 that the steam generators and the action of their safety 23 valves tend to limit the effects of gross failures of tubes.
24 In other words,the safety valves on the steam generators 25 are only of a limited size, approximately a 1 to 2-inch or Ov f
b 20 pv 7 6127 p
(_jl 1 2-inch flow area. So therefore, even though you may have 2 failed 10 tubes or 50 tubes, you can only relieve a certain 3 amount of steam or water through those valves. So that 4 ultimately you do not have a very large sensitivity once 5 you go above a certain level. In general, the numbers we 6 are talking about is after five tubes fail, you do not see 7 major changes in the trends.
8 Q So the testimony that you have just given is >
9 based on the assumption that you are not also dealing with 10 a loss-of-coolant accident then, right?
11 A That is correct.
12 I would like to make a comment with respect to 13 the loss-of-coolant accident. Although we have not done l (~h
\~ l 14 Byron-specific combined LOCA and tube-rupture analyses, 15 Westinghouse has provided generic analyses to show the 16 impact on peak clad temperature hen you do postulate 17 multiple-tube ruptures in a large LOCA event.
18 0 With regard to loss-of-coolant accident, Byron-19 specific loss-of-coolant accident analysis, why has that 20 not been done?
21 A The analysis that has been provided in the 22 past has shown a small impact on the overall LOCA analyses 23 for multiple tubes. In other words, we have done analyses 24 to show that we can withstand. The numbers I have seen from 25 the transient analysis people there are in the 5 to 8 tubes
(
O
D 20 pv 8
. 6128
,O
'V 1 that could fail during a large-break LOCA and still not 2 produce significant changes to the results.
3 0 When you say the analyses that you have done in 4 the past, are you referring to Zion and Indian Point?
5 A The analysis that I am aware of was done for 6 a four-loop plant. I do not recall the exact model it was, 7 but it has been verified that that sensitivity is applicable 8 to a plant such as Byron.
9 0 What plant was that?
10 A I do not recall the exact plant.
11 O You do not recall the name of it?
12 A No.
g 13 O How has it been verified that it was applicable 14 to Byron?
15 A Again, I would have to actually talk to the 16 individual that was involved at that point.
17 O So you don't know, is that right?
18 A I have talked to the group that was in charge 19 of these analyses and asked for the number of tubes 20 that they could withstand before they felt their large-break 21 analyses would be invalidated, and the response was: 5 tubes .
22 Now, as far as the details as to which plant that was and 23 exactly why it was specific to Byron, I don't know. I don't 24 have that information.
25 0 You mean why it was applicable to Byron?
1 O
'O
~. e. ,
6129 l 1 A Yes.
2 O When you say that a tube rupture event in 3 conjunction with a. loss-of-coolant accident would not 4- change the analysis significantly, what parameters are 5 you talking about and what t'erms?
6 A The definition of significance with respect to 7 LOCA events is typically that the peak clad temperature 8 will not rise more than 50 degrees.
9 0 So that was the criterion that you were using 10 when you said it would not change it significantly?
11 A Yes.
12 Q Are you familiar with a -- have you had an 1
13 opportunity to review the testimony that was given in this G 14 case by the previous panel on the steam generator issue 15 the week of April 11 to April 15? Have you seen that 16 testimony?
17 A Yes, I have.
18 MR. GALLO: You mean the Westinghouse panel?
19 Which panel are we talking about, the staf f or the 20 Westinghouse?
21 MR. THOMAS: Either one, but the Westinghouse 22 in particular.
23 WITNESS HITCHLER: Yes, I have.
24 BY MR. THOMAS:
25 0 You a e aware, then, that there was a lot of (D
~
.o zu pv tu 6130
)
(~/
x_ 1 discussion regarding the SAI report during that testimony?
2 A (Witness Hitchler) Yes.
3 Q You were familiar with that report, is that right?
4 A' Yes, I am.
5 0 And so you are aware that the NRC in its review 6 of.the SAI report and other A-3 activities has stated that 7 multiple-tube failures should be considered. Is that 8 correct?
9 MR. GALLO: Objection. There is no predicate 10 for that question, no evidence in this record that indi-11 cates that the NRC has made a declaration that it is 12 considering those kinds of accidents.
gs 13 MR. GOLDBERG: Judge, in fact, I think the 14 converse may be true because Mr. Marsh testified that the 15 consideration was in the context of deriving suitable 16 emergency operating procedures.
17 MR. THOMAS: Let me rephrase the question.
18 MR. GOLDBERG: I do not purport to want to
! 19 testify. I am not testifying. But my recollection does 20 not square with the inference in the question.
l 21 MR. THOMAS: I do not have a perfect recollection l
end 20 22 of the testimony regarding that.
r 23 24 i
i 25 t
21-1 6131 1 MR. THOhAS: Let me withdraw'that question and T
2 put the question in another form.
3 BY MR. THOMAS:
4 Q Are you familiar with NUREG 0397?
5 A (Witness Hitchler) Not by number.
6 Q Are you familiar with the NUREG entitled 7 " Evaluation of PWR Response to Main Steamline Break With a Concurrent Steam Generator Tube Rupture and Small Break LOCA"?
9 A I have not reviewed that yet.
to MR. THOMAS: Judge, I do have a copy which I 11 would just propose to submit to the witness so that the 12 witness understands clearly what document I am talking about
() 13 and not necessarily to ask him any specific thing within 14 that document.
15 (Document handed to witness.)
16 BY MR. THOMAS.
17 Q' Let me tender NUREG 0397. Have you read-that is document at any time?
19 MR. GALLO: Objection. He has already said that 2o he is not familiar with the document. I don't what use
(
as it is handing it to him.
22 MR. THOMAS: He said he was not familiar with it 23 .by number.
24 JUDGE SMITH: After you read the title of it, (s
\
25 he also said that he had not read it yet.
l
~
6132 21-2 i
Is that correct, sir.
( ) 2 WITNESS HITCHLER: That is correct. I have not a read that document.
4 BY MR. THOMAS:
s O You have not read that document. Okay.
. Can you tell me based upon your analysis wnat 7 would be the results of a main steamline break outside of a containment with the failure to isolate what those results 9 Y U to MR. GALLO: Objection. It is beyond the scope
,, of the. witness' testimony. The witness' testimony deals 12 with frequency of occurrence and does not deal with r~' ,3 consequences. The question therefore is beyond the scope L ,'
,, of his direct testimotiy and should not be allowed.
is MR. THOMAS: Judge, in his testimony he goes into
,, the probability of core melt and I suppose you can regard 3, that as frequency or you can regard it as consequences.
to JUDGE SMITH: Where?
19 9 ' 9
- 2o MR. GALLO: It is not core melt, and again it 2, is core damage. Its frequency is ten to the minus seven per year.
23 MR. THOMAS: It says core melt also.
7- 24 MR. GALLO: Still dealing with the probabilities
- i
-' of occurrence.
25
21-3 6133 s
JUDGE SMITH: .The. probabilities, but if he wants
' a to test the statement of probabilities, this is one way of
< s doing that.
4 MR. GALLO: By asking him what the consequences 5
are?
! 6 JUDGE Si4ITH: Is that what you are asking? Are 7
you going to consequences or are you going to move in the direction of procanilities after you establish one of the consequences mentioned in the testimony. If he is going
' ~
to challenge the probabilities, he can do it by estab1'.ching-
.that there are additional mechanisms leading to severe 12 core damage other than what he has taken into account.
in '
( ,) MR. GALLO: It is my understanding,_Your Honor, that the probabilities dealing with the frequency of these 15 events is a consideration that excludes consequences.
16 Consequence is a factor in determining risk.
JUDGE SMITH: I understand that.
, MR. GALLO: Then as I recall the question, he was asking 4.bcut further consequences, off-site consequences of a mean steamline break. That is not within the scope I
of this witness' testimony.
l 22 JUDGE SMITH: What do you say, Mr. Thomas?
! MR. THOMAS : One moment, please.
1
/N (Counsel conferring.)
.h- 25 l MR. THOMAS: I think a fair construction of the
~ .
6134 21-4 i ' question is'it.is asking for consequences as opposed to Gi a probability or frequency.
s ,/
3 ' So if the Board accepts Mr. Gallo's characterization 4 of'the witness' testimony ---
5 JUDGE SMITH: If you are not ultimately going a to probabilities,'Mr. Gallo is correct. I thought you could 7 go to probabilties by establishing additional ---
a MR. THOMAS: Consequences. I understand that,
, but that was not really the direction of the question.
io JUDGE SMITH: Then he is correct.
in BY MR. THOMAS:
2 Q Mr. Hitchler, have studies been performed to
/N i3 check the effect cn containment integrity for a main steamline
. \h i4 break inside containment with multiple steam generator tube is ruptures?
is A (Witness Hitchler) I am not aware of mass energy r7. release calculations being performed combining those two l is types of events.
i, O So there is no such study for Byron that you 2o are aware of, right?
2: A I am not aware of one.
, 22 0 Is any other member of the panel aware of such I
! 23 a study for Byron?
l fs 24 WITNESS BLOMGREN: No.
U 2s WITNESS TIMMONS: No.
21-5 6135 i WITNESS HITCHLER: No.
a WITNESS BUTTERFIELD: No.
3 WITNESS: FLETCt!ER: No.
4 Q Mr. Hitchler, are you familiar with the study by s an . individual by the name of Jefferie L. Lachance entitled e " Steam Generator Tube Rupture Effects On A Loss Of Coolant 7 Accident"?
e A (Witness Hitchler) No, I am not.
e (Pause.)
.io MR. THOMAS: One moment, please.
- Excuse me, Your Honor, I am trying to switch 12 witnesses now.
BY MR. THOMAS:
f
) is 14 - Q Mr. Fletcher, in your testimony on page 15 you is indicate that the loose parts monitoring systems are utilized ie for indications of impact signals within the steam generator i7 that alert operators to the possible presence of metal objects.
is Are you aware of whether those are installed at Byron?
i, A (Witness Fletcher) I am aware that Byron has 2o loose parts monitors, yes.
2: Q And it is your understanding that those are on
- 2 the primary side or also on the secondary side?
l' 23 A It is my understandir.g they are on the secondary i
2 ', side.
ifl V 2s- Q You indicate that those are installed to alert
21-6 6136 i operators to the possible presence of metal objects. Is (n) 2 it your understanding that the loose parts monitoring system 3 are in continuous operation?
4 A The particular mode of operation of the loose parts s monitors at Byron I am not familar with. 'I do not know e what Commonwealth Edison's plans are for that.
7 Q Have 'you ever been to Byron?
e A No, I have not.
9 Q When were you first contacted about heing a io witness in this proceeding?
si A In the Iaiddle of last year, approximately.
12 Q Have you reviewed the testimony that was given
. /N ,3 in this case the week of April lith through the 15th?
'D i4 A I have reviewed the testimony given by the is Westinghouse witnesses for the 12th through the 14th.
ie Q Did-you review the staff testimony?
17 A I scanned that very quickly, Mr. Thomas.
l-l te (Pause.)
19 Q Are you familiar with the NUREG that I just l
2o tendered to Mr. Hitchler, 0937. Did you have an opportunity i 21 to look at that?
22 A I am not familiar with that document.
l 23 Q On page 4 when you are asked what is the purpose i
2, of your testimony, you indicate "The purpose of my testimony A
as is to provide an overview summary of the other Westinghouse i
q
21-7 6137 1 witnesses' testimony on the panel." Is that correct?
s
,, 2 A That is correct, Mr. Thomas.
3 Q You then proceed to suramarize the testimony .of 4 Dr. Conway, Dr. Wootten, Dr. Patel, Mr. Malinowski, Mr. Timmons ,
5 Mr. Blomgren and Mr. Paul, right?
e A That is correct.
7 Q Are you aware that Mr. Paul did not testify here --
a I am sorry, Mr. Paillaman testified.
9 JUDGE' SMITH: If you had been present, you would to have voted that that was corrected in his testimony.
11 MR. Th0 MAS: That is right. I was just informed 12 of that,-Judge.
j 3 13 Judge, for the record, I would again renew my 14 motion,-or the motion that Mr. Savage made yesterday to is strike this testimony. I don't see how that testimony adds is anything to the testimony that is already.before this Board.
1 17 JUDGE SMITH: Do you have any other new grounds?
to MR. THOMAS: No. Other than the testimony that is has been given here today, it indicates that the purpose 20 of the testimony is to summarize the testimony of the previous as witnesses. .I don't think that is proper testimony nor do 22 I think it is necessary nor should be received in the record.
23 MR. GALLO: Judge, that has not been elicited
- 24 here today. Mr. Fletcher was not asked what the purpose
\'" }
- 25 of his testimony was. He was asked does it state that
. . - , . , . _ -.--,e--... . - , . . . - . , , _ _
. - . , . . . , , . - , . - . - - . , , , , , - =n -- - - . - ,
6138 4 1-8 1 the purpose of your testimony is thus and so, and he said f~T
(_) a- yes.- He was not asked what the purpose ofhis testimony 3 was.
4 JUDGE SMITH: Is that the basis for your motion, 5 your question and answer that Mr. Gallo just referred to?
s- MR. THOMAS: Yes, that he states in his prefiled 7 testimony that the purpose of his testimony is to summarize i
e the testimony of other witnesses.
e JUDGE SMITH: We went through that yesterday.
so MR. THOMAS: My understanding of what took place it yesterday was that you indicated we could renew the motion 12 at the time that we cross-examined, and that is basically
' f~'\
33 what I am doing.
%)
i4 JUDGE SMITH: You just asked the same question.
15 What cross-examination have you conducted which would throw te new light other than that one question, the identical l
17 question that was asked yesterday?
18 j
end l 21 j 20 21 t
22 23 i
g 24 I
\ ~/
)
25
6139
-n)B-22-b-11
(, MR. THOMAS: I have not shown anything that would 2 shed new light. I still think the motion is well taken.
3 JUDGE SMITH: As it was shown yesterday and we 4 ruled yesterday.
5 MR. THOMAS: Yes.
6 I guess the additional matters that have been 7 brought out today is that he has never even been to Byron, 8 and there has been some additional testimony today. I can 9 see what the disposition of the Board is. I just want to.
10 make a record on this subject.
11 JUDGE SMITH: Yesterday it was developed that he 12 was he was doing more than summarizing the testimony of the 13 witnesses. If that were the only purpose of his presence 7_s r i Tw/ 14 here, the motion would have been sustained yesterday. But 15 you have not addressed in any way that I can see the basis 16 of our ruling yesterday, which was that he has given inform- ,
17 ation as to the totality of the fixes as to which no one of 18 those witnesses could testify.
19 And you were given te opportunity to challenge 20 that, if that is in fact the case. We have had by way of 21 background, and I do not know to what extent you have shared 22 this experience, but we have had many times frustrations in-i 23 volved when'a panel of witnesses or a witness appears and 24 his or her testimony is so narrow that you don't get an over-25 view and I think myself it is rather helpful to have somebody O
G I
I
6140
() 1 here who is prepared.to defend an entire area and is prepared 2 to bring it together and make himself available for cross-3 examination to determine whether there is any gap, any weak-4 ness in the overview analysis. And I think it is respon ive 5 to a problem which is frequently seen in these hearings.
6 I think if you wanted to take the time you could 7 have yesterday when it offered, gone through and excised the 8 parts which were purely summary. But that would not have 9 done much as a matter of fact. It would have just taken the 10 context out o f the testimony. You are not prejudiced by 11 pure summary.
12 (Counsel conferring.)
13 JUDGE SMITH: I don't recall whether at your
( \
k s# 14 motion we struck the statement that -- about the overview 15 summary or not.
16 MR.GALLO: During the argument I did say, Judge, 17 that if Mr. Salvage was bothered by the word " summary," that 18 I would stipulate to strike that word. It seemed to me that 19 the witness has quite clearly state his purpose at the bottom 20 of page five of his testimony, the first paragraph of answer 21 6.
22 MR. THOMAS: Answer 6 is the very summary -- on 23 page 4 he has asked what the purpose of his testimony is:
24 "The purpose of my testimony is to pro-25 vide an overview summary of the other Westinghouse
(
(
6141 O
\s,) I witness' testimony on the panel with respect to 2 these issues."
3 MR. GALLO: It goes on to the next page. Your 4 Honor, I just don't see any purpose being served by our con-5 tinuing to debate this issue.
6 MR. THOMAS: I would agree with that.
7 MR. GALLO: It is a matter for the-Appeal Board.
8 It seems to me the witness is here. He is prepared to answer 9 questions and they ought to be asked.
10 JUDGE SMITH: Mr. Thomas has pursued it. He seems 11 to be perplexed by the ruling, and I just wondered if we 12 really understood his concern, and I want to give him full 13 opportunity.
\' 14 BY MR. THOMAS:
15 Q Mr. Butterfield, Mr. Hitchler in his testimony 16 has mentioned generic emergency response guidelines prepared 17 by Westinghouse. Has Ceco reviewed these guidelines?
18 MR. GALLO: Objection. It is beyond the scope of I
i 19 this witness' testimony. Mr. Butterfield talks about the
- 20 narrow question of accepting the recommendation of 21 Westinghouse of the flow-induced vibration modification and 22 his opinion that it will work. His testimony does not ad-23 dress these guidelines that are being referred to by 24 counsel.
25 Beyond that, they seem to be beyond the direct l b V
l l
i
6142 (Ol 4 1 scope of they deal with emergency planning of this particu-2 lar issue.
3 MR. THOMAS: It is not emergency planning.
4 MR. GALLO: That is correct. I stand corrected 5 on that statement.
6 MR. THOMAS: Judge, I think when Mr. Butterfield 7 testified I asked him a few questions this morning, and may-8 be he is not the appropriate person to deal with that ques-9 tion.
10 BY MR. THOMAS:
11 Q Mr. Fletcher, can you respond to that, since you i
12 are our overview person?
13 A Mr. Thomas, you will have to (Witness Fletcher) b' 14 repeat the question.
15 Q Mr. Hitcherl just recently mentioned generic emer-16 gency response guidelines prepared by Westinghouse. Do you 17 recall that reference?
18 A I remember him making that statement; yes.
19 To your knowledge, have those been submitted to 0
20 Commonwealth Edison.
21 A I have no knowledge of that.
22 Q Mr. Butterfield, can you answer that question.
23 A (Witness Butterfield) I can answer the question.
. 24 Q Have they been submitted to Commonwealth Edison?
4 25 A Yes, they have.
G
6143 O
V B-5 1 Q And has Commonwealth Edison reviewed them?
2 A Yes.
3 0 And what did that review consist of?
4 A Commonwealth Edison is a member of the 5 Westinghouse owners' group, has been ever since its formation.
6 -part of that owner's group is a subcommittee called the 7
procedure subcommittee, a member of that procedure subcomit-8 tee is a member of Commonwealth Edison Company. As a member 9
of that subcommittee this person has been reviewing or workinc 10 with these procedures in? Westinghouse over the past several 11 years through the owners' group.
12 The procedures, as they are developed, are pre-13
,3 , sented to the utility industry and seminars. Members of
14 Commonwealth Edison who are involved in writing and devel-15 oping procedures have been in attendance at those seminars.
16 This is an ongoing evolution of procedures and has involved 17 literally hundreds of thousands of manhours of both utility 18 and Westinghouse participation.
19 So we get those, Commonwealth Edison gets those 20 procedures as they are completed and distributed to members 21 of the Westinghouse owners' group.
22 Q Have those procedures been modified to make them 23 specific to Bryon in any fashion?
24 A To my knowledge those procedures have been used 25 as a basis for the development of the Byron plant specific
6144 O
- Q B-6 1 procedures. Now these procedures are specifically related to 2 what I will call emergency procedures, not normal operating 3 procedures.
4 5
6 E-22 7
8 9
10 11 12 13 14 l
15 16 17 18 19 l 20 21 22 23 24 25 -
I
!O
^'
- ~s e. .
6145 1
()3
( 1 Q Are those procedures in final form at this point?
2 A I am not aware of the present state of the pro-3 cedures. I will state that in terms of the Westinghouse 1
4 Owners Group procedures there is what we call a Rev 0, which 5 was distributed and I believe is the basis for the Byron 6 procedures. The Rev 1 will be coming out this summer. And 7 at some time the station will probably make whatever minor 8 changes are necessary to take advantage of the latest 9 information available.
10 0 On page 4 of your testimony in answer 3 you 11 state that Westinghouse has recommended that Edison expand 12 selected tubes in the preheater region and operate the units 13 with about 10 percent of the feedwater flow and during the 45'v'1 14 steam generator through the auxiliary feedwater nozzle.
15 Is that right?
16 A Yes, sir.
17 0 I take it at this point, based on our previous 18 testimony here, that that simply has been an oral 19 recommendation from Westinghouse, is that correct?
20 A That is correct. c 21 Q And in fact, you were not aware of the letter 22 or you have not received yet the letter that Mr. Timmons 23 alluded to this morning?
24 A I personally would not receive that. I am not i
25 the project manager, nor am I in the project engineering l
o 1
t l
b 23 pv 2 6146
/~S h 1 group.
2 Q But to your knowledge, neither has Commonwealth 3 Edison received any written recommendation at this point, 4 is that correct?
5 A To my knowledge, that is correct. May I explain, 6 that h for the final fix. As Mr. Timmons indicated, 7 there have been communications back and forth with respect 8 to setting up meetings and discussions. There may have 9 been written requests for meetings which may have alluded 10 to the fix. I am not aware of them, but they may exist.
11 Q In that same answer you indicate that expand 12 selected tubes in the preheater region. Do you know which 13 tubes?
d 14 A As'I indicated previously, I am aware of a 15 general envelope of tubes, the identity of the exact tubes 16 I am not aware of.
17 Q And what d o you mean by the general envelope of 18 the tubes?
19
( A Mr. Timmons testified to you that a while ago 20 that the tubes were to be selected from essentially along 21 the T-slot ~and the front row, I believe he called it.
22 That, in my opinion, satisfactorily envelopes what I 23 understand to be the area.
24 That's what you mean by the general envelope?
Q 25 A Yes, sir.
iO 1 -
6147 6148 b)
\_/ 1 Q Do you know how these tubes are going to be 2 expanded?
3 A Yes, sir.
4 Q And how is that?
5 A What Westinghouse characterizes as hydraulic 6 expansion.
7 Q How does that work?
8 A That information is proprietary.
9 MR. THOMAS: I think basically we are at the 10 point in the proceedings, Judge, where a large percentage 11 of the remaining questions are going to get into the 12 proprietary area. I think we have come up to the point of
- fT 13 the fix itself.
i k -) 14 JUDGE SMITH: Okay. Do you know the answers 15 to these questions? Did you discover them?
16 MR. THOMAS: No. The answers, as I understand j 17 them, have not even been discoverable. I don't know the 18 answers to these questions. This is a fix that is still 19 developing really.
20 JUDGE SMITH: Just a minute 21 (Board conferring.)
22 MR. THOMAS: Judge, did you mean -- go ahead.
23 (Board conferring.)
24 MR. THCMAS: Did you mean did I ask somebody 25 these questions during a break and discover like that?
/~%
( k V
l
~
o 23.pv 4 6149
(). 1 JUDGE SMITH: We had suggested that before we 2 go to an in camera session that you might wish to informally 3 determine whether you really want the answers or-the answers 4 are helpful to you. However, that would leave the Board 5 out of it too.
6 MR. THOMAS: Right. We are such a central area 7 on this whole thing that it is very important that this 8 be made of record whether the answer helps me or not.
9 I don't know whether it is going to help me or not, but I 10 think it is very important --
11 JUDGE SMITH: You may not know until later in 12 any event.
13 MR. THOMAS: Right.
14 JUDGE SMITH: You don't have any other 15 examination that you can conduct other than your in camera?
16 MR. THOMAS: Basically I don't have any other 17 ' examination. When I conclude the in camera session around
- 18. the fix itself, I anticipate that I will be finished with 19 the panel.
20 JUDGE SMITH: All right.
21 MR. THOMAS: I would certainly object to starting 22 the in camera session the first thing tomorrow, whatever 4
23 the Board's feeling is on that. I don't know.
24 How long do you think it will take?
25 MR. THOMAS: I would say an hour, maybe an hour l
+ - - - .__ . _ _ _
bE23 pv 5
~
6150 1
f3
(,,/ 1 and a half.
2 JUDGE SMITH: All right. What is the pleasure 3 of the parties?
a 4 MR. GALLO: I have no objection.
5 MR. GOLDBERG: I have no objection, Judge. I 6 just want to, given the sensitivity of the issue yesterday, 7 that maybe Mr. Thomas can really consider whether he needs
- 8 Proprietary information to try his case.
9 MR. THOMAS: I need the information on the fix, 10 on the modification. If Westinghouse regards that as 11 Proprietary, then I need proprietary information.
i 12 JUDGE SMITH: Is there a possibility it could be 13 handled as a proprietary exhibit?
b)
\s_/ MR. THOMAS:
14 I am not sure what a proprietary r
15 exhibit is.
16 JUDGE SMITH: Confidential paper saying -- I 17 see no advantage to that at this juncture.
la MR. GOLDBERG: The only point before we become l
', 19 encumbered with a process that we had some concerns about t
20 yesterday, I guess without testifying, I am not really 21 certain that Mr. Thomas has really ascertained the need 22 for the information or if has some indication of what he L
23 really wants that is going to further the public evidentiary l record that we have already assembled.
24 25 We have had a description of the modification,
\_-
i i
. . , - , _ . . _ . . . _ . _ _ _ _ . - . . _ _ . _ . . _ _ . _ . _ _ _ . _ _ _ _ . . _ , , ,_ __.._._._....__......_,,,,,m_ r , _ . _ -
F D 23 pv 6 6151 n(,,/ 1 and over a day of examination on it, what it constitutes.
2 And I think all we are really going to get into is finite 3 details that may or may not be of any probative value.
4 JUDGE SMITH: How do we know until we do it, 5 though? That is the problem.
6 MR. GOLDBERG: I guess that's all.
7 MR. PEDERSON: I am with the Rockford Register 8 Star. Our lawyer is not here,but we understood yesterday 9 that any questions that wem going to elicit proprietary 10 answers would be entered on the record so that the record 11 of the proceeding would include the questions but not the 12 answers.
13 JUDGE SMITH: Oh, no, that was a misconception.
\>/ 14 It will be on the record of the proceeding. It will be 15 available for this Board to make findings on and for review 16 boards and the courts to look at. It will not be made 17 publicly available, and that includes both the questions I end 23 18 and the answers.
19 l 20 21 22 23 24 25 l0
6152 24-1 1
,f s MS. PEDERSON: That was apparently a misunderstandinc Ys ,) 2 that all heard, our lawyer, my executive editor and myself.
3 JUDGE. SMITH: It may be possible that some of l
4 1 the questions might not be proprietary, but that succeeding 5
questions might very well be if they are predicated upon 6
castcade of proprietary answers, and I have no way to 7
excise the transcript that wall.
s MS. PEDERSON: Okay. The newspaper has not desired 9
to try to limit the proceedings or the extent of the questions to and answers, but we do wish to protect the public's right 11 to know what areas were covered in in camera.
12
~
JUDGE SMITH. Well, I do not know what assurance
_* f'%.
h 13 jw ,/ we can give you that we will take out of the in camera 14 section the areas covered. I think you already know the 15 areas covered. They have ccate right out up to the specifics 16 in the'open session. It is the specifics now that are going 17-to be covered in camera, as I understand it.
18 You just learned, for example, an hydraulic expansior 19 process, and I would expect what we hear in camera tomorrow 20 will not make very good reading for the Sunday Supplements.
21 MS. PEDERSON: I would like to reserve che right 22 ,
in case the editor and the lawyer wish to come to the session 23 tomorrow.
rg a 24
( ; JUDGE SMITH: We will do our best to assure that 25 the testimony received tomorrow is limited to oroprietary
I 6153 2
1 -information and does not go wandering off into non-proprietary
/
()h . a directions.
3 MS. PEDERSON. Thank you.
4 MR. THOMAS: Judge, maybe that is another reason s to begin tomorrow to give them a chance to make any additional e record they might want to make in this regard if they were 7 under some kind of misapprehension of the ruling.
s JUDGE SMITH: All right. I think we ought to 9 start tomorrow anyway, and we will ask tomorrow that the io parties be particularly cooperative and sensitive to limit si the in camera session to only that which is essential for
.i2 in camera and not following the natural temptation to go i3 back into public stuff and bring that in.
(}
i4 I have completed.
is MR. GALLO: I wonder if we could have identification 16 of who_is going to be here with Mr. Thomas so that we can ,
l 17 see what kind of protective agreements we need to have signed?
is The Judge ruled that Mr. Thomas does not need one. Mr.
is Bridenbaugh has already signed one and Ms. Chavez has, too.
20 MR. DAVIS: If I might, we have a protective 2 agreement in hand here ready to be signed. The earlier 22 Protective agreement that Mr. Bridenbaugh and Ms. Chavez
- 23 signed was limited to discovery, used during discovery and, I
j 24 hence, is outdated at this point.
O' 25 So I would suggest that anyone, especially that c_
~6154 24-3
' .is identified as a party'to this proceeding, other than the
/^s a
\s , NrC staff and the utility, who wishes to be present during an in camera session and have acess to that transcript, see me perhaps after this proceeding this evening or the first 5
thing tomorrow before the in camera sessio so we can make the arrangements.
7 MR. THOMAS: We will do it tonight so we can a
get here tomororwe and get underway and do not have to do 8
that tomorrow morning.
'O We of course have no objection to these agreements.
JUDGE SMITH: I know, but is there a problem 12 to the number of representatives of theparties attending?-
s 13 JUDGE SMITH: Maybe I am asking a gustion that
/\~-)
'd does not-have to be answered. Do you have a concern about
~
the number of the parties attending, representatives?
MR. DAVIS: Your Honor, I.saw it as being counsel
" for those partis which have counsel and perhaps one o::
18 at most two technical advisers to that counsel or representative. I was anticipating fewer than six or 2
seven.
21 JUDGE SMITH: I think we will have to have at 22 least one member of the interverting organization present, 23 ego, I
24 l MR. DAVIS. Of each intervening organization?
('m
\_- **
DAARE is one and SAFE is another, and the League is another.
l i
L
- _ . _ _ _ . _ _ . _ = . . . - - _ -_ -. _ _ ..
i 24 4 6155 i
JUDGE SMITH: At least one representative --
+
O 2 I don't know, but more than just counsel and technical 3
representatives. The client has to be heard. too.
4 L
MR. DAVIS: We are prepared to recognize that 3
reasonable request.
I 6
, JUDGE SMITH: Anything further?'
- - 7 (No response.)
e
, JUDGE SMITH: We will begin at 9 a.m. tomorrow 9
in this room in an in camera session.
to (Whereupon, 4:50 p.m., the hearing in the 11 above-entitled matter was adjourned, to reconvene at j 12 9:00 a.m., Wednesday, April 27, 1983.)
i 13
( *
- w 14 15 16 i
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18 19 20 21 22 23 24
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6156 CERTIFICATE OF PROCEEDINGS 2
3 This is to certify that the attached proceedings before the 4 NRC COMMISSION 5 In the matter of:
6 Date of Proceeding:
7 Place of Proceeding:
8 were held as herein appears, and that this is the original 9 transcript for the file of the Commission.
10 Barbara Whitlock 11 Official Reporter - Typed 12 f
Official Reporter - Signature 34 15 16 17 l
18 19 20 l
l l
21 22 23
,- s
% )
25 TAYLOE ASSOCIATES REGISTERED PROFESSION AL REPORTERS NORFOLK, VIRGINIA