ML20206C391
| ML20206C391 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/08/1988 |
| From: | Pollard R HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE, UNION OF CONCERNED SCIENTISTS |
| To: | |
| Shared Package | |
| ML20206C372 | List: |
| References | |
| OL-1, NUDOCS 8811160259 | |
| Download: ML20206C391 (15) | |
Text
_ _ _ _ _ _.
C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Ada.inistrative Judges:
Sheldon J. Wolfe, Chairman Emmeth A. Luebke Dr. Jerry Harbour
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. ! -443-OL-1 OF NEW HAMPSHIRE, et al.
)
bO-443-OL-1
)
(On-Site Emerguncy (Seabrook Station, Units 1 and 2
)
Planning and Safety
)
Issues)
November 8, 1988 SECOND AFFIDAVIT OF ROBERT D.
POLLARD I,
Robert D.
Pollard, do make oath and say:
1.
I am a Nuclear Safety Engineer for the Union of Concerned Scientists.
A statement of my qualifications is l
contained in paragraphs 1. through 5. of my affidavit filed '.n this proceeding on September 16, 1988.
2.
The purpose of this affidavit is to respond to the Board's Order, dated October 25, 1988, requiring, inter alia, affidavits "specifically and in detail responding to the affidavits attached to Applicants' response of September 28" and l
"spacifically and in detail address (ing) pages 8 through 10 of the NRC Staff's Inspection Report No. 50-443/88-10.
ORDER, October 25, 1988, at 2.
3.
After observing the licensee's annual full-participation emergency exercise performed June 28-29, 1988, the l
l 00111602b9 001109 PDR ADOCK 05000443 C
s i
NRC inspection s,tm reported that "[t]he Technical Support Conter (TSC) and Emergency Operations Facility (EOF) staff displayed questionable engineering judgement and/or did not cocognize or address technical concerns."
NRC Inspection Report 50-443/88-09, page 5, attached as Exhibit A to my prior affidavit.
The NRC gave five examples to support this conclusion.
I have addressed each of these examples in successive paragraphs of this affidavit.
4.
Since the NRC portrayed the five items as only examples, I conclude that there were additional instances during the exercise where conduct of the TSC and EOF staff provided further support for the NRC's conclusion regarding poor engineering judgement and failure to recognize or address technical concerns.
However, since the NRC has not provided i
in"ormation about these other instances, I am prevented from providing an assessment of their significance.
Emergency Feedwater System (EFW) 5.
One of the examples cited by the NRC to support itu conclusion was that "[elfforts continued to restore the Emergency
[
Feedwater Pump after a large break LOCA."
Id.
j f
6.
The licensee claims that, after a large break loss-of-(
coolant accident (LOCA) was postulated, efforts to repair the inoperable EFW pump were continued because "these efforts would l
not affect other ongoing LOCA response activities," and "to assure a backup heat temoval method if a need for future use I i i
b
Q i
arose, even if a current need was not perceived."
Affidavit of i
i Gary J. Kline, page 4.
7.
The NRC, relying on C. J. Conklin, a different Stanior Emergency Preparedness Specialist than the one, E.
Fox, who actually participated in the exercise inspection and observation, now says that the "licensee correctly stated that the EFW pump would be required to operate to aug. port steam generator cooldown l
in the recovery phase and continued repair efforts were prudent."
MT.. Inspection Report 50-443/88-10, page 8, emphasis added.
NRC also claims that "the inspector apreos and determined that the stated uctivity did not detract from the overall recovery effort, nor did it diminish other high priority recovery action in progress or planned, and cnat TSC judgments were made with long-term recovery in mind."
Id.,
emphasis added.
I 8.
With respect to the claims by both the licensee and the NRC that EFW might be required in the long term, I believe that l
they are invalid.
In a large break LOCA, there is little if any l
l potential for usefully employing an EFW pump, in either the short term or the longer term recovery phase.
In a large break LOCA, the emergency core cooling systems can refill the reactor vessel with additional water spilling out the large break in the reactor l
coolant system piping.
Therefore, no reactor coolant can be
(
r circulated through the steam generator tubes and smergency r
feedwater would be of no use in removing heat from the reactor
(
coolc.it or the reactor ccre.
Steam generator cooldown is not
[
required during long term recovery from a large break LOCA and l
the new NRC inspector gives no explanation for his contrary
(
r I L i
r
O s
belief.
The steam generators would slowly cool down on their own by heat loss through the insulation.
While efforts to restore the EFW pumps would be required in the very long term, i.e.,
during the months prior to resuming operation, such efforts are of no utility during the time period following a large break LOCA which was covered by the exercise.
l 9.
The new NRC inspection report does not indicate how t.it inspector "determined" that the irreievant EFW purp activities I
did not detract from the overall recovery w! fort.
In fact, as explained below, the licensee failed to make sufficient efforts i
to locate and isolate the release path, an important par; of the recovery effort.
10.
In sum, neither the NRC's revised inspection report nor t
Mr. Kline's affidavit explains or mitigates the conclusion in the first NRC report that the continued efforts to restore the EFW pump were an examp?.o of questionable engineering judgment and/or the failure to recognize and address technical concerns.
i l
Containment Building Spray (CBS) 11.
Another txample of deficient technical judgment was the "questionable fix" for the Containment Building Spray (CBS) j system.
NRC Inspection Report 50-443/88-09 at page 5.
}
i 12.
Gregg Sessler, the individual who coordinated the development of what the NRC origins 11y called a "questionable fix," attempts to explain the NRC's conclusion as the result of i
"the constraints of the exercise on communicating with observers l
Affidavit of Gregg F. Sessler, page 5.
He also claims, i l l
I
(.
4 t/aderstandably, that the flow path he developed was "tecnnically sound" and that, in any event, it was a "contingency plan" which would not have been im.slemented without NRC approval.
Id., pages 5-6.
13.
The licensee apparently convinced the new NRC inspector of the soundness of Mr. Sessler's judgment because the second NRC inepection report accepted the alternate CBS flowpath as a "last resort" measure.
NRC Inspection Report 50-443/88-10, page 9.
14.
As an initial matter, neither the original NRC inspection team nor the latest NRC inspector nor Mr. Sessler himself give any details about the equipment and flowpath used for this "last resort."
Without additional information, no assessment of its validity can be made.
Moreover, the NRC's belated acceptance of the contingency plan as a "last resort" is unavoidably inconsistent with its first assessme..t.
The NRC's first inspection team sutely must have known that the contingency plan was a last resort and yet they concluded nevertheless that it was "questionable."
Finally, if the initial NRC conclusion is accurate, the safety issue is not resolved by dependencu on the NRC ultimately to prevent the employment of a contingency plan fourided on poor engineering judgment.
Location and Isolation of Release Path 15.
Another axample noted in the first NRC inspection report was tris "lack of effr t to 1ccate and isolate the release path."
NRC Inspection Report 50-443/88-09, page 5..-
e-O 16.
Gary Kline, another member of the TSC who participated in the' exercise, claims that "a concerted and planned effort was made to locate and isolate the source of the containment bypass leakage (i.e.,
the release path)," and that "the source of the leak was initially isolated to the containment enclosure ventilation crea.
" Affidavit of Gary J.
Kline, pages 5-6.
He goes on to say that efforts were made to further isolate the release and that entry to the electrical penetration area wne not made due to high radiation levels.
Id.,
page 6.
17.
The licensee told the new NRC inspector of these efforts leading him or her to conclude that the NRC's original seven-member inspection team "was unaware of these activities during the drill."
NRC Inspection Report 50-443/80-10, page 9.
The NRC further concludes that the postponement of entry into the containment enclosure was justified by the imminence of the restoration of the CBS pump.
Id.
18.
These explanations are not persuasive for several reasons.
First, it is a significant overstatement to claim that time release path was "isolated" to the containment enclosure ventilation area because this area includes "the electrical penetration area, the enclosure building annulus, the enclosure area ventilation room, the mechanical penetration area, the equipment vaults and the charging pump cubicles."
Affidavit of i
Gary J.
Kline, page 6.
19.
Second, the fastest and most effective way of terminating a release le to isolate th6 leakage path.
Contrary to the suggestion of the NRC in its second report, restoration of 6-
I 3
O the CBS pump could not have "stopped the release."
NRC Inspection Report 50-443/88-10, page 9.
The CBS system, by reducing containment pressure and washing radioactive material from the containment atmosphere, would reduce the rate of radioactive material release, but not terminate it.
- Thus, locating and iso.1.ating the release path should have received a higher prierity than attempting to restore the CBS pump.
In any event, efforts to locate and isolate the release path were particularly impor. ant given the repeated delay (through controller intervention) in CBS pump restoration.
20.
In addition, although Mr. Kline specifically cites high radiation levels outside only one area -- the door to the electrical penetration area -- he nevertheless claims that a review of the radiation data "for these areas" justified postponing entering other aroas within th9 containment enclosure ventilation area.
Affidavit of Gary J.
Kline, page 6, emphasis added.
Hownver, the licensee does not provide sufficient information to judge whether its decision not to expend further offorts to locate and isolate the release was acceptable.
l 21.
Finally, no explanation has been offered for why the original NRC inspection team present during the exercise noticed none of the claimed efforts to locato and isolate the release path.
Steam Generator Blowdown 22.
Another of NRC's examplos of questionable engineering judgment was the lack of effort "to blowdown Steam Generators to I
lessen the heat load in containment."
NRC Inspection Report 50-443/88-09, page 5.
23.
Mr..Sessler states that the control room operators and TSC staff recognized that the Emergency Operating Procedures called for blowdown of the steam generators.
Affidavit of Gregg F.
Sessler, pages 6-7.
He also acknowledges that these procedures ware not followed and characterizes that failure as a temporary postponement to allow an assessment of the level of radioective material in the steam generators.
Finally, he offers a post-exercise rationale for not blowing down the steam generators that the rate of heat transfer between the containment atmosphere and the insulated steam generators was insignificant and "the potential reduction did not warrant immediate depressuriration without further evaluation of potential radiological consequences.
Id.,
pages 7-8.
24.
The new NRC inspector ochoes the licensee's claim that the steam generators were not blown down "because the TSC staff was unsure of the integrity of the S/G tubes because no sample was available due to blowdown system isolation."
NRC Inspection Roport 50-443/88-10, pages 9-10.
The "NRC position" is that although "improved guidance to the operator may be warranted,"
the decision not to blowdown the steam oonorators "appears to have been reasonable and appropriato."
Id.,
page 10.
25.
These explanations are technically invalid and may indicate a fundamental lack of understanding of the behavior of the Seabrook Station during a large break LOCA.
The only l
possible way to have a level of radioactive material on the 1.-
secondary side of the steam generators that would justify l
postponing blowdown for fear of the radiological consequer.:en would be a significant primary to secondary leakage path through the steam generator tubes.
However, if such a leakage path existed during a large break LOCA (the exercise scenario), the leakage flow would not be from the reactor coolant system to the secondary side of the steam generators.
Rather, the flow would be from the secondary side of the steam generators through tne tube leakage paths into the primary system and out the large break.
Thus, although tubes leaks could raise concerns about the radiological consequences of steam generator blowdown during some accidents, tube leaks do not raise such concerns during a large break LOCA.
26.
Furthermore, assuming that the licensee's staff had genuine reasons to be concerned about the integrity of the steam generator tubes, blowdown was all the more important in order to reduce the containment heat load.
Rather than being limited to the small heat transfer through the steam generators' insulation to the containment atmosphere, the containment hett load would be t
i substantially increased by the hot secondary water leaking through the steam generator tubes and out the large primary l
system break directly into the containmont.
Radioactive Release Rate 27.
The fifth example of questionable engineering judgment and/or failure to recognize and address technical concerns is the failure of both the LOF and TSC staff to question "a release of 9-
. qp '
- %; QI w 4;;;
3ff it
, i in
'n greater than 7000 cur!.es per second with only clad damage and no y
a:
core uncovery."
NRC Inspection Report 50-443/88-09, page 5.
0; l'
28.
James MacDonald claims that the TSC staff did indeed question and discuss the lack of correlation between the release condition and core cooling indications.
Affidavit of James A.
3 e
'MacDonald, page 3.
i 29.
The second NRC report likewise says that the logs in fact revealed that several of the licensee's staff membern questioned and/or commented on the mismatch.
NRC Inspection Report 50-443/88-10, page 10.
30.
There is no explanation given for why the first NRC I
6 ll inspection team, who observed the drill and presumably had access l
to the exercise logs, reached a conclusion diametrically opposed to the second NRC inspector.
In any event, I agree with the second NRC report that more effort should be made in developing an exercise scenario where the postulated core damage and releaso rates are consistent.
Id.
However, the actual scenario used in the June 28-29, 1988, exercise postulated conditions which were mutually exclusive on technical grounds.
Thus, it is of questionable validity to use the results of that exercise to I
determine whether the licensae's staff "demonstrate (d) the l
ability to analyze station conditions, parameter trends and develop potential 7,olutions for placing the unit in a safe, l
i stable condition."
1988 FEMA /NRC Graded Exercise at 2.2-2.
l r i
}
l
e Conclusion 31.
The affidavits of Messrs. Kline, MacDonald and Sessler and the NRC Inspection Report 50-443/88-10 are not sufficient to resolve the "weaknesses" identified in NRC Inspection Report 50-443/88-09.
Furthermore, they do not alter my original conclusion that the exercise objective was not met because onsite emergency response staff did not demonstrate an "ability to analyze station conditions, parameter trends and develop potential solutions for placing the unit in a safe, stable condition."
In my view, these matters involve significant safety issues which have not been resolved.
Signed under the pains and penaltjes of perjury this seventh day of November 1988.
District of Columbia City of Washington ss:
/
Robert D.
Pollard Sworn and subscribed,before me this 8th day of November, 198,8, ashington, D.C.
c\\,-,
HARI SINGH I 6>
Notary Public g, c;,,.uba s g m M m h 14,1 m My commission expires' 11 -
s i
UNITED STATES OF AMERICA totKL;ED UNC NUCLEAR REGULATORY COMMISSION 10 N7/10 A11:07 crou
)
00CXtide.
ti. ' f.
In the Matter of
)
N'Mk"
)
PUBLIC SERVICE COMPANY
)
Docket No.(s)
OF NEW HAMPSHIRE, EI AL.
)
50-443/444-OL-1
)
(On-Site EP)
(Seabrook Station, Units 1 and 2
)
)
CERTlELCATE OF FIERY 1CE I,
Stephen A.
Jonas, hereby certify that on November 9, 1988, I made service of the within MEMORANDUM OF JOINT INTERVENORS IN RESPONSE TO OCTOBER 25, 1988 ORDER OF LICENSING BOARD, by first class mail, or by Federal Express as indicated by (*] or by Telefax as indicated by
[**]
to:
Alan S.
Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Thomas S. Moore Docketing and Service Atomic Safety and Licensing U.S.
Nuclear Regulatory Appeal Panel Commission U.S.
Nuclear Regulatory 1717 H Street Commission Washington, DC 20555 East West Towers Building 4350 East West Highway Bethesda, MD 20814 1
l L
Administrative J3dge Robert Carigg, Chairman Sheldon Wolfe, Chairman Board of Selectmen Atomic Saferp.and Licensing Town Office Board Panal Atlantic Avenue U.S. Nuc1'sar Regulatory North Hampton, NH 03862 Commission East West Towers Building 4350 East West Wighway Bethesda, MD-20814 Administrative Judge Diane Curran, Esquire Emmeth A. Luebke Andrea C. Ferster, Esquire 4515 Willard Avenue Harmon & Weiss
. Chevy Chase, MD 20815 2001 S Stteet, NW / Suite 430 Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merril, EsqtG re Atomic Safety and Licensing Attorney General Board Pt,nel George Dana Bisbee, Esquire U.S.' Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 0?301-6397 Bethesda, MD 20814 Adjudicatory File Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Docket Office of General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building One White Flint North, 15th F1.
4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852 Atomic Safety and Licensing Robert A.
Backus Appeal Board Panel Backus, Meyer & Soloman U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box S16 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr. J.
P.
Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, NE 04333 Paul McEachern, Esquire Thomas G.
Dignan Matthew T.
Brock, Esquire Ropes & Gray Shaines & McEachern 225 Franklin Street 25 Waplewood Avinnue Boston, MA P.O. Box 360 Pottsmouth, NH 03801
w Mrs. Sandra Gavutis Mr. Calvin A.
Canney
- Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801 Senator Gordon J.
Humphrey R.
Scott Hill-Whilton, Esquire.
U.S. Senate' Lagoulis, Clark, Hill-Washington, DC 20510 Whilton & McGuire (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950 Senator Gordon J. Humphrey Mr. Edward Molin one Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbuty, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC. 20472 Gary W.
Holmes, Esquire Richard A.
Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 Judith H. Mizner, Esquire Charles P. Graham, Esquire 79 State Street, 2nd Floor Murphy and Graham Newburyport, MA 01950 33 Low Street Newburyport, MA 01950 Lando W.
Zech, Jr., Chairman Thomas M.
Roberts, Commissioner r
U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission One White Flint North One White Flint North
~
11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Kenneth M. Carr, James R. Curtiss, I
l Commissioner Commissioner l
l U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory l
Commission Commission i
l One White Flint North One White Flint North i
11555 Rockville Pike 11555 Rockville Pike l
Rockville, MD 20852 Reckville, MD 20852 l
1 l
m'
.g Kenneth'C.. Rogers, William C.
Parlor, Esquire Commissioner
' General Counsel U.S.. Nuclear Regulatory Office of-the General Counsel Commission-
~
One White Flint North One' White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD '20852 Rockville,-MD' 20852 9
Marjorie'Nordlinger, Esquire-Emile Julian.
Deputy Ge; eral Counsel Chief, Public Documents Room Office of the General Counsel 0.S. Nuclear Regulatory Commission
.One White Flint. North Washington, DC 20555 11555 Rockville Pike.
Rockville, MD 20852 r
,/Ca
\\
/
j~[g
/[./
' Stephen A. Jonas Deputy Chie{
Public Protection Bureau Department of the Attorney General One Ashburton Place I
Boston, MA 02108 (617) 727-2200 L
DATED:
November 9, 1988 i
f 1
i
[
l 4
i I
i l-t I
t
.