ML20215D033
| ML20215D033 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/03/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#486-1177 OL, OL-1, NUDOCS 8610100590 | |
| Download: ML20215D033 (200) | |
Text
UN11ED STATES O
NUCLEAR REGULATORY COMMISSION
~
ORGXAL IN THE MATTER OF: DOCKET NO: 50-443 OL 50-444 OL PUBLIC SERVICE COMPANY ONSITE EMERGENCY PLANNING OF NEW HAMPSHIRE, et al. AND TECHNICAL ISSUES l
(Seabrook Station, Units 1 and 2)
O .
LOCATION: PORTSMOUTH, NEW HAMPSHIRE PAGES: 878 - 1027 DATE: FRIDAY, OCTOBER 3, 1986
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j OfficialReporters 444 North Capitol Street Washington, D.C. 20001 Po 101 oo % , ' (202) 347-3700
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NATIONWTOE COVERAGE
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1 UNITED STATES OF AMERICA
'f.p) 2 NUCLEAR REGULATORY COMMISSION
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3 BEFORE THE ATOMIC. SAFETY AND LICENSING BOARD.
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4
'----------------X 5
In the' Matter.of: :
- ~ Docket Nos.-50-443-OL' 6- PUBLIC SERVICE COMPANY OF :- .
5 0 -4 4 4 -OL '.
NEW HAMPSHIRE, et al. : -Onsite Emergency Planning ~
7
- and. Technical Issues (Seabrook Station, :
- 8. Units 1 and 2)- :
9
X 10 Howard Johnson's Motor Lodge Interstate Traffic Circle 11-
-Salons A'& B Portsmouth, New Hampshire 12 Friday, October 3,~1986 13 O(/ -
The hearing in the above-entitled matter: .
14 reconvened at 9:00 a.m.
3 15 BEFORE:
16 -
SHELDON J. WOLFE, Chairman 17 Atomic Safety and Licensing Board Nuclear Regulatory Commission 18 Washington, D. C. 20555 19 EMMETH A. LUEBKE, Member
- Atomic Safety and Licensing Board ,
y Nuclear Regulatory Commission Washington, D.C. 20555 21 JERRY HARBOUR, Member g Atomic Safety and Licensing Board Nuclear Regulatory Commission 23 Washington, D. C. 20555
, 25
. _ _ - ~ _ . . _ _ . . ,. ._ --__- - - _ , , . , _ . . . . _ - -_.. _ .-_- _._.._..
8 879
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1' ' APPEARANCES:
jr') 2 On Behalf of'the Applicant:
N/
.3 THOMAS G. DIGNAN,'ESQ.
KATHERINE A. SELLECK, ESQ.
'4 Ropes & Gray 4 225' Franklin Street 5 Boston, Massachusetts 02110 6 On Behalf of the NRC:
7 SHERWIN E. TURK, ESQ.
ROBERT PERLIS, ESQ.
8 Office of the. General Counsel Nuclear Regulatory Commission s Washington, D.C. 20555
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10 'On Behalf of the State-of New Hampshire:
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11 . GEORGE DANA-BISBEE, ESQ. _
Senior Assistant Attorney General
. 12 Office of the Attorney General State House Annex 13 Concord, New-Hampshire
. g,; On Behalf of the Seacoast Anti-Pollution League:
15 ROBERT A. BACKUS, ESQ.
JANE DOUGHTY, ESQ.
16 Backus, Meyer & Solomon 111 Lowell Street
- - j7 Manchester, New Hampshire 03105 18 On Behalf of the Commonwealth of Massachusetts
,-aI
, j 19 CAROL SNEIDER, ESQ.
g Assistant Attorney General l 20 Department of the Attorney General 3 One.Ashburton Place, 19th Floor ql Boston, Massachusetts, 02108 ,
21 3
E On Behalf of the New England. Coalition on huclear 22 Pollution:
23 DIANE CURRAN, ESQ.
24 Harm'on " & Weiss 20001 S Street, S.W.
(s 25 Suite 430 Washington,- D.C. 20009
880 Sim 1-3 1 C_ O_ N_ T E,N T_ S
'~) '2 WITNESS: DIRECT ~ CROSS REDIRECT RECROSS BOARD . DIRE 1 VOIR RICHARD ECKENRODE j .(Resumed) ~ ' 885' 978 996 '984 5
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EXHIBITS EXHIBIT NO. ~
IDENTIFIED '
ADMITTED 10 SAPL-No. 2 896
- 11 SAPL No. 3 913 1016 (Limitationn) 12 Commonwealth No. 1 958 .959 Commonwealth No. 2 961 964
.I_si
.13
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SAPL No. 4 1019 14 15 LAY-IN DOCUMENTS 16 Follows Page SAPL Cross-examination plan for the
)7 NRC Staff on SAPL Supplement Contention 6 918 18 Commonwealth Exhibit 1 960 19 Commonwealth Exhibit 2 964 20 SAPL Exhibit 2 1016 21 22 23 Ac
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1 PR0CEEDINGS 2 JUDGE WOLFE: The evidentiary hearing is now in 3 session.
4 Mr. Perlis, do you have a report to make?
5 MR. PERLIS: Yes, Judge Wolfe. We did receive 6 a copy of the draft document this morning from our resident 7 inspector. It was telecopied to him late yesterday from 8 Washington.
9 We have handed a copy to counsel for SAPL 10 approximately 15 minutes before this session began.
11 Just for the record, although we have handed 12 over this draft document, I do want to put the Board and 13 parties on notice that the staff in the future does not 14 intend to hand over draft documents of reports. Under 15 2.790 I don't believe we are' required to.
16 However, in the light of the promise I made to 17 Board yesterday, we have handed over the document in this 18 case.
19 JUDGE WOLFE: Mr. Backus.
20 MR. BACKUS: That is correct. We have just 21 received that report. I presume that we would use the next 22 available recess to compare it with the draft of the final.
23 JUDGE WOLFE: How much time would you need for 24 that?
25 MR. BACKUS: Oh, I don't know. I should think ACE-FEDERAL REPORTERS, INC.
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00000101 882 marysimons 1 probably maybe 10 or 15 minutes, something like that.
2 (Board conferring.)
3 JUDGE WOLFE: We will recess for 10 minutes.
4 If you need longer, we will be standing by.
5 We will have a 10-minute recess.
6 MR. BACKUS: Thank you.
7 (Recess taken.)
8 JUDGE WOLFE: All right, back on the record.
9 In going through the transcript last night, if 10 you have your transcripts before you, after transcript page 11 793, page 796 follows and is out of order. Page 796 12 obviously should come after page 795, and then there are 13 two pages 796. The second page 796 for our purposes, and 14 if you happen to have to cite the second page 796, that 15 will be 796-A.
16 MR. PERLIS: There are two other transcript 17 corrections I would like to make at this time if possible.
18 JUDGE WOLFE: All right.
19 MR. PERLIS: I believe there are two pages 835 20 as well.
21 JUDGE WOLFE: You're right.
22 MR. PERLIS: So the second page there would 23 also be 835-A.
24 JUDGE WOLFE: Yes. The second page 835 should 25 be 835-A.
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( [ marysimons 1 MR. PERLIS: The second correction, and I have 2 discussed this with counsel for SAPL, on page 838 there was 3 a question asked. The question as it reads in the 4 transcript is, "However, I assume you were aware that the
. 5 applicants have filed corrected testimony on this date 6 indicating that that status display malfunctions above five j 7 percent and therefore in all power modes."
8 The question was "now functions," two words, 9 rather than " malfunctions."
10 JUDGE WOLFE: N-o-w?
11 MR. PERLIS: N-o-w space functions.
12 JUDGE WOLFE: All right, the transcript will be 1 13 so corrected, j 14 Mr. Backus.
. 15 MR. DIGNAN: Mr. Chairman?
- I
, 16 JUDGE WOLFE: Yes.
17 MR. DIGNAN: While we are on the subject of the 18 transcript, I' noticed that the transcript at this session 19 has started from page 1. We will be citing to ycu the '83 20 session which of course has pagination from page 1 back 21 then.
22 I was wondering if we could agree on a 23 convention that the '83 transcript will be cited as the 24 transcript and this will be cited as the 1986 transcript 25 because otherwise this ---
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< . 00000101 884 marysimons
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1 JUDGE WOLFE: I was going to give instructions 2 on that, Mr. Dignan. That will follow, and you might keep 3 this in mind, that one of our instructions would be that
- 4 when you cite the transcript for the 1983 hearing that you 5 would preface transcript, or "TR" with one dash, TR, and 6 then your page number, the 1 standing for the original 7 transcript of August 1983.
8 When you cito the current transcript, just cite 9 it transcript page and everyone will know that when you say lo transcript such and such a page that that stands for the 11 current transcript.
12 you are smiling, Mr. Dignan.
13 HMR . DIGNAN: I have got it in the word 34 processor as the other way around.
15 (Laughter.)
16 JUDGE WOLFE: All right, Backus.
i' 17 MR. BACKUS: Thank you, Mr.-Chairman. ,
18 Having had an opportunity to review the draft 19 Lawrence Livermore report with the final, I noted a couple 20 of discrepancies that I would like to see if the witness 21 can discuss, and I wonder if Mr. Perlis could furnish him i
22 with a copy of the draft so I can just direct a couple of 23 questions on that to the witness, f 24 MR. PERLIS: He has a copy of it.
25 MR. BACKUS: Okay, fine.
?
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( marysimons, I Whereupon, 2 RICHARD J. ECKENRODE 3 having been previously duly s:vorn, was further examined and 4l testified as fo1Jows:
5 CROSS-EXAMINATION 6 BY MR. BACKUS:
7 Q Once again, just to make it clear, Mr.
8 Eckenrode, my recollection is you did testify that in 9 answering for the staft our Interrogatory No. 9 and 10 referring to a recommendation made principally by you based 3
11 upon a review of the contractor draft technical evaluation 12 report, that was a reference to this draft report which O)
(. 13 counsel has now furnished to us and which you have with 14 you; is that right?
A That is correct.
15 l 16 Q Just noting the changes, first of all, I note 17 that the change, the first thing there right in the 18 introduction, it refers to on June 19th and 21th an audit 19 of the Seabrook Station parameter display system was 20 conducted by the NRC.
21 I take it that is just a simple error?
22 A Yes, sir. It was May 19th and 21st.
23 Q Next in Se'. tion 3.2.2 on page 5, in the second 24 sentence of that section, the sentence there reads 25 "Although verification and validation reviews are not a ACE-FEDERAL REPORTERS, INC.
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00000101 886 Lmarysimons 1 requirement of Supplement 1 to NUREG 0737, the design 2 problems identified by the NRC -- and here I think I am 3 quoting text that does not appear in the final'from this
'4 point on -- combined with the lack of a formal PSNKV&V
~5 process, led to-the concern that additional design
.6 deficiencies may exist-in the Seabrook SPDS that were not i
i 7 detected by the audit process."
t 8 Now am I correct that that does not appear in
, 9 the final?
10 MR. PERLIS: Objection. Judge Wolfe, the 11 contention-here deals with certain items in the SPDS that i
12 have not been put into place yet and that must be put into
( 13 place by the first refueling outage.
i 14 The question arising from the contention then 15 is whether the plant can operate safety pending the 4
- 16 implementation of those items.
I i 17 I don't object to any questions on this draft l 18 document that relate to the items that are not yet i
i 19 implemented. To the extend that counsel wishes to direct 20 questions on the draft document unrelated to the issue in i 21 the contention, which is those items that have not yet been
! 22 implemented, and this is one of them, we do object as being l
- 23 beyond the scope of the contention and just not relevant i
24 here.
l 25 MR. BACKUS: Well, Mr. Chairman, the testimony L C:) ,
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(~) marysimons 1 furnished by staff, and which is solely sponsored by this 2 witness, did include a final report from Lawrence Livermore 3 in the audit. The witness who was sponsoring that 4 testimony and therefore in support of that final'has now l l
5 indicated that one of his recommendations was based upon a 6 draft of that report which does have some discrepancies in i
7 the final. So it would seem to me that this is very 8 appropriate for cross-examination.
9 MR. PERLIS: Judge, if I may, I ---
10 JUDGE WOLFE: Well, would you address Mr.
11 Perlis' objection on this.
12 MR. BACKUS: Well, I guess the short-response
( 13 to that is that we don't feel the cross-examination, 14 question by question, has to be justified as to the 15 relevance of the contention, but that cross-examination can 16 be directed toward the testimony which this party offered 17 in support of its position on that contention, and that 18 should be the measure of cross-examination as I have always 19 understood it.
20 In other words, if testimony has gone in or j 21 exhibits have gone in that in this case the staff may think 22 have things that go beyond the contention, that does not 23 prevent a party from cross-examining that testimony.
24 JUDGE WOLFE: Now what portion of the audit of 25 August 1, 1986 with respect to what is now in Section 3.3.2 ACE FEDERAL REPORTERS, INC.
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1 goes beyond the contention?
2 MR. BACKUS: I really don't think that any of 3 it does. I think the thing has to be looked at as a whole 4 as to the extent to which it ---
5 JUDGE WOLFE: Well answer my question, what 6 part of it does, any part of this 3.3.27 Now you say that 7 you may cross-examine upon that area. No one disagrees 8 with that.
9 MR. BACKUS: Oh, all right.
10 JUDGE WOLFE: Mr. Perlis, your objection is 11 that portion that is in the draft does not touch upon the 12 issue here?
I
(_/ 13 MR. PERLIS: Judge, it is my contention that 14 the portion cited by Mr. Backus does not touch upon the 15 contention, but I would like to clear up one thing. I 16 would have objected to a question asking about area, I 17 believe it was 3.2.2, had counsel for SAPL directed a 18 question based on the final TER, and if I may explain that.
19 The whole technical document was not put into 20 the record because we agree it is relevant to the 21 contention. It was put into the record because it is part
, 22 of SER Supplement 6. That is the reason the whole 23 technical report is there.
24 As to the objection we made yesterday, we don't 25 believe merely because we are required to put the whole SER ACE-FEDERAL REPORTERS, INC.
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1 into evidence that that.in and of itself makes an item 2 relevant to a contention and therefore open to cross-3 examination.
4 I would also like to make one other point, and 5 that is that Mr. Eckenrode testified yesterday that his 6 conclusion would not have changed had it been based on the 7 final report instead of the draft report. That is an 8 additional reason to object to questions about changes in 9 the draft versus final report, especially when those 10 changes are on an area unrelated to the contention.
11 JUDGE WOLFE: Did I hear you right that you 12 understood Mr. Eckenrode to say that if his testimony had
() 13 been based on the final audit rather than the draft that 14 his testimony would have been the same?
15 MR. PERLIS: I believe that was his testimony 16 on transcript 869, but if you would like to clear it up, we 17 could ask the witness now. Excuse me, 868 at the. bottom of 18 the page and 869.
19 JUDGE WOLFE: The Board is at somewhat of a 20 disadvantage. We don't have a copy of the draft.
21 MR. BACKUS: Perhaps one can be furnished. I 22 think there may be at least one available to the Board.
23 (A copy was furnished to the Board.)
24 JUDGE WOLFE: And we are now looking at 3.2.27 25 MR. BACKUS: Yes. It is on page 5 of both the ACE. FEDERAL REPORTERS, INC.
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1 draft and the final. That section is at the very top of 2 the page on the final and just after the first paragraph in 3 the draft.
4 MR. PERLIS: Just so the record can be clear.
5 We only have four copies of the draft report. I believe 6 they are now in the hands of counsel for SAPL, the witness, 7 myself and the Board.
8 JUDGE WOLFE: Is this a foundation question you 9 are asking, Mr. Backus. Are you going into the 10 deficiencies within the issue as framed by the Board that 11 survived the motion for summary disposition?
12 MR. BACKUS: I believe I am.
13 JUDGE WOLFE: Then I don't understand precisely 14 your objection then, Mr. Perlis.
15 MR. PERLIS: My objection is I believe he is 16 not.
17 JUDGE WOLFE: And on what do you premise that 18 belief inasmuch as he hasn't asked a follow-up question?
19 MR. PERLIS: Because the verification and the 20 validation review that is discussed in 3.2.2 is a separate 21 item from the items that the staff has identified as open 22 items or deficiencies in the SPDS which need to be 23 implemented before the end of the first refueling outage.
24 (Board conferring.)
25 JUDGE WOLFE: Rather than have the reporter ACE. FEDERAL REPORTERS, INC.
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1 read it, if you can recall your question, Mr. Backus, would 2 you pose it once again, please.
3 MR. BACKUS: Yes, and I might just say, and I 4 don't know if this is pertinent to the Board making a 5 ruling,.but I don't expect this to be at all lengthy.
6 The question was, I guess the foundation 7 question, as I recall it was, to direct the witness' 8 attention to-the fact that there was different text in that
- 9 paragraph of this report between the draft and the final, 10 and then I was going to ask some him some questions about 11 the possible significance of that difference.
12 MR. PERLIS: And my objection simply put is 13 that difference has nothing to do with the 11 items of non-14 compliance which are listed on page 5 of Mr. Eckenrode's 15 testimony which, as we understand it, are the elements of 16 non-compliance that make up the contention.
17 (Board conferring.)
18 JUDGE WOLFE: The Board is going to sustain the 19 objection. You must be more specific and precise and I
20 direct your attention to the 11 deficiencies that were 21 encompassed within the paragraph 3 of the Board's 22 memorandum and order of September 15th, 1986. You may 23 explore those in detail, any differences in language 24 between the draft and the final audit report that deals-25 with specifically with these 11 deficiencies.
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- Okay. The record will note an 2 exception to that ruling.
I i 3 JUDGE WOLFE: Mr. Dignan, I will return your 4 copy.
5 MR. DIGNAN: Thank you, Your Honor.
6 BY MR. BACKUS:
7 Q All right, let's turn to item 4.4.1 of the 8 draft under audit team observations. It is on page 8. The 9 draft refers to the reactivity control CFS display consists 10 of 10 horizontal intensity bars and four of the bars are 11 for the steam generator.
12 A Excuse me, you said 4.4.17
- 13 Q 4.1.1. I'm sorry, yes, 4.1.1, page 8.
14 JUDGE WOLFE: That is a carryover then on page
- 15 8. Is this what you are talking about?
4 .
16 MR. BACKUS: In the draft it appears as the 17 first sentence ---
, 18 JUDGE WOLFE: Oh, you are looking at the draft 19 then.
t 4 20 MR. BACKUS: Yes. In the draft it appears in 21 the first sentence in the first full paragraph on page 8.
4 22 In the final it appears in the first sentence of the last 23 paragraph on page 7.
24 MR. DIGNAN: Your Honor, would the Board like 25 to keep one copy of the draft because I sort of don't have i
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( } sarysimons 2 1 a dog in this fight.
2 (The document was handed to the Board.)
3 BY MR. BACKUS:
i 4 Q Do you have those two in front of you?
5 A Yes, sir.
6 Q Now there again there is a discrepancy between 7 the draft and the final, and my question to you is is that 8 simply based upon a mistake of fact and where is the 9 mistake of fact, in the draft or in the final? P 10 A Are you talking about the 10 versus 57 11 Q Yes.
12 A It was mistake in the draft. There are only
() 13 five bars.
! 14 Q And lastly in Section 4.6.1 on page 15, the 15 last sentence of that section, the draft says 16 " Additionally, PSNH is not committed to continuously 17 display the SPDS in the Seabrook control room."
18 And the final says "Furthermore, PSNH has not 19 implemented procedures to ensure the SPDS is always 20 dinplayed on at least one control room CRT."
i 21 Does the difference in language there mean that A
22 by the time the final report was filed there had been some 23 commitment made that was not made at the time the draft was ,
t 24 written?
25 A No.
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() marysimons 1 Q Do you know why the text changed?
2 A We felt that the second writing was much
'3 clearer. Obviously there was no commitment. When'we were 4 there at the audit, the licensee generally does not make 5 commitments at the audit. Commitments are made later. We 6 felt that the statement as stated by Lawrence Livermore was 7 incorrect.and therefore we changed it to a better 1
8 description of the situation.
1 9 Q Now I know you are not with PSNH, but I will 10 ask you whether you are personally aware of whether there 11 is any applicant commitment to continuously display the 12 SPDS in the Seabrook control room?-
13 A I believe that is one of the items, hearing 14 testimony the day before yesterday, that is being looked at 15 right now.
16 Q So you would refer to the testimony that was 17 given by the applicant witness on that point?
18 A Yes.
- 19 MR. BACKUS: In light of the Board's ruling, 20 that is all I have on the document that was furnished to us 21 this morning by the staff and referred to by the witness in 22 Staff Interrogatory Response No. 9.
. 23 By MR. BACKUS:
24 Q Now going back to the staff direct testimony
, 25 and again to the Lawrence Livermore audit final report that ACE-FEDERAL REPORTERS, INC.
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( j marysimons 1 was attached to it at 4.4.1, page 14, the last paragraph, 2 the discussion there again was of the fact that the audit 3 team noticed the Seabrook Station operating staff did not 4 use the lower-function displays, but instead used hard 5 wired instrumentation and hard copies of the CSF status 6 trees, right?
7 A That is correct.
8 Q Now am I correct, Mr. Eckenrode, that those 9 status trees have been furnished to the staff, or examples 10 of them have been furnished to the staff as part of their 11 SBN letter 920 on January 6th, 19867 12 A I will have to look at that letter.
13 Q We would like to furnish you with copies of the 14 pertinent portions that we intend to use of that SBN letter 15 920.
16 A Fine.
17 (Copies of the document referred to were 18 furnished to the Board and the parties.)
19 MR. BACKUS: Now let me represent to you that 20 what we put in front of you and the Board and parties is 21 the cover letter, SBN 920 of January 6th, 1986 that was 22 furnished by the staff in response to a document request, 23 and hard copies of the critical safety function displays 24 from the SPDS.
25 THE WITNESS: Yes, that is correct.
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(; marysimons 1 MR. PERLIS: Excuse me for a second. Could we 2 mark these for identification?
3 MR. BACKUS: Sure. I believe this would be 4 SAPL No. 3 for identification at this point.
5 (The document referred to
) 6 was marked SAPL Exhibit 7 No. 2 for identification.)
8 BY MR. BACKUS:
9 Q Now, Mr. Eckenrode, if we turn to these 10 figures, 4.1-1, 4.2-1 4.3-1 and 4.4-1, would those he 11 examples of the hard copies that would be referred to in i
12 that text from the Section 4.4.1 of the audit team report?
13 A I can't guarantee that they are exact 14 examples. They are similar at least to what they would 15 have used.
1 1 16 One thing that is missing, the actual displays 17 and what the shift technical adviser would do is write on 18 under each of the boxes the actual values that he reads 19 from the meter.
20 Q But by looking at these can we have a pretty 21 good representation, would you say, of what the audit team 22 would be meaning by saying the operators used hard copy?
23 It would be something like this?
i 24 A I believe so, yes.
25 Q It might be on a clipboard somewhere in the i
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,,g 00000101 897 g marysinons 1 room that they would go and get, something like this?
2 A Probably in the desk drawer of the STA.
3 Q Since the RHR flow and containment hydrogen 4 concentration are not on the SPDS, those parameters would 5 also not appear on the hard copies of the SPDS logic 6 diagrams; is that correct?
7 A That is correct.
8 Q In fact, any SPDS parameters not on the SPDS 9 would also not be on the hard copies; is that right? i 10 A That is correct.
11 Q So the SPDS system, even if the operators are 12 using hard copy, would not in any way in its present state 13 direct the operators to look at those parameters, would it?
14 A It is the operators' procedures which direct 15 them to look at thoso parameters and not the SPDS.
16 Q For example, if we look at the first one, 4.1-1 17 and we follow the flow charts, because the system does not 18 have certain parameters displayed, there is no where on 19 this chart or the other charts that an operator is directed
! 20 as part of SPDS display to look at say residual heat 21 removal, for example, right?
22 A That is correct, not from these.
i 23 Q Now isn't it also true that since the j 24 containment isolation is not part of the SPDS system, the 25 hard copies of the logic diagrams would not direct plant i
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1 operators to look at containment isolation display?
2 A That is correct.
3 Q Now Section 3.2 of the audit report discussed !
4 the design verification review, does it not? I believe 5 that is at page 4.
6 A Yes, sir.
7 .Q And does it not state on that page and in that 8 section that the plant SPDS software development had not 9 proceeded by the time of the auditLto the point where 10 validation testing of the critical safety function status 11 determination logic could be done?
12 MR. PERLIS: Objection. I.think here again we
( )- 13 are into the same design verification reviews, and it was 14 not a portion of those 11 items.
15 MR. BACKUS: I think this is certainly within 16 the scope of the contention, Mr. Chairman. The 17 determination of the validation testing of the status tree 18 determination seems to me to be certainly involved within 19 the question of whether or not the SPDS as proposed for use 20 with a licensed condition up to the time of the first 21 refueling is adequate.
22 Plus, I would just again for the record note my T
23 original basis for pursuing this cross-examination that it 24 is on testimony or exhibits furnished by the staff in
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1 , r1 restricted in cross-examining that which has been furnished
, gp 2 by the staff.as evidence in this proceeding.
. 3 . (Board conferring.
4 JUDGE WOLFE: Could you go back to the 5 question, please.
6 (The pending question was read by the 7 reporter.)
8 (Board conferring.)
9 MR. BACKUS: I might note for the record, Judge i 10 Wolfe, that all the question was was whether that was 11 correctly stated to the witness. It was obviously a 12 foundation question, but so we won't have to repeat that 13 all when the next question is asked, the next question 14 would of course have asked the question about the :
15 significance of that.
! 16 JUDGE WOLFE: Objection sustained. The
. 17 question is outside the scope of the issue before the
. 18 Board.
19 BY MR. BACKUS:
20 Q Mr. Eckenrode, was it not the audit team's 21 assessment that Public Service did not fully implement 22 Section 18.2 of NUREG 0800 with regard to the review of the 1 23 system design versus functional requirements?
- 24 MR. PERLIS
- Objection.
25 FROM THE AUDIENCE: Stop objecting.
i 1
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() marysimons 1 JUDGE WOLFE: We will hear your objection. The
]
i 2 audience will please not cause any disturbance.
! 3 MR. PERLIS: The objection is the same 4 objection I raised earlier.- I think we are going beyond-i 5 the scope of the contention here.
6 JUDGE WOLFE: We would like a more detailed i 7 indication of where this inquiry is leading, the purpose
'8 and how this is in any way connected to the 11 deficiencies
.l j 9 which are within the scope of the ---
f 10 MR. BACKUS: Mr. Chairman, I am cross-examining 11 the staff testimony and attached. exhibits sponsored by this J.
4 12 witness, and I don't think the Board can correctly limit 13 that cross-examination by now ---
( 14 JUDGE WOLFE: I am limiting you. I an asking 15 for your statement of the nexus between the question you 16 have put and what is at issue in this litigation.
i
< 17 Now I can ask you that purpose. If you don't 18 answer without more I will sustain the objection.
l 19 MR. BACKUS: Our basic point here is that this l 20 witness apparently has taken the responsibility for the 1
21 staff for justifying the delay of the SPDS being fully l 22 compliant with NUREG 0,737 until the end of the first i-l 23 refueling.
t 24 We find that that position is not supported by l
J 25 this verification and review audit done by Lawrence L ( )-
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1 Livermore Labs which has been added here as an attachment 2 to this testimony.
3 Our contention, I don't think, can be limited 4 to particular deficiencies that have been identified by the 5 staff witness. I think our contention is entitled to be on 6 the system as an integrated part of the control 7 technologies employed in this plant.
8 JUDGE WOLFE: The scope of the issue is defined 9 by the Board in its memorandum and order ruling on the 10 applicant's motion for summary disposition. There are 11 11 deficiencies and absent any explanation from you that your 12 question has any connection with these 11 deficierncies, it
() 13 is outside the scope of the issue.
14 MR. BACKUS: Well, as I understood the Board's 15 order, and the Board is obviously telling us what its order 16 means, there is a question in the Board's mind ---
17 JUDGE WOLFE: It should be clear to you what 18 the Board's order meant, too.
19 MR. BACKUS: As I understand the Board's order,
! 20 we are dealing with in the Board's mind, and it is a ruling 21 we have to accept for purposes of this level of the 22 proceeding, we are dealing with a question of reasonable 23 assurance of whether the SPDS -- well, to be precise, you a
24 have referred previously to the last paragraph of the 25 Board's order.
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1 It says, "SAPL and the Staff and/or the 2 Applicants shall present written explanatory testimony upon 3 the issue of whether or not in light of the fact that the 4 SPDS is not currently at optimum, incomplete, because of 5 the aforementioned deficiencies, there is reasonable 6 assurance that in deferring improvements to the SPDS until 7 the first refueling outage the safety of the population in 8 the immediate vicinity of the plant will be protected."
9 Now whether those deficiencies do present 10 safety functions and whether they may suggest that there 11 are further deficiencies seems to be involved in the 12 matters that are discussed in this report which the staff 13 has offered in support of its evidence and which I think we 14 should be entitled to examine.
15 (Board conferring.)
16 JUDGE WOLFE: The audit report of the Livermore 17 National Laboratory is its complete final audit report, and 18 the staff had every right to offer this in evidence as a 19 complete report.
20 The report in and of itself does not expand the 21 scope of the issue as posed and framed by the Board. you
- 22 might have an objection and could have had an objection if 23 only portions of this report were put into evidence. I 24 believe that as a lawyer you would be the first to ask for 25 the full report, and you do have the full report before l
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1 you.
2 Therefore, it is only those portions of the 3 report that are relevant to the Board's order limiting the-4 scope of the issue as to which you may ask questions.
5 Objection sustained.
6 MR. SNEIDER: Your Honor, if I may add 7 something. I would like to point out to the Board that we 8 did not receive this report until after the Board had 9 defined the scope of this contention. The contention as 10 originally stated stated that there were deficiencies in 11 the SPDS. We could not know the full extent of those 12 deficiencies until we saw the SER Supplement 6 which was
() 13 received after the Board's order.
14 MR. PERLIS: Mr. Chairman?
15 JUDGE WOLFE: Yes, Mr. Perlis.
16 MR. PERLIS: If I may reply to that. The 17 contention was framed without benefit of Supplement 6 as 18 were the summary disposition motion and the response.
19 If intervenors wished to expand the contention 20 after the supplement had been produced, the Commission has 21 a procedure by which a contention can be expanded. I would 22 only add that that procedure has not been followed here and 23 the contention has not been expanded and no attempt has 24 been made to expand it.
25 JUDGE WOLFE: Is that just a comment, Ms.
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2 MR. SNEIDER: As I understand it, the way the 3 ~ contention was originally phrased, it encompassed all 4 deficiencies in the SPDS. It was narrowed by the Board's 5 order and we did not receive the Lawrence Livermore report 6 until-I believe a week ago -- well, sometime within the 7 last several weeks.
8 MR. DIGNAN: May I point out to the Board that 9 the deficiencies pointed out in the Lawrence Livermore 10 -report are the same deficiencies that the Board included in 11 the contention by the references the Board made. The
-12 Lawrence Livermore report is entirely consistent with the
( 13 draft-license which gave rise to the contentions, plus the 14 other matters which the intervenors complained of. The 15 deficiencies are the same in all the reports.
16 JUDGE WOLFE: Well I merely have the comment of 17 Ms. Sneider.
18 MR. SNEIDER: That comment was made in support 19 of Mr. Backus' line of cross-examination, j 20 JUDGE WOLFE: All right, proceed, Mr. Backus.
21 By MR. BACKUS:
l 22 Q I am now going to go to Section 3.3 of.the
! 23 report which discusses validation tests, does it not?
24 A Yes, it does.
25 Q And did not the audit team's assessment
()
1 f
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.{)marysimons I conclude that PSNH should re-evaluate the adequacy of l 4
2 previous validation testing to ensure that the usefulness 3 of the Seabrook SPDS was thoroughly examined?
- 4 MR. PERLIS
- Same objection.
5 MR. BACKUS: It seems to me that the issue of 6 validation of the parameters to be displayed is certainly 7 within the scope of the contention.
8 MR. PERLIS: There is a narrow issue of data 9 validation algorithms. I don't believe that is what this 10 question is limited to.
11 (Board conferring.)
12 JUDGE WOLFE: May we have the question read
() 13 back, please.
14 (The pending question was read by the 15 reporter.)
4 16 MR. DIGNAN: Your Honor, before the Board rules 17 on this objection, may I make another point here. The 18 contention we can all agree, to whatever degree, has been ;
i 19 cut down by the Board by the prior ruling of the Board, 1 20 without getting to the degree.
21 The original contention, the broadest l l
22 contention that ever was in was the Seabrook Station 23 control room design does not comply with general design 24 criteria 19 through 22, 10 CFR Part 50, Appendix A, NUREG 25 9737, Item 1-D-1 and 1-D-2.
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00000101 906 marysimons 1 Now I'think it is undisputed in this matter 2 that the real rules for NUREG 0737 are in NUREG 0737 Sup.
3 1. Everybody has agreed on that.
4 I would direct the Board's attention 5 respectfully to the opening paragraph on page 5 of this 6 report which says in the second sentence "Although 7 verification and validation reviews are not a requirement 8 of Supplement 1 to NUREG 0737, the design = problems" and so 9 forth, and they go on to recommend that one still be done.
10 Now in its broadest form the contention.was 11 seeking compliance with 0737, which means 0737 Sup. 1, and 12 I don't think there is any dispute that 0737 Sup. I doesn't 13 require it.
14 So this thing is not only beyond the narrow 15 contention the Board has left alive, but it is beyond the 16 contention as it was originally framed.
17 MR. BACKUS: We are aware of that language.
18 But it seems to us this bears on the whole question, which r
19 is at the very heart of this matter, of whether 20 implementation of the SPDS can be in the Board's definition
' 21 of it deferred without interfering the requirement, the-22 standard of reasonable assurance.
23 The fact that we have in this audit report the 24 assessment of audit team members that there is a need for 25 further validation testing certainly must bear on that ACE-FEDERAL REPORTERS, INC.
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} marysimons, 1 ' issue.
2 I don't think that we can take bits and pieces 3 out of NUREG 0737 and say that because this bit and piece 4 of it says th.ts that testimony going to the issue of 5 whether thase-parameters have been successfully, or 6 sufficiently I should say validated does not have anything
'I 7 to do with whether the overall requirements of 0737 have i
- 8 been complied with here.
9 (Board conferring.)
10 JUDGE WOLFE: Looking at page 5 of Mr.
j 11 Eckenrode's written direct testimony, Mr. Backus, would fou 12 please connect your question to Mr. Eckenrode's summary of
() 13 the 11 deficiencies that are in issue.
14 MR. BACKUS: I think it would go basically to 15 anything that is shown on the SPDS. I suppose the most 16 precise link-up would be with Item 8, the data validation 17 algorithms may be not be sophisticated enough to ensure 18 validator display to the operator.
19 JUDGE WOLFE: All right, there is the argued 20 nexus.
21 MR. PERLIS: If he wishes to ask a question as 22 to how that finding relates to non-compliance 8, I will 23 withdraw my objection. I think his question was a lot 24 broader than that, and to the extent that his question was 25 a. lot broader than that, I do object.
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l 1 MR. BACKUS: Well, I am going to stand on the 2 question as phrased. I think cross-examination in my l 3 experience has always been intended to be sufficiently wide-l l 4 ranging to bring out the truth without having to sort of l
5 make your final argument on the case in support of every 6 question.
( 7 JUDGE WOLFE: I don't know in what litigation 8 you have been involved, but ---
9 MR. BACKUS: Extensive litigation, Federal and 10 State Courts.
11 JUDGE WOLFE: That is not my understanding nor 12 my experience, it may have been yours, but before this
) 13 Board you have to show a nexus. If there is an objection, 14 you have to show a nexus, or you can withdraw your question 15 and ask a specific question that does fit within deficiency 16 No. 8.
17 MR. BACKUS: I am not withdrawing the question.
18 MR. DIGNAN: your Honor, with respect to the 19 Board's tentative I gather ruling on a nexus to No. 8, may 20 I point out that No. 8 talks about data validation 21 algorithms in the SPDS. The part of the audit report we 22 are talking about talks about a design verification and 23 validation of the system as a whole.
24 With respect to my colleague, Mr. Perlis, I 25 don't think there is even a nexus to No. 8 between the two ACE FEDERAL REPORTERS, INC.
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1 and suggest that the question is out even on that basis 1
2 because the kind of validations we are talking about are 3 totally different things here.
4 One is whether the SPDS does enough validation 5 internally as it operates and the other is talking about 6 validating the review of the system. They are two much 7 different things.
8 (Beard conferring.)
9 JUDGE WOLFE: We find no nexus with the 11 10 deficiencies.
11 Objection sustained.
1 12 MR. BACKUS: There is no need to note
/"N
(_) 13 exceptions on this record, as I understand it.
14 JUDGE WOLFE: No, there is not.
15 MR. BACKUS: So I will go forward.
16 BY MR. BACKUS:
17 Q The field verification tests had not been 18 completed at the time of the audit because the final SPDS 19 software had not been installed; is that correct, Mr.
20 Eckenrode?
21 A Are you quoting the report and, if so, could I 22 please have ---
23 Q I believe we are looking at 3.4 of the report, 24 3.4.1, excuse me.
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() marysimons l 1 objection.
2 JUDGE WOLFE: Same answer?
3 MR. BACKUS: Same question.
4 JUDGE WOLFE: Same ruling.
5 (Laughter.)
6 BY MR.~ BACKUS:
7 Q Has the safety parameter software been 8 installed as of this time, if you know?
9 MR. PERLIS: Objection.
10 'MR. BACKUS: I have nothing further. I stand 11 on the question.
12 JUDGE WOLFE: Same ruling.
13 BY MR. BACKUS:
14 Q Is the NRC going to perform an installation 15 audit of the Seabrook Station SPDS as per Section 18.2 of 16 NUREG 08007 17 MR. PERLIS: Objection.
18 JUDGE WOLFE: May we have that question back, l
19 please.
l l 20 (The pending question was read by the
! 21 reporter.)
22 JUDGE WOLFE: What is your objection to that?
l 23 MR. PERLIS: I apologize. I was anticipating
' 24 what I believe will be a follow-up question. I am going to r
25 withdraw the objection to that question. ?
I C:)
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v marysimons 1 THE WITNESS: It has not yet been determined 2 that we will do a post-implementation audit. We don't do 3 that on all plants. It may be done on this one.
4 BY MR. BACKUS:
5 Q So it is not know when, if ever, one will be 6 done; is that right?
7 A That is. correct. The 11 items will be 8 reviewed.
9 Q Well absent such an audit, how is there going 10 to be an appropriate level of confidence that the data a
11 display will accurately reflect the sensor signal which 12 measures the variable display?
13 A That is one of the 11 items I believe.
14 Q Well that is good to know, but I think the 15 question was calling for something by way of ---
16 A I just indicated on the question before that we 17 would be reviewing the 11 items, and that is one of them.
18 Q Well which one of the 11 items are you 19 referring to then?
20 A I believe you said the data validation item.
21 Q Now what priority does the SPDS have on the 22 process of the main plant computer?
! 23 A Iamnot[surewhatpriorityithas.
24 Q The main plant computer receives inputs from 25 plant instrumentation via nine intelligent remote terminal 4
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i 1 units or IRTUs which then transmit the data to two host l
2 computers which in turn perform SPDS calculations and )
3 develop SPS displays; is that correct?
4 A Would you please refer me to the page you are 5 reading from and I will determine whether it is correct.
- 6 Q Okay. Let me refer you to the next-document 7 that we want to refer to here then, which is the Meeting 8 Summary for Seabrook Station, Units 1 and 2, dated June 9 24th, 1986 that was sent out under the signature of Mr.
10 Victor Nerses, Project Manager, and I am particularly 11 referring to paragraph No. 1.
12 Mr. Eckenrode, before I go to that, I believe 13 you asked me where I got the text describing the transfer 14 of information from sensors to data, and I would refer you 15 on that to the Lawrence Livermore audit at page 2, right in
- 16 the middle of the page under the general heading of safety 17 parameter display systems design overview. Do you see 18 that?
19 A Yes. Your statement is correct then from that 20 report.
- 21 MR. BACKUS
- Now can I please ask to have 22 marked as SAPL Exhibit 3 for identification this meeting 23 summary?
! 24 JUDGE WOLFE: It is so marked.
i-()
(
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1 (The document referred to was 2 marked SAPL Exhibit No. 3 3 for identification.)
4 BY MR. BACKUS:
5 Q Now this June 24th, 1986 meeting summary, now 6 SAPL 3 for identification, notes that during physical 7 inspection of the IRTU terminal cabinet, No. CP-125, the 8 staff found a lack of sufficient separation between 9 electrical cables. Is that right?
10 A If you are~ reading from the report, that is 11 correct.
12 Q Has the staff followed up with a check of the
() 13 other IRTU terminal cabinets to ensure that cable routing
- 14. will not cause a problem?
15 A I'm sorry, I don't see that in the item. I had 16 nothing to do with this letter. So you will have to find 17 what you are talking about.
18 Q Well the question now is a question not on the 19 letter but.to you in light of what is reported in that 20 meeting summary.
21 The question is do you know if the staff has 22 followed up with a check of other IRTU terminal cabinets to 23 ensure that the cable routing will not cause a problem?
24 A No, I do not know.
25 Q Do you know if the identified cable routing ACE FEDERAL REPORTERS, INC.
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{} marysimons 1 defic 2=ncy has been corrected?
2 A No, I don't.
3 Q Now let's look at the host computer for a 4 moment. It performs a check of each input value to verify 5 that it is within the range of the measuring instrument and 6 within " reasonableness limits," is that right?
7 A That's correct.
8 Q And the reasonableness limits are those 9 established by Public Service as the applicant, are they 10 not?
11 A Yes, it is.
12 Q Has the NRC examined the reasonableness
( 13 assumptions that have been adopted by the company?
14 MR. PERLIS: I am going to object at this 15 point. I don't know where this questioning is leading, but 16 it doesn't appear as if it is leading towards the specific 17 SPDS deficiencies which have to be corrected before the 18 first refueling outage.
19 JUDGE WOLFE: No response, Mr. Backus?
20 MR. BACKUS: No. I stand on the question and 21 again stand on the previous arguments made. There is of 22 course reference to this in the Lawrence Livermore Lab 23 report which gives rise to the question.
24 JUDGE WOLFE: Before we rule Judge Harbour has 25 a question.
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U marysimons 1 JUDGE HARBOUR: In looking at the document that
'2 has been marked for identification as SAPL Exhibit 3, Mr.
3 Eckenrode, is it your understand that this document is 4 discussing anything having to do with the SPDS?
5 THE WITNESS: No, sir, it is not.
6 MR. BACKUS: May I ask a follow-up to that, 7 Judge Harbour?
8 JUDGE WOLFE: Sure.
9 BY MR. BACKUS:
10 Q Mr. Eckenrode, don't the IRTU units have to be 11 functional as part of the operation of the SPDS in order to 12 provide input to the SPDS7 13 A Some of them have to be operational to provide 14 input to the SPDS, but they are not part of the SPDS.
15 JUDGE WOLFE: Objection sustained.
16 BY MR. BACKUS:
17 Q Wouldn't the issue of the reliability of the 18 intelligent remote terminal units be related to the 19 availability of the SPDS7 20 A It is my understanding that they were in the 21 calculation for availability, yes.
22 Q And would be relevant to the question of ,
1 23 availability under heavy load conditions?
l 24 MR. DIGNAN: Objection. I don't see how the 25 availability of the SPDS is relevant to the contention 4
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1 before the Board.
2 MR. BACKUS: I would suggest that given the
- 3 rules that we have already had that this would be relevant 4 to Mr. Eckenrode's Item 11, noting once again our position f
5 that this contention is not limited to Mr. Eckenrode's a
6 testimony on deficiencies.
7 JUDGE HARBOUR: Mr. Eckenrode, before we rule, 8 would you explain what you mean when you use the 9 " availability"? Is this a term of art here that we are 10 talking about?
11 THE WITNESS: What was the last part?
12 JUDGE HARBOUR: Is availability a term of art
() 13 used by the engineers for some particular kind of measure?
14 THE WITNESS: It is a' term of art. The 15 definition of availability has never been written down for 16 this case. What we are trying to do is determine the 17 . percent of time the system is up versus down for 18 maintenance, et cetera.
19 MR. DIGNAN: I will then stand definitely on 20 the objection because the item that is Item 11 talks about 21 system response time and what that, as I understand it, 22 means is that you are assuming that the system is
- 23 available. The question is under a heavily loaded 24 condition will it react quickly enough.
25 I believe this particular witness went into O
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_ ,J' marysimons 1 that on cross-examination yesterday. He indicated he 2 thought five seconds was a satisfactory, and if I misquote 3 him I apologize, and that some other time may be too long, 4 and that is what this No. 11 is all about. If everything 5 is loaded up is the system going to react as quickly as it
. 6 should. It is not a question of its being available or 7 unavailable.
8 (Board conferring.)
9 JUDGE WOLFE: May we have the question back, 10 please.
11 (The pending question was read by the 12 reporter.)
13 (Board conferring.)
14 JUDGE WOLFE: Objection sustained.
15 BY MR. BACKUS:
16 Q Has the staff examined the range and 17 reasonableness checks performed by the RDMS?
18 A No, we have not. I'm sorry. As far as this 19 SPDS review is concerned, we have not. It may have been 20 done through another branch in instrumentation or 21 something.
22 Q Mr. Eckenrode, I believe you were here when the 23 applicant's witnesses testified, were you not?
24 A yes, sir.
25 Q And a question was directed to the applicant's ACE. FEDERAL REPORTERS, INC.
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00000101 918 marysimons 1 witnesses about an inadequate core cooling monitor?
- 2. A Yes, sir.
3 Q Do you' recognize that there is such a piece of 4 equipment in this plant?
5 A We consider the inadequate core cooling monitor 6 to be a series of items. It is various pieces of-7 instrumentation.
8 Q It is referred to in the Lawrence Livermore-I 9 report as -- maybe it is a system rather than a single 10 item, but it is referred to there as an inadequate core 11 cooling monitor; is that right?
! 12 A Yes, it is.
I () 13 MR. BACKUS: That is all I have.
14 JUDGE WOLFE: All right. Mr.-Backus, would you 15 please hand to the reporter a copy of your cross-i 16 examination plan for NRC Staff on SAPL Supplemental p
i 17 Contention No. 6 which will be incorporated into the 18 record.
19 (SAPL cross-examination plan for the NRC Staff
) 20 on SAPL Supplemental Contention No. 6 follows:)
) 21 22 1
23 L 24 25 i
i I
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SEACOAST ANTI-POLLUTION LEAGUE'S CROSS EXAMINATION PLAN FOR NRC STAFF i; ON SAPL SUPPLEMENTAL OONTENTION NO. 6 Docket Nos. 50-443-OL 50-444-OL
- 1. Legal Requirement for SPDS Issues to be explored: *
-Requirements for implementation of the SPDS specified by NUREG-0737 Supplement'No. 1
- Proposed schedule for implementat ion agreed upon by NRC Project Manager and licensee
[) - Formalization of proposed schedule as required by NUREG-0737 Supp. No. 1 Subsequent actions by NRC Staff and applicants relative to the schedule for implementatin of the SPDS II. Safety Importance of the SPDS Issues to be explored:
- The lack of compliance of the Seabrook Station SPDS wi th the minimum requirements of NUREG - 0737, Supp. No. 1
- Staf f's view of the saf ety of operat ion between initial start up and the 1st refueling relative to other periods of operation
- Features of the SPDS, as presently const i tuted, which could lead to operator error
- Mode dependency of 2 CSF status trees
- Lack of sophis t icat ion of data validat ion algorithms D
s/
- Usefulness of lower-level SPDS display formats
- Human engineering discrepancies
- System response time under heavy load t
e , ,e , ----,,,n, , --,.~n, , - , . , ,~ , , - - -
,Y
- The importance and safety significance of the missing _ parameter displays /where and how satisfactorily the missing data is otherwise available in the control room.
- RHR Flow
- Containment Hydrogen Concentration
- Containment Isolation
- Stack Monitor
- S team generator (or s teamline) radiat ion Ill.
Design Verification and Design Validation Audit
- Who conducted the audit
- Audit Team Assessments
- System Requirements review
- Design Verification Review
- Validation Tests
- Field Verification _ Tests - when to be done?
(-
N
- How complete the installation of the control room SPDS is at this time.
IV.
Main Plant Computer System
- Priority of SPDS in Main Plant Computer Process
- Cable routing in Intelligent Remote Terminal Units (IRTU's)
- Host Computer Checks of Input values
- RDMS Range and Reasonableness checks O
i l
. 00000101 919
/~i marysimons
(_)
1 JUDGE WOLFE: Ms. Sneider, cross-examination?
2 MR. BACKUS: Note for the record that I have 1 3 handed the plan to the reporter.
4 JUDGE WOLFE: Before you begin, Ms. Sneider, 5 Mr. Backus, you had marked for identification two 6 exhibits. Are these just to follow the record?
7 MR. BACKUS: Pardon me?
8 JUDGE WOLFE: I.se these just to remain marked 9 for identification and. follow the record?
10 MR. BACKUS: I would offer these for admission
- 11. at the conclusion of the testimony of this witness. I was 12 going to make the motion when Ms. Sneider finished her D)
(_ 13 examination.
14 JUDGE WOLFE: We will have a 10-minute recess 15 while Ms. Sneider is reviewing her notes.
16 (Recess taken.)
17 JUDGE WOLFE: Before you begin, Ms. Sneider, I i 18 didn't recall whether your comment came after my ruling 19 upon an objection to a question put by Mr. Backus, whether 20 it came after that or before. I believe your comment came 21 after I made my ruling.
22 MR. SNEIDER: I believe that is correct, Your 23 Honor.
24 JUDGE WOLFE: I would just bring to your l 25 attention that on numerous occasions this Board has advised l l
l
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1 that any new contentions must be timely brought to the 2 attention of the Board and you must meet certain criteria 3 before we could admit such new proposed contentions.
4 All right, go ahead, Ms. Sneider with your 5 cross.
6 CROSS-EXAMINATION 7 BY MS. SNEIDER:
8 Q Mr. Eckenrode, would you agree with NUREG 0737 9 Supplement 1, that prompt implementation of an SPDS is of 10 primary importance?
11 A If that is what NUREG 0737 says, yes, I agree.
12 Q And would you also agree with NUREG 0737 that
()~ 13 prompt implementation of an SPDS provides an important 14 contribution to plant safety?
15 A Yes.
16 Q How would you define the word " prompt," Mr.
17 Eckenrode?
18 A At that time I believe it was meant that of the 19 items in NUREG 0737 that was probably the one that should 20 be done first. We have found that that implementation 21 throughout the United States has been difficult and has 22 taken longer than we would have expected.
23 Q How many licensed nuclear power plants are 24 there in the United States now approximately?
25 l A About a hundred.
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, 1 Q And would you say-that a majority of those
'2 plants have SPDS systems in place?
3 MR. DIGNAN: I am going to object on-the
- 4 grounds of relevance of'the contention before this Board I.
- 5 which is whether the Seabrook SPDS should or should not~
6 have things in place before the first refueling outage, and j 7- I fail to see the relevance of the question as to what 1
8 other plants may or may not have.
9 MR. SNEIDER: Well, the witness testified that 4
10 he was determining what was prompt based on the difficulty 11 that other plants in the United States have had in-12 implementing an SPDS and I was just following up to that
) 13 response.
14 JUDGE WOLFE: Overruled.
15 Answer the question, Mr. Eckenrode, i 16 THE WITNESS: As near as I know at the present 17 time there is no SPDS that is totally operational that has 18 been approved by the staff.
1 19 .BY MS. SNEIDER:
20 Q In your testimony, Mr. Eckenrode, on page 3 you 21 refer to guidance provided to the-staff by the Director of l 22 the Division of Licensing. What guidance are you referring 23 to there?
24 A This is internal guidance by the Director of 25 Licensing to his project managers and to his staff.
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1 Q Could you tell me the date of that guidance?
2 A No, I don't have the date.
3 Q An approximate year?
4 A It would have been between the issuance of 5 NUREG 0737 Sup. 1 and probably the April 15th, 1983 date.
6 Q Well since NUREG 0737 Supplement was issued in 7 January of 1983, then it would be safe to say that the 8 guidance was issued in 1983; is that correct?
9 A I believe that is correct, yes.
10 Q Is that guidance in written form?
11 A Yes. I believe it is an internal memo to the 12 staff.
( 13 Q Could we be provided a copy of that guidance 14 since you do refer to it in your testimony?
15 A I don't have a copy here.
16 MR. SNEIDER: Your Honor, the Commonwealth 17 would request that the staff provide a copy of such 18 guidance since it is referred to in the testimony.
19 MR. PERLIS: My problem with that request is 20 the testimony was given out some time ago. Had the 21 Commonwealth desired a copy of the document, I think now is 22 a late time to bring it up.
23 MR. SNEIDER: We received the testimony just 24 last week, on Tuesday of last week to be precise.
25 MR. DIGNAN: Mr. Chairman, I go with the staff ACE-FEDERAL REPORTERS, INC.
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1 on this one. There is nothing wrong with the telephone 2 system, and the staff historically has been extremely 3 cooperative if people call them up and say, gee, we would 4 like you to bring that document with you.
5 I think to make the request at the lith hour of 6 the lith day as they say is out of line.
7 JUDGE WOLFE: Certainly we try to accommodate 8 the wishes and requests of all parties. We do think that 9 it is quite late in the day for you now to ask for the 10 presentation of this document.
11 Mr. Perlis, do you have a copy in hand here of l 12 this guidance by the Director of the Division of Licensing
) 13 referred to at page 3 of Mr. Eckenrode's ---
14 MR. PERLIS: I am not certain of that. I may.
15 If the Board likes, I could check.
16 JUDGE WOLFE: Yes.
17 (Pause.)
18 MR. PERLIS: I have a larger document of which 19 that memorandum is attached, yes.
20 JUDGE WOLFE: It is part of a larger 21 memorandum?
22 MR. PERLIS: The guidance itself is not part of 23 a larger document, but I have it attached to something 24 else.
6 25 JUDGE WOLFE: Do you have any objection to ACE-FEDERAL REPORTERS, INC.
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J marysimons 1 furnishing the guidance to counsel for Massachusetts?
2 MR. PERLIS: The only objection I have is if 3 Massachusetts wants to'ask questions on the document I 4 would like to have a copy of the document in front of me 5 and I only have one copy. I don't object to showing it to 6 them, no.
7 JUDGE WOLFE: All right. Well hand it to Ms.
8 Sneider and you may sit alongside of her if she has any 9 cross-examination and read it along with her.
10 (The document was shown to Ms. Sneider by Mr.
11 Perlis.)
12 (Pause.)
() 13 JUDGE WOLFE: Have you finished reading the 14 guidance Mr. Perlis provided to you, Ms. Sneider?
15 MR. SNEIDER: Yes, I have. I am ready to 16 continue.
17 BY MS. SNEIDER:
18 Q Mr. Eckenrode, where that guidance refers to 19 plants with proposed implementation dates after fuel load, 20 I take it is referring to plants in 1983, the year the 21 guidance was issued, that were close to be licensed?
22 A No, I don't believe that is correct. I think 23 it is any implementation that was proposed after the 24 memorandum was put out.
25 Q The date proposed for implementation of O
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marysimons 1 Seabrook's SPDS was originally in 1983; is that correct?
2 A I believe that is correct, yes.
3 Q And the date subsequently proposed for 4 implementation and accepted by the staff was June 30th, i
. 5 19867 6 MR. DIGNAN: I object. I thought we settled 7 the question of whether we were going into the history of 8 the staff / applicant negotiations yesterday, Your Honor. l 9 MR. SNEIDER: Your Honor, I am just trying to 10 get at whether the proposed implementation date for the 11 Seabrook SPDS was before or after the' proposed date of fuel 12 loading which goes directly-to the witness' testimony and- 1
() 13 to this guidance that was issued.
14 MR. DIGNAN: It may or may not go to the 15 guidance that was issued, Your Honor, but it doesn't go to 16 -the contention that the Board has left in this case.
.17 MR. SNEIDER: Your Honor, I would also like to 18 add that Mr.'Eckenrode states that he made the decision to l
19 allow deferral of correction of these deficiencies based in 20 part on this guidance, and I think it does go to the issue 21 of whether it is a safety concern.
1 22 ,
JUDGE WOLFE: What was the date of this 23 guidance?
24 MR. PERLIS: June 1983.
. 25 JUDGE WOLFE: June 1983.
1
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() marysimons 1 MR. PERLIS: I believe it is dated June 1st,
, 2 1983. Ms. Sneider has my copy and.she could confirm that.
3 MR. SNEIDER: June 1st, 1983.
4 JUDGE WOLFE: Overruled.
5 THE WITNESS: Would you please ask the question 6 again, Ms. Sneider.
7 BY MS. SNEIDER:
8 Q The date subsequently proposed for 9 implementation and accepted by the staff was June 30th, 10 19867 11 A Yes. That was based on an expected fuel load 12 date.
( 13 Q Well, the proposed date for implementation was 14 not after the date scheduled for fuel load, was it?
15 A No, not originally.
16 Q Well, as a matter of fact, Mr. Eckenrode, isn't 17 it true that this guidance states that the negotiation 18 process for implementation dates should be completed by 19 July 1st, 19837 2C MR. PERLIS: Your Honor, I am going to object.
21 MR. DIGNAN: I object.
22 JUDGE WOLFE: Yes, this is getting into the 23 area of history, and the Board has already ruled that this 24 is not relevant.
l 25 Sustained.
l () -
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(),marysimons 1 BY MS. SNEIDER:
2 Q ' Going back to my previous question, your 3 testimony doesn't say anywhere that for those plants with 4 proposed implementation dates before fuel load that the 5 guidance authorized the imposition of license conditions in 6 lieu of completion of an SPDS, does it?
i 7 A Would you rephrase that, please.
1 8 Q Your testimony states, and I will quote, the ,
9 Director's guidance further stated that in those instances 2
10 where proposed implementation dates were after the date for
, 11 fuel load licensed conditions were to be imposed for all 12 those commitments that were not yet implemented at the time
( 13 of issuance of an operating license." Is that correct?
14 That is what your testimony states.
15 A Yes, that is correct.
f 16 Q Well the guidance does not say anything about 17 direct or authorize that conditions can be imposed in lieu 18 of completion of an SPDS in those instances where proposed i
19 implementation dates are before fuel load; is that correct?
i 20 MR. DIGNAN: I am going to object until the i
21 document is marked for identification, I have got a copy of 22 it and I can follow this examination. We are talking about 23 a guidance document. There is one copy in the room. The 24 document I assume speaks for itself if it is relevant and 25 now we are asking the witness whether or not it says 4
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1 something.
2 MR. SNEIDER: Perhaps I could. rephrase the 3 question.
4 BY MS. SNEIDER:
5 Q Your testimony does not any where state that in 6 those instances where proposed implementation dates are 7 prior to fuel load that licensed conditions may be imposed 8 in lieu of completion of an SPDS, does it?
9 MR. DIGNAN: I object. The testimony speaks 10 for itself. It is a written document.
11 JUDGE WOLFE: Sustained.
12 BY MS. SNEIDER:
O)
(_ 13 Q Mr. Eckenrode, in your testimony you note that 14 the Seabrook SPDS is deficient in 10 respects, is that so?
15 A I count 9 of the 11 that show deficiencies. 10 16 and 11 I believe are not necessarily deficiencies yet.
17 Q All right. I will accept that.
18 Nevertheless, you do conclude that those 19 deficiencies need not be corrected until the first fuel 20 reloading; is that correct?
21 A That is correct.
22 Q One of the bases in your testimony for that 23 conclusion that the deficiencies need not be corrected 24 until the first fuel loading ---
25 A Excuse me, Ms. Sneider. I think you said first ACE-FEDERAL REPORTERS, INC.
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.( [ marysimons 1 fuel loading, and I think it is the first refueling.
2 Q Yes. 'I stand corrected.
3 Now as one of those bases you state that the 4 Seabrook SPDS should not increase the potential for 5 operator error.
6 A That is correct. That is what we are required 7 to review based on NUREG 0737.
8 .
Q Isn't the purpose of an SPDS aus stated in NUREG 9 0739 Supplement 1 to decrease the potential for operator 10 error in the event of an abnormal occurrence?
11 A. Yes, it is.
12 Q So the fact that the SPDS does not-increase the l 13 potential for operator error is not really relevant to your 14 determination of adequacy, is it?
15 A Our reviews look at both conditions. Obviously 16 we have to go with the requirement to make sure it doesn't 17 increase the potential for non-safety.
18 Part of the review also, if you will continue 19 in 0737 is to determine that the licensee has done an 20 adequate analysis process and work to develop their SPDS.
21 That is also part of the-review which goes to the other 22 half of your question I believe.on the reduction of the
. 23 chances for error.
. 24 Q By the way, Mr. Eckenrode, when did you conduct ;
. 25 the onsite audit of the Seabrook SPDS? )
l l (~)T
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.1 A May 21 to 23 I believe 1986.
2 Q And until that point you did not know the full.
3 extent of the deficiencies of the Seabrook SPDS, did you?
4 A No.
5 Q But isn't it the case that you had already 6 concluded a month earlier in April 1986 when you issued the 7 safety evaluation status report for the Seabrook Station 8 -SPDS that any deficiencies identified during the audit 9 review by the staff would not need to be implemented until 10 the first refueling outage?
11 A We knew enough about the system based on the 12 safety analysis report delivered to us in January that they
) 13 had a system that we have looked at before at other plants 14 and knew that the system in that respect would be in 15 reasonably good shape by plant startup.
16 Q But you really didn't know this with respect to 17 the Seabrook SPDS?
18 MR. PERLIS: Objection. That has been asked 19 and answered.
20 JUDGE WOLFE: I understood that to be the 21 thrust of this last answer.
22 THE WITNESS: Yes, Your Honor.
23 JUDGE WOLFE: All right.
24 BY MS. SNEIDER:
25 Q As another basis for your determination that ACE-FEDERAL REPORTERS, INC.
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1 the deficiencies in the Seabrook SPDS need not be corrected 2 until first fuel reloading, you state "The information not 3 presently available on the SPDS is available elsewhere in 4 the control room." Is that correct?
5 A Yes, ma'am, as is all of the information on the 6 SPDS.
7 Q Isn't the purpose of an SPDS that there be one 8 concise display in the control room where all the critical 9 safety parameters are displayed?'
10 A That is the purpose of SPDS. ,
11 Q And why is that, Mr. Eckenrode?
12 A In the lessons learned from Three Mile Island h- 13 we know that a control room is rather large and that the 14 , information on the safety related equipment is spread 15 throughout the control room. The purpose of the SPDS was 16 to bring the major things together to show a general 17 picture of the safety of the plant.
18 Q And I take it that is the reason that NUREG l 19 0737 Supplement 1 states that an SPDS is supposed to be in i
20 addition to other control room equipment?
21 A That is correct.
l 22 Q I fail to understand then, Mr. Eckenrode, the l 23 basis for your determination that completion of the l
l 24 Seabrook SPDS can be deferred -- or perhaps you can explain 25 the nexus between the fact that the other parameters are I
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1 available elsewhere in the control room, the ones that 2 aren't on the SPDS, how that relates to your decision to 3 defer the Seabrook SPDS?
4 A The SPDS as it stands is a fairly good SPDS, 5 fairly complete. There are some things on it that are not 6 yet complete. In other words, when they start up it will 7 be operating. It just will not be operating to the full 8 extent.
9 Q Mr. Eckenrode, now would you define the word 10 " minimum"?
11 A In respect to what, ma'am?
12 Q In your testimony you state that the staff has
) 13 identified a minimum set of approximately 20 plant 14 purameters it believes to be sufficient to provide plant 15 operators with information about the critical safety 16 functions specified in NUREG 0737 Supplement 1.
17 A The minimum set that we are talking about here 18 is, as you say, is about 20. One can take a particular 19 parameter and find two other types of parameters, two other 20 parameters in the control room that will supply the same 21 information to the operators.
22 So in this case we have looked at the minimum 23 set. We expect that the information needed by those 24 parameters that are missing will be available to the 25 operators.
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l' Q' Okay. Are you saying that a display that has 2 less than 20 minimum parameters would not adequately inform r
3 plant operators of all of the critical safety functions?
4 A The critical safety functions that we are 5 dealing with also I would say have a time variable or a 6 mode variable.
4 7 The items that we are missing, the RHR, for 8 instance, is not something that would be used immediately 9 upon an accident. So they have all of the information 10 that is required up to that point on the SPDS. The general 11 picture of the safety of the plant is there.
12 Q But actually, Mr. Eckenrode, you found the
() 13 Seabrook SPDS acceptable with only three-quarters of those 14 minimum parameters in place; isn't that correct?
15 A I don't think we have said the Seabrook SPDS is
- 16 acceptable yet. So there are things that have to-be done.
17 Q But acceptable for-the period before first fuel 18 reloading.
19 A yes.
20 Q Why is the SPDS not acceptable for the period 21 of-operation after first fuel reloading and it is
- 22 -acceptable now?
i 23 A It is a matter of trying to get the other items
- 24~ that should be in the SPDS completed in a reasonable time.
1 25 Th9 SPDS is acceptable to a level even beyond that. It is l
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00000101 934 marysimons
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1 just a matter of the degree of acceptability. We would 2 like it to be 100 percent or 110 percent maybe. It is 3 about 80 to 90 now.
4 Q What are you basing that determination on that 5 it is 80 to 90 now?
6 A The number of parameters is what we are 7 discussing I believe now. If we talk about 20 parameters, 8 the two that are missing.
9 Q Well I believe your testimony states there are 10 five missing.
11 A I think we also agreed that several of those 12 are being put in now.
) 13 Q Do you have personal knowledge of that?
l l 14 A The RDMS display is being put in, and we had a 15 date I believe for the radiation parameters to be put in, r !
16 The containment isolation, for instance is already there.
17 Q Do you have personal knowledge of that?
18 A I have not got documents from PSNH yet to
! 19 verify that, no.
l 20 Q So that is based on hearsay then?
21 A It is based on the evidence of the licensee 22 two days ago. That is all it is based on.
23 MR. SNEIDER: Your Honor, I would like to move 24 to have stricken from the record the witness' testimony as 25 to what parameters or displays are now in the control room ACE FEDERAL. REPORTERS, INC.
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1 that he does not.have personal knowledge of.
-2 JUDGE WOLFE: I think the record can speak for
, 3 itself. You may continue your cross-examination, but I 4 think it should be a matter of record. And to the extent 5 that he has no knowledge, that will come through.
i 6 BY MS. SNEIDER:
7 Q Mr. Eckenrode, you have testified that an SPDS 8 is necessary to aid the control room operator in rapidly 9 and reliably assessing the safety status of the plant; is 10 that correct?
r 11 A It is an aid in doing that, yes.
12 Q And so isn't it therefore possible that no SPDS
() 13 is on display in the_ control room that an operator might 14 not be-immediately alerted to abnormal plant conditions?
15 A My guess is'the operator would know about the 16 conditions quite a bit before that through his normal 17 instrumentation and alarms.
18 Q Didn't you testify on Wednesday that the SPDS 19 is typically the first indication that something is wrong 20 in the plant?
i 21 A I probably did. It is very difficult to i 22 determine which is going to occur first. I believe an j
23 individual alarm can come on giving that information before 2
- 24 the SPDS shows a general situation.
25 Q But an SPDS would certainly aid the operator to ,
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( ) marysimons ,
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1 immediately assess the condition?
2 A Yes, we hope it will. That is the purpose of 1
3 it. '
4 Q So would you agree then that if an SPDS display 5 was not at all available at a particular time that it could 6 adversely affect the operator's ability to rapidly and 7 reliably determine plant status and to take action to 8 mitigate or prevent an accident?
9 MR. DIGNAN: Object---
10 THE WITNESS: No, I do not believe so.
11 j MR. DIGNAN: The question has been answered.
12 The objection is moot.
13 BY MS. SNEIDER:
14 Q Well, if that is not the case, why do we have 15 this requirement for an SPDS?
16 A The requirement is one item to attempt to give 17 the operators all of the information in several different 18 ways. This is one other way. It is a matter of gather 19 individual parameters and attempting to let a computer put 20 them together to show a total plant picture.
21 Q Is it true that at Three Mile Island, Unit 2, 22 that most of the critical parameters were also on display 23 somewhere in the control room?
24 A Yes, but Three Mile Island also had some other l
l 25 problems with their instrumentation.
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.1 Q Yes, I understand that.
2 Q -Well what then-do you see.as the basis for 3- NUREG 0737 Supplement-l's requirement that an SPDS display -
l 4 be continuous?
i.
i 5 A That the SPDS should be there all of the time
'6 while operating.
d
'7 Q Well you have just testified now that if it is 8 not available it won't adversely affect the operator in any I 9 way. So I am ---
10 A It won't adversely affect the operator. It may 11 improve his indications. ;
1 12 Q Well then if an SPDS display, continuous
() 13 display could improve the operator's ability to assess an
- 14 accident and mitigate it, why have you seen it sufficient' ,
15 to wait until first refueling for Seabrook to have a 16 continuous display? ,
, 17 A As I indicated before, Seabrook does have an 18 SPDS. It is available in the control room. It turns out
- 19 on the continuous items that you are dealing with that they-j 20 have even a more flexible system than the requirement.
+
21 allows. It can be put on any CRT in the control room. All 22 we want to do is make sure it is continuously on one, but 23 they do have an SPDS operating, or they will have it
- 24 operating prior to the first refueling outage.
25 Q Do you have personal knowledge of that?.
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1 A Yes, ma'am, I have been there and seen it.
2 Q Excuse me, could you repeat what you said. Did 3 you just testify that they did have a continuous display; 4 is that what you are saying?
5 A No, I didn't.
6 Q Well, you do agree with the Lawrence Livermore 7 audit report which states that all control room displays 8 could be selected such that no SPDS is provided in the 9 control room?
10 A Yes, ma'am.
- 11. Q And that is why you are requiring as a license 12 condition that the Seabrook SPDS display be continuous
( 13 after first fuel reloading?
14 A Yes, ma'am.
15 Q Is there are reason you are not requiring that is this be a continuous display prior to full power operation?
17 A We believe that the display they have now is 18 satisfactory to the extent that it is available in the 19 control room. We expect that it will be a continuous 20 display eventually and that is satisfactory, yes.
21 Q You have testified that the residual heat 22 removal flow and hydrogen concentration variables are 23 considered by the staff to be part of the minimum 24 information required to assess the critical safety 25 functions; is that correct?
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e 00000101 939 marysimons
'[G~D 1 A Yes.
2 Q Why is it that RHR flow is required to be 3 displayed on SPDS?
4 A I would have to go into my files to-find each 5 reason on each one of the parameters. I don't have that at '
6 my fingertips.
7 Q Let me ask you this. If an operator had an 8 indication of RHR flow when he thought had the RHR system 9 isolated from the reactor coolant system, that could 10 indicate that he had not successfully isolated the RHR 11 system; is that not correct?
i, 12 A I am not sure I can answer that.
13 Q Well, if you can't determine what the need for l 14 RHR flow is, how are you able to determine that the 15 Seabrook SPDS is sufficient the way it is?
! 16_ MR. DIGNAN: I object. The witness did not
- j. -17 testify that he couldn't determine the reasons why he j 18 thought it was necessary. He said he did not have it at 19 his fingertips. The question is without foundation.
4
- 20 BY MS. SNEIDER
i 21 Q Do you have that information with you, Mr.
22 Eckenrode?
23- MR. DIGNAN: May I have a ruling on my i 24 objection, Your Honor.
25 JUDGE WOLFE: Well, I thought you were going to
(
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- 'l - respond to that. Do you withdraw the question?
2 MR. SNEIDER: No, I do not, Your Honor.
'3 JUDGE WOLFE: Sustained.
4 BY MS. SNEIDER:
5 Q Do you have the information available with you 6 on why an RHR flow parameter is required to be displayed on i 7 SPDS?
?
8 A The information on that item is the head of one
, 9 of our reviewers from the former PSRB Branch. We discussed 10 that earlier. The review originally was done by the '
i 11 Procedures and Systems Review Branch and there is a 12 gentleman there who reviewed this item. I would have to 2 () 13 defer to him.
i 14 Q Well, it is accurate to say then that you do
17 A I personally, yes, that is true.
18 Q Mr. Eckenrode, I would.like to understand how 19 you feel competent to testify then that deferral of adding 20 the RHR flow display to the Seabrook SPDS will not pose a
- 21 threat to the public health and safety?
22 MR. PERLIS: Is there a question there?
23 MR. SNEIDER: Yes. I am asking the witness how 24 he feels competent to testify to that?
25 MR. PERLIS: Them I am going to object to the ACE-FEDERAL REPORTERS, INC.
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., V 1 form of the question.
2 MR. DIGNAN: I am going to object on the 3 grounds that a witness is never suppose to testify as to 4 his competence. His competence is a decision for the 5 Tribunal.
6 JUDGE WOLFE: Sustained. You may ask another 7 question in its place.
8 BY MS. SNEIDER:
9 Q I would like to ask what the basis is for your 10 determination that deferral of adding an RHR flow parameter 11 to the Seabrook SPDS will not pose a threat to the public 12 health and safety?
) 13 A The basis is advice from my technical reviewer 14 in that area.
15 Q But is not based on your own personal 16 knowledge?
17 A That is correct.
18 Q Do you know where in the control room the RHR 19 flow parameter is displayed?
20 A It is displayed on two recorders. I am not 21 positive where they are, two separate channels.
22 Q Do you know how the operator's attention would 23 be drawn to those displays?
24 A No, I do not. It certainly would depend on the 25 scenario you are dealing with, and my guess is there are ACE-FEDERAL REPORTERS, INC.
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'V 1 alarms that whatever the condition is that would require 2 that would occur, and it would be somewhere in an 3 operator's procedures as to what he would do.
4 Q But you do not know that for a certainty?
5 A That is correct.
6 Q Now in the event of an accident at Seabrook 7 there are a number of actions the operator would need to be 8 taking to' mitigate that accident I assume; is that correct?
9 A Yes.
10 Q And he would also need to be paying attention 11 to a number of different parameters and displays; is that 12 correct?
( 13 A Yes, that is correct.
14 Q So is it possible that under such circumstances 15 his attention would not be focused on the RHR flow display?
16 A It certainly would be if that were the area 17 that he was involved in and expecting something to happen
, 18 there, yes.
19 Q And so it is true that he might not immediately 20 notice if there was a possible malfunction in the RHR flow i 21 system?
22 A I can't say that.
23 Q Well do you know why the NRC requires that 24 hydrogen concentration variables be displayed on SPDS?
l 25 A I know some about it, but I again would refer l
l
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(~)
v marysimons l' to the reviewer of the parameter.
2 Q Well for one thing do you know what the 3 significance is of a high level of hydrogen concentration 4 in the containment?
5 A I believe I do, but my answer would be 6 speculation. So I would prefer not to.
7 Q Are you aware whether there could be a 8 potential for serious offsite consequences if the operator 9 were not unaware of hydrogen concentration levels?
10 MR. DIGNAN: Could I have that question back, 11 please, Your Honor.
12 (The pending question was read by the 13 reporter.)
14 MR. SNEIDER: Excuse me. I will rephrase the 15 question.
16 THE WITNESS: There were too many negatives 17 there.
18 MR. SNEIDER: You can delete the word "not" 19 from that question. Well I will rephrase the whole 20 question.
21 BY MS. SNEIDER:
22 Q Do you know whether there could be a potential 23 for serious offsite consequences in the event that the 24 operator is not aware of hydrogen concentration levels?
4 25 A No, I do not know that.
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. 1 Q~ _Your answer means you don't know whether or not
'2 there would be offsite consequences?
i-3 'A. .That is correct. .
J 4 Q- Are you aware that one of the problems during
- 5 the accident at Three Mile Island is the fact that'the 6 operators were not aware of the significant hydrogen 7 concentration in the containment?
- 8 A I believe that is correct, yes.
i -
9 Q Do you know where the information on hydrogen i
10 concentration levels is available in the control room?
11 A No, I.do not.
12 Q So you do not know then whether it can be
() 13 readily seen from the STA position in the control room?
14 A I would assume it could not be seen from the i
15 STA position. Again, that is speculation.
a
, 16 Q And do you know whether high concentrations of 17 hydrogen in the containment, whether or not it can lead to j
18 hydrogen explosion?
19 MR. DIGNAN: Could I hear that question back, 20 please, Your Honor.
21 (The pending question was read by the
- 22~ reporter.)
4
, 23 MR. DIGNAN: I object to the form of the ,
24 hypothetical question. There are not enough parameters on
~
25 that question. To say that there is simply hydrogen i
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' marysimons 1 present in large concentrations puts.a broad, broad, broad l
l- 2 hypothetical that I think is well beyond the scope of the 3 contention and too broad a question in any event. A lot of
[
j- 4 other parameters have to be know besides the existing
- 5 hydrogen to have a meaningful and probative answer to kind 6 of a question.
7 MR. SNEIDER: First of all, it is well within 8 the scope of the contention since the contention is whether 9 the. safety of the public offsite, whether there is 10 reasonable assurance that they will be protected.
.11 Perhaps I could narrow the question somewhat.
12 By MS. SNEIDER:
( - 13 Q Do you know whether having high levels of I
14 hydrogen concentration in the containment is-one factor 15 that could lead to a hydrogen explosion?
16 A Yes. Hydrogen is quite a volatile gas.
17 Q Would you say then that is one of the reasons.
, 18 why hydrogen concentration variables are required to be
! 19 displayed on the SPDS?
l 20 MR. PERLIS: Objection. He has already i
i l 21 indicated that he doesn't know why hydrogen concentration i _22 is part of the SPDS.
- 23 JUDGE WOLFE: Isn't so that so, Ms. Sneider?
24 Do you withdraw the question?
25 MR. SNEIDER: Would you reread the question.
1 4
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1 (The pending question was read by the 2 reporter.)
3 -JUDGE WOLFE: Well, I will sustain Mr. Perlis' 4 objection.
5 MR. SNEIDER: Your Honor, this is ---
6 JUDGE WOLFE: I know it is important, but the 7 witness has said he-has no opinion. This was the opinion 8 of his reviewers. So where are we going with the 9 question? It was the opinion or a conclusion of his 10 reviewer, I have forgotten which.
11 THE WITNESS: A technical judgment of the 12 reviewer.
13 JUDGE WOLFE: Thank you.
14 BY MS. SNEIDER:
15 Q On what do you base your testimony that display 16 of hydrogen concentration levels on the Seabrook SPDS can 17 be deferred until first fuel reloading without posing a 18 threat to the public health and safety?
19 MR. DIGNAN: I object to the question as asked 20 and answered and indeed in the direct. I would 21 respectfully draw the Board's attention to page 11 of this 22 testimony.
23 The witness stated his reasons. He said all 24 the information, which includes hydrogen and everything 25 else we have been talking about, that will be added to the O' SPDS is currently available to the operators elsewhere in ACE. FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-336 6646
00000101 947 j } marysimons 1 the control room.
2 While the modifications will improve the 3 quality of the SPDS, these modifications are not critical 4 from a health and safety standpoint, and then he goes on to 5 state the staff's final conclusion.
6 Now this is the uniform testimony of our 7 witnesses and the staff witnesses. What is being relied on 8 here is not an analysis of whether this factor or that f
t 9 factor has more safety significance. It is that the 10 information is there.
11 We have had testimony from Mr. Walsh as to 12 exactly where it is and this witness. A staff reviewer
) 13 can't keep in mind every control room he has looked at.
14 But I suggest this has been asked and-answered and asked 15 and answered, Your Honor, and it is now getting 16 repetitious, and it was answered directly as to what the 17 basis was.
18 MR. SNEIDER: Well, even in that portion of the 19 testimony just cited, Your Honor, the witness testified 20 that this would not pose a threat to the public safety, and 21 I am trying to find out the basis of the witness' own 20 testimony when he states that he is not qualified to 23 testify to that fact.
24 JUDGE WOLFE: I don't recall that that was part 25 of the question.
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100000101 948 d[ .marysimons 1 MR. DIGNAN: I don't either, and I don't recall 2 the witness saying he wasn't qualified to testify to what 3 he testified to. What he said is that he didn't' have in 4 his head the staff reviewer who had made the conclusions 5 that these were necessary.
6 As I understood the thrust of this witnesses 7 expert testimony it was assuming it to be necessary, which 3 he is getting from his reviewer, the fact of the matter is 9 the stuff is all in there anyway and on that basis he 10 concludes it is not critical.
11 Now what we are doing is twisting that into 12 something that the witness has not come up here to say, 13 which is he has not purported to testify as to why the 14 staff is taking the position that this has to be on the 15 system.
16 Indeed, our witnesses made it clear that the 17 staff and applicant aren't even in agreement on that, that 18 they'are in technical disagreement on those matters still.
19 But the witness has made clear the basis for why that makes 20 no difference, which is the availability elsewhere in the 21 control room of the information, and it is that conclusion
, 22 that the witness is prepared to defend, has defended ably i'
23 and should be attacked. The rest of this is irrelevant to i 24 this testimony.
~
25 JUDGE WOLFE: Wel1, I am willing to give i
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'l counsel pretty good latitude. I will sustain the 2 objection. I think we have been over this, but I would 3 suggest that if you want to get into this area-asked 4 pointed questions. Isn't it a fact that.this not being on 5 the display system at this time-that it would be dangerous 6 to the public-health and safety for the following reason, 7 and ask him the questions. Put it to him.
8 You know what his attitude and opinion is. Now 1
9 press him on it and ask him specific questions.
10 but. SNEIDER: I thought, Your Honor, that the 11 witness had already said that he was unable to answer those 12 questions.
) 13 JUDGE WOLFE: In one area.
14 (Board conferring.)
15 JUDGE WOLFE: Mr. Witness, was that your 16 testimony? I understood it was only with respect to the 17 RHR that you could not give n technical judgment on whether 18 or not if it was not in place prior to refueling that it 19 would not present a safety hazard.
20 THE WITNESS: The parameter selection area, 21 which is one of the 11 items, we used Lawrence Livermore as 22 a contractor to review the parameter selection area, and in 23 this case because of the current change order with the NRC 24 staff, we used the former PSRV reviewer to review that l 25 particular item also. And it is their judgment that the ACE-FEDERAL REPORTERS, INC.
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1 i 1. parameters as stated can wait.until the first refueling j 2 outage.
I 3 JUDGE WOLFE: That is with respect to the RHR7 '
4 THE WITNESS: And the hydrogen concentration. I 5 JUDGE WOLFE: Yes. I am speaking about the 6 other deficiencies listed at page 5 of your written. direct 7 testimony. .You have your own technical judgment on the 8 rest of those deficiencies as to why the improvement 9 thereof or the placement thereof can be deferred pending a 10 first refueling.
11 THE WITNESS: Yes.
12 JUDGE WOLFE: I don't understand your response
( 13 to me and Ms. Sneider.
14 MR. SNEIDER: My questions were on RHR flow and' 15 hydrogen concentration variables, which I think are two 16 critical parameters that affect the public safety or affect 17 whether there is reasonable assurance that the public can 18 be protected. My questions were specifically directed to
?
19 those two parameters.
20 (Board conferring.)
21 JUDGE WOLFE: Is it too late to go back to the 22 original question, Ms. Reporter.
23 (The reporter asked for a few minutes recess to 24 find the original question.)
25 JUDGE WOLFE: We will have a recess then in ACE-FEDERAL REPORTERS, INC.
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},marysimons 1 place for three minutes while you find the question.
2 (Brief recess.)
3 JUDGE WOLFE: All right, the hearing is 4 resumed.
l 5 Would you read back the question.
6 (The question was read as follows: On what do-7 you base your testimony that the display of hydrogen i~ 8 concentration levels on the Seabrook SPDS can be deferred
' 9 until the first refueling loading without posing a threat 10 to the public health and safety?)
11 JUDGE WOLFE: Now, Mr. Dignan, you had an 12 objection.
) 13 MR. DIGNAN: I did.
14 JUDGE WOLFE: And you now say that you will 15 rephrase your question. you said you would rephrase it, i
16 but you couldn't remember what you had asked in.the first 7
17 place, isn't that correct?
i 18 MR. SNEIDER: I don't believe I said I would 7
j 19 rephrase it, or if I did, after hearing it, I fail to see-2 l 20 any problem with that question.
21 JUDGE WOLFE: That was my recollection that you 22 said you were going to rephrase or restate it, but you just
, 23 couldn't remember the question. Are ycu now satisfied with t
24 the question?
25 MR. SNEIDER: I am satisfied with the question.
! (:)
i i
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['J.
L 1 (Board conferring.)
2 JUDGE WOLFE: Objection sustained. The basis 3 for the Board's ruling is that this has been explored and 4 it has been asked and answered.
5 MR. SNEIDER: Your Honor, I would like to move 6 to have stricken from the witness' testimony his response 7 to Question 11 since the witness has testified that he does 8 not have the technical competence to make that 9 determination, that deferral of the remaining modifications
- 10 to the Seabrook SPDS,.that it does not pose a threat to the 11 public health and safety.
- 12 JUDGE WOLFE
- What answer is this now, please?
) 13 MR. SNEIDER: Question 11. The witness has 14 testified that he relied on someone else's conclusion who 15 is not being presented as a witness here.
16 MR. BACKUS: I would like to note for the 17 record that I will join in that motion by counsel for the 18 Commonwealth. ,
19 MR. PERLIS: I must admit that I am at a loss 20 if that is her basis for a motion to strike. The witness 21 has testified that in part he has relied upon other 22 people. That can go to the weight of the witness'
- 23 response.
24 I fail to see how it can go to the 25 admissibility of the response. Counsel has been given ACE. FEDERAL REPORTERS, INC.
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00000101 953
(,} marysimons 1 great leeway in exploring the basis for the response. I 2 think the testimony in both the direct and from the cross-3 examination stands, but I fail to see how the fact that he 4 relied in part on someone else's input can serve as a basis 5 to strike his testimony.
6 MR. BACKUS: Judge Wolfe, I think a witness is 7 certainly entitled to rely on other experts within his 8 field. However, as I understand Mr. Eckenrode's expertise 9 as set out in his resume it is in human factors 10 engineering. What we are now talking about is the safety 11 significance of those aspects of plant accident conditions 12 that are not currently displayed, hydrogen concentration O(_/ 13 and residual heat removal.
14 I don't think Mr. Eckenrode can come here and 15 sponsor a conclusion which goes to that aspects of the 16 plant when he does not claim, as I understand it, expertice 17 in that field himself.
18 As I understand it, what he is saying here in 19 this conclusion, and I think I hear counsel for the 20 applicant emphasizing this in some of the objections I have 21 heard, is that the bottom line is he feels that there is 22 not a serious risk or lack of reasonable assurance of the 23 public health and safety because these parameters are 24 elsewhere displayed.
25 That in effect comes close to an attack on a ACE FEDERAL REPORTERS, INC.
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I 1 Commission regulation because that is of course _the case
, 2 and yet there is:still the requirement that these
'3 parameters be displayed on an SPDS in a concise and 4 continuous form so that plant conditions can be rapidly 5 updated.
6 ER) I think that the use of that part of this
! 7 answer to support the ultimate conclusion this witness
+
8 supports does not comport with the underlying Conmission-9 regulation we are involved with here which is of course 10 NUREG 0737 Supplement 1, and that would be the basis on 11 which I would join in the Massachusetts motion.
12 MR. DIGNAN: May I be heard, your Honor. I
__ )~ 13 come back to some of the things I mentioned earlier in the 14 objection.
15 If one reviews the qualifications, my Brother 16 Backus is quite correct, the witness is a human factors 17 engineer and that is what we are here to talk about with 18 this witness. If one reviews the testimony, the witness in l l
19 no way attempts to say that I am the guy who selects what 1
4 20 ought to be in the SPDS.
21 What he is here to tell us is assuming that i
22 something that should be on the SPDS, and that is a i 23 decision, as I understand it, made by the disciplines who i
24 think certain parameters are critical, assuming it should 25 be there, Iamtelbingyouit is not a problem if it isn't l (2) i ACE-FEDERAL REPORTERS, INC.
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00000101 955 marysimons
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1 there for one cycle of the plant because it is somewhere 2 else in the control room.
3 That is all this witness purports to testify 4 to. The human factors engineer, as I understand it, is 5 somebody who is an expert at saying what lights, what 6 buttons and what displays will cause best the operator to 7 reactor correctly. That is all he is testifying to. He is 1
8 an expert.
9 He is not here to make the selection of the 10 parameters. That has been apparently done by other people 11 in the NRC and, as we have admitted in our testimony, we 12 aren't yet in agreement with the NRC whether this parameter
) 13 ought to be on there at all".
14 But the question before you and the question to 15 which the witness is thoroughly qualified in is assuming 16 that it should be there, if it isn't, will the operator 17 still react correctly, and the basis for his testimony is 18 yes, because it is elsewhere in the control room. And the 19 record is unchallenged as to where it is in the control 20 room from our uitnesses and I don't see any problem with 21 the testimony and there certainly is no basis for a motion 22 to strike.
23 MR. SNEIDER: Your Honor, if I may comment on 24 that?
25 JUDGE WOLFE: Sure.
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()
7 marysimons 1 MR. SNEIDER: First of all, if you are saying 2 that the witness' testimony is based on the fact that these 3 controls are elsewhere in the control room and therefore 4 there should be no problem with having these displays on 5 the SPDS, the witness has testified that he does not even 6 know where in the control room these displays are located.
7 So I think if that is all his testimony is 8 based on, that alone would be reason to strike it.
9 More importantly, the witness is testifying 10 that certain items which are required to be on SPDS are not 11 necessary that the public can be protected until first fuel 12 reloading even though they are not on SPDS.
) 13 I think the burden is on the witness then to show, or 14 on the staff to show that it does not pose a problem to the l
15 public offsite and the witness does not seem to be 16 competent to testify to that.
17 (Board conferring.)
18 JUDGE WOLFE: Well, certainly the witness is 19 competent to testify as a human factors engineer. I will 20 sustain the objection, but we upon review of his testimony 21 as well as of any other expert witness make a determination 22 as to what weight to give to his testimony.
23 The motion to strike is denied.
24 How many more questions do you have, Mo.
25 Sneider?
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-%J l MR. SNEIDER: It's a bit.
2 JUDGE WOLFE: I'm sorry?
3 MR. SNEIDER: It is a bit, Your Honor.
4 JUDGE WOLFE: All right. We will adjourn until 5 a quarter of two. ,
2 6 (Whereupon, at 12:45 p.m., the hearing 7 recessed, to reconvene at 1:45-p.m., the same day.)
8 t
9
.i 10 11 I 12 j
13 14 4
i l
15 i 16 17
, 18 19 20
' 21 _ s.
22 i
23 24 25 N
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1 AFTERNOON SESSION 2- (1:45 p.m.)
i' 3 JUDGE WOLFE: All right, the hearing is 4 resumed.-
- 5 Ms. Sneider.
6 Whereupon, 7 RICHARD J. ECKENRODE 8 having been previously duly sworn, was further examined and 9 testified as follows:
~
10 MR. SNEIDER:- I have a document that I would
- 11 like to have marked for identification.
12 (Ms. Sneider passes the document to the Board 13 and parties.)
14 (The document referred to was 15 marked Commonwealth Exhibit 16 No. 1 for identification.)
i 17 CROSS-EXAMINATION (Resumed) 18 BY MS. SNEIDER:
19 Q Mr. Eckenrode, the document placed in front of 20 you marked as Commonwealth's Exhibit No. 1, is that the 21 document which you referred to in your testimony no page 3 22 as the guidance?
23 A Yes.
24 MR. SNEIDER: Your Honor, I would like to move 25 that Commonwealth Exhibit No. 1 be moved into evidence.
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.1 JUDGE WOLFE: Any objection?. ;.
1 MR. PERLIS:
2 No objection. e
+ .
1
.3 MR. BACKUS: No objection.
4 MR. DIGNAN: No objection, Your Honor.
5 JUDGE WOLFE: All right. Massachusetts Exhibit .i 6 1 is admitted into evidence. '
7 (Commonwealth Exhibit No. 1, l 8 previously marked for identifi-t !
9 cation, was admitted into the 10 record.)
11 MR. BACKUS: Gentlemen, might I ask, is it
~
12 going to be possible to have an exhibit like the one just
()I 13 admitted incorporated into the record?
14 THE WITNESS: You would have to give 20 copies i.
i 15 of such an exhibit to the reporter, isn't that.right, if it i 16 is to be incorporated into the record?
a
~
17 (Discussion off the record.)
1;8 JUDGE WOLFE: Well, this could have been 1
L 19 incorporated then as an exhibit because it is very short, a l 20. page and a hal* or so, but that is up-to Ms. Sneider. ,
21 You have to, if it is going in as an exhibit, a 22 separate exhibit and not incorporated into the record, you
+
4 23 have to give three copies to the reporter. l 24 If it is incorporated into the transcript it i 25- becomes part of the record, but whichever you want. To go I -I )
\
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00000101 960 marysimons 1 in separately as an exhibit you give three copies to the 2 reporter.
3 MR. SNEIDER: I gave the reporter three 4 copies. Do I understand that if it is part of the 5 transcript that there only needs to be one copy?
6 JUDGE WOLFE: If it is incorporated into the 7 transcript as Massachusetts Exhibit 1, yes.
8 MR. SNEIDER: I would like it to be 9 incorporated as part of the transcript.
10 JUDGE WOLFE: All right.
11 (Commonwealth Exhibit No. I marked and admitted 12 follows:)
13 14 s
15 16 17 18 19 20 21 22 23 24 25
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- E WASHINGTON, D. C. 20155 8 8/
[,,,, June 1, 19S3 L505-53-05-001 MEMORANDUM FOR: DL Project Managers FROM: Darrell G. Eisenhut, Director -
Division of Licensing
SUBJECT:
EMERGENCY RESPONSE CAPABILITY SCHEDULE NEGOTIATIONS By how, each of you has reviewed your utility's response to Generic Letter 82-33 that was due to be submitted on April 15, 1983. Some have already begun negotiations with the plant owners to develop enforceable schedules. The enclosures to this document provide more detailed guid-ante for the PMs to use in the negotiation process with utilities. A key item is the acceptability of certain schedules .without further negotiations.
This guidance is intended for internal use only. .
O' In general, for those plants that have not yet received an operatinglicens requirements 'in time for the staff to complete its evaluation prior to the fuel load date is acceptable. In order for the staff to complete its licensing review, the, Detailed Control Room Design Review (DCRDR) Summary Report and the Safety Parameter Display System (SPDS) Analysis and Im-piementation Plan should be submitted six mor.ths prior to the fuel load date and the Procedures Generation Package in accordance with Regulatory Guide 1.33 'and Supplem:"r. I to NUREG-0737. For those whose proposed implementation dates are after the fuel load dates, the general process for evaluation of justification and negotiation specified in the enclosures should be followed. In any event, all such comitments are to be made License Conditions if not yet implemented at OL issuance time.
If there are any questions or problems with this process, you should discuss the matters with the lead PMs as early as possible. They are identified in the enclosures and have an established system for elevating any necessary issues for management resolutions.
The next step af ter the negotiations is to put the comitments in an enforceable document. A draft Confirmatory Order is being developed and will be provided to you as soon as it is ready. It should be used for all plants holding a Full Power li:ense.
O
_l
/
DL Project Managers -
2- June 1, 19S3 -
You should complete the negotiation rocess by J ' 1 1983.
i (
'Darrell 2. Eisenhut, Director Division of Licensing
Enclosures:
As stated cc w/ enclosures:
DL A/Ds DL BCs '
NRR Div Dirs ,
- O mee e
- 8 8
, e O . .
G 0
e
,e .
4 O
~
00000101 961 marysimons (J 't 1 MR. BACKUS: I wonder if I could request that 2 our exhibits also be incorporated into the transcript?
3 JUDGE WOLFE: Not if they are not admitted.
4 MR. BACKUS: Well, I was going to move their
{
5 admission in due course.
6 JUDGE WOLFE: Well, let's wait until we get to 7 that point then. j i
8 MR. BACKUS: All right. !
l 9 MR. SHEIDER: At this time I would I?.ke to mark )
j 10 for identification the Commonwealth's Exhibit No. 2.
L i 11 (Copies of the document were distributed by Ms.
12 Sneider to the Board and parties.)
l <
l (_%) 33 (The document referred to was
! 14 marked Commonwealth Exhibit l 15 No. 2 for identification.)
16 BY MS. SNEIDER:
17 Q Mr. Eckenrode, can you identify this document?
18 A Yes, I can.
19 Q Is this the document referred to earlier this 20 morning which I had questioned you on about called the 21 Seabrook Station SPDS Status SER?
22 A Yes, it is.
23 MR. SNEIDER: At this time the Commonwealth 24 would like to move to have admitted into evidence 25 Commonwealth's Exhibit No. 2.
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1 JUDGE WOLFE: And incorporated into the 2 transcript?
3 MR. SNEIDER: And incorporated into the 4 transcript.
5 MR. DIGNAN: Objection, relevance. It is a 6 piece of history.
7 MR. PERLIS: Excuse me, Judge. Before I make 8 an objection or don't make an objection, may I have time to 9 read the document?
10 JUDGE WOLFE: All right.
11 (Pause.)
12 MR. PERLIS: If the Board waiting for me now?
() 13 JUDGE WOLFE: Yes.
14 MR. PERLIS: Thank you. I have completed 15 reviewing the document. The staff has no objection.
16 JUDGE WOLFE: And how is this relevant to the 17 issues before the Board. This is an objection on that 18 basis,that it goes to the background and the timing of 19 implementation.
20 How is it relevant, Ms. Sneider?
21 MR. SNEIDER: I think instead maybe it goes to 22 the credibility of the witness. It is relevant to when the 23 decision was made to defer implementation of the 24 deficiencies in the SPDS.
25 The witness already testified this morning that 1
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00000101 963 marysimons 1 with respect to this document that he made the decision 2 that these deficiencies could be deferred before he even 3 knew what all the deficiencies were.
4 MR. PERLIS: Excuse me, Judge Wolfe. I don't 5 object to the admission into evidence of this document. I 6 do take issue with her characterization of the witness' 7 testimony. I don't believe that is what the witness said, 8 nor do I believe that this document goes to the credibility
. 9 of the witness because I think what he said is fully 10 consistent with this document.
11 MR. SNEIDER: Excuse me. I will retract that.
12 It goes to the basis of his decision, what factors he was 7-)~
(, 13 taking into consideration when he decided to defer the 14 correction of these deficiencies until first fuel 15 reloading.
16 (Board conferring.)
17 JUDGE WOLFE: Overruled.
18 As indicated by Ms. Sneider, it is for the 19 limited purpose of showing the basis of Mr. Eckenrode's 20 statements regarding the deferring improvements to the SPDS 21 system.
22 All right, Massachusetts Exhibit 2 is admitted
- 23 into evidence for that limited purpose and is incorporated 24 into the transcript.
25 (Commonwealth Exhibit No. 2,
- n/
(_
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6M6
'00000101 964
- _marysimons 1 previously marked for identi-
-2 'fication, was admitted into 3 evidence.)
4 (Commonwealth Exhibit identified and admitted 5 into evidence follows:)
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202-347-3700 Natioriwide Coverage 800-336-(M6
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MR 1*l g MEMORANDUM FOR: V. Nerses. Senior Project Manager, PWR Pro.iect Directorate #5 Division of PWR Licensinq-A FROM: C. E. Rossi, Assistant Director fnr Technical Support i Division of PWR Licensing-A I
SUBJECT:
' SEABROOK STATION SPDS STATUS SER -rT"
,, m-Q " \! O Plant Name: ',' Seabrook Station,' Unit 1 '
Utility: : ,. . Public Service of New Hampshire ,e. -
Docket No.:
'50-443 ;,. .
46,.p QBb.
p 1 r torate:' PD 5/DPA
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Project Manager: ~
, , V. Nerses '
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Review Branch: . EICSR/DPA Review Status: Open . .
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A .The enclosed report provides'the EICSB/DPA position with respect to the status ~ ;-
\> of the Safety Parameter Display System (SPDS) being developed by Public Se vice of New Stampshire .(PSNH) .fo'r .Seabrook Station., Unit 1. The staff's ongoing review '-
is based on the applicants'.'s afety analysis report submitted January 6,1986 and -
additional infomation submitted Ap'r il 2,'1986.3 An onsite audit.is scheduled .
for may 20-22. 1986. We expect many open issues.to be resnived by the audit but _.
Ifcense conditions 'will .be required to ensure . completion of implementation and -
conformance with staff requirements. . 3'N., e.w -
..- _. ?;_ , .
_; ;.. . , m.. _
This status report was prepared by R.'J. Eckenrode of EICSB/DPA. -Mr.- Eckenrode -
is not aware of any differing professional opinions ~ with the conclusions 'docu-- :--
mented here. A SALP report is provided as Enclosure 2.
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C."E. Rdssi, Assistant Director .
". , . ' ': ..4
> for' Technical Support - -
, Division 'foPWR Licensino-A + '
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Enclosure:
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As stated
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O. SAFETY EVALUATION STATUS REPORT l
FOR THE SEABROOK STATION SAFETY PARAMETER DISPLAY SYSTEM 18 -
HUMAN FACTORS ENGINEERING -
18.2 Safety Parameter Display System NRC Task Action Plan Item I.D.2 requires all licensees and applicants for an operating license to provide a safety parameter display system (SPDS) (NUREG-0660, NUREG-0737, and Supplement I to NUREG-0737). Implementation is to be on a schedule negotiated with the staff. The purpose of the SPDS is to continu-ously display infomation from which the plant safety status can be readily and reliably assessed. The principal function of the SPDS is to aid control room personnel during abnomal and emergency conditions in detemining the safety O' esat., of tse ,iant and in assessin, .hether ahnomai conditions warrant cor- ;
rective action by operators to avoid a degraded core. A written SPDS safety 1 analysis shall be prepared describing the basis on which the selected parameters are sufficiert to assess the safety status of each identified function for a wide range of events, which include symptoms of severe accident.
The applicant's SPDS safety analysis report was submitted January 6,1986 and additional infomation was provided by letter dated April 2,1986. The repo'rt and additional infomation are under review by the staff to confirm: (1) the adequacy of the parameters selected to be displayed to detect critical safety functions; (2) that means are provided to ensure that the data displayed are 4
valid; (3) the adecuacy of the design and installation of the system from a human factors perspective; (4) the adequacy of the verification and validation (V&V) program to ensure a reliable SPDS; and (5) the adequacy oi isolation de-vices to provide an acceptable
- interface between Class IE safety-related
.. .n. ,n- nanam.
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Instr.umentation systems and the SPDS. An audit of the system is scheduled fnr May 20-22, 1986, at which time the staff should be able to resolve many o# the open issues.
The applicant has proposed a June 30, 1986 implementation date for the Seabrook l
SPDS and this is acceptable to the staff. However, some items identified in the staff review may not be resolved by that time. A schedule, approved by the i
staff, will be required for the resolution of these items. If necessary, a license condition will be established to ensure that any remaining items identi-fled by the staff during its audit review will be implemented by the licentee prior to restart following the first refueling outage.
O 3
_ _ _ _ _ , , _ - , . _ - , _ , --- * ' ~ ' "
-00000101 965 f~)i marysimons 1 BY MS. SNEIDER:
2 Q Mr. Eckenrode, the containment isolation status 3 is another critical parameter not displayed on the Seabrook 4 SPDS; is that correct?
5 A That is correct.
6 Q In fact, the containment isolation display is 7 located a significant distance from the primary SPDS 8 location; isn't that so?
9 MR. PERLIS: Objection to the word 10 "significant."
11 BY MS. SNEIDER:
12 Q Mr. Eckenrode, perhaps you can tell re how far
() 13 away the containment isolation display is from the primary 14 SPDS location?
15 A I believe it is approximately 26 feet.
16 Q And from the primary SPDS location it is 17 difficult to read the legends on the containment isolation 18 display; is that correct?
19 A That is correct, yes.
20 Q Now you heard the applicant's witnesses testify
- 21 that they have made certain changes in the containment 22 isolation display since you have seen it; is that so?
23 A That is correct.
24 Q Do you know how many lights are on that 25 display?
A No, I do not.
ACE FEDERAL REPORTERS, INC.
ll02-347-3700 Nationwide Coverage 800-336-6M6
00000101 966-marysimons
(
1 Q Do you know size the lights are?
2 A. As I recall, they are approximately~two inches 3 wide by an inch and a half long. I am sorry -- yes, two 4 inches wide by an inch and a half high.
5 Q Without having seen the corrections that have 6 been alleged to have been made on that containment 7 isolation display, are you able to say whether an operator 8 stationed at the primary SPDS location would be able to.
9 determine if there was a failed containment isolation valve 10 by looking at the containment isolation display?
t 11 A Yes, he would.
12 Excuse me, you are assuming of course that
( )' 13 containment isolation has been called for?
! 14 Q Called for in the SPDS.
- 15. A No, called for in the plant. Containment i 16 isolation is in effect.
17 Q Yes.
18 A Then my answer stands. That is correct.
19 Q Now, Mr. Eckenrode, could you tell me, in the J'
20 event of an accident where radiation is released into the 21 containment, what would happen if a containment isolation i
22 valve was left open?
23 A A single valve?
! 24 Q A single valve.
25 A I believe all of them are redundant. Nothing ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-(M6
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00000101 967 marysimons
'}
I would happen.
2 Q Well, what if it were more than one valve?
3 A Well, if there were two valves in a single 4 line, yes, there would be containment release -- radiation 5 released.
6 Q In your testimony you also state that the 7 Seabrook SPDS does not display sufficient radiation 8 parameters; is that correct?
9 A That is correct.
10 Q And in particular you state'that the SPDS does 11 not display steamline and stack radiation parameters; isn't 12 that so?
) 13 A That is correct.
14 Q And steamline and stack radiation parameters 15-- are another two of the minimal parameters that the staff 16 considers necessary to adequately assess critical safety 17 functions; is that correct?
18 A That is correct.
19 Q Would you tell me why it is necessary to know 20 steamline radiation?
21 A Steamline radiation is one indication of a 22 steam generator tube rupture event and several other events 23 I believe.
24 Q And what is the significance of stack
, 25 radiation?
i ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 800-336-6M6
d' 00000101 968 marysimons
- - 1 A That indicates radiation to the environment.
2 Q So-the absence of such information on steamline
+
3 radiation or stack radiation could lead to operator error 4 in assessing accidant conditions or making recommendations 5 to the public?
- 6 MR. PERLIS: Objection. It has not been
'7 established that there is an absence of that information.
8 The information is not present on the SPDS. It wasn't-I 9 proper foundation for the question as phrased.
10 BY MS. SNEIDER:
11 Q If there were the absence of such information,
.12 could it-lead to operator error in assessing accident
() 13 conditions?
14 A If the absence-is on the SPDS I don't believe 15 so.
16 Q If-there was an absence of such information in 17 the control room could it lead to such error?
18 A I suppose it could if there was absence in the 19 control room.
20 Q I don't believe we are evaluating the control 21 room right now.
22 Q Well, let's take it one question at a time. Do 23 you know where in the control room the stack radiation and-1 24 steamline radiation parameters are currently displayed?
25 A Yes, I do.
ACE-FEDERAL REPORTERS, INC.
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l 00000101 969 marysimons
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1 Q Could you tell me where?
2 A They are on the RDMS, the radiation data 3 management system display which is directly behind the 4 STA's position.
5 Q If there was a problem with stack radiation or 6- steamline radiation, what would draw the STA's attention to 7 the RDMS display in back of him?
8 A I believe there are auditory alarms.
9 Q Do you know whether or not there are auditory 10 alarms?
11 A- There are auditory alarms. I~ don't know the 12 specific parameters on the RDMS which are alarmed. I think
() 13 that it is a general alarm that any one of them is 14 releasing which draws you to that panel.
15 Q But you don't know that for sure?
16 A That is correct.
17 Q Why are you requiring the steamline radiation, 18 stack radiation parameters be displayed on the SPDS at any 19 point?
20 A We believe they are two important parameters 21 indicating the general safety of the plant.
22 Q Well if you believe it is acceptable to have 23 the stack and steamline radiation parameters displayed on 24 the RDMS, why isn't that still not acceptable for after the 25 first refueling outage?
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationside Coscrage 800-336-6646 I
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00000101 970 )
(,_)'s marysimons l
1 A It may be.
2 Q Now I believe we heard some testimony on 3 Wednesday from the applicants stating that they intend to 4 add steamline and stack radiation monitoring to the lower 5 level SPDS display; is that correct?
6 A I don't remember that it was the lower level.
7 I just remember that they said it was going to be added to 8 the SPDS.
9 Q Well, assuming that it is only added to the 10 lower-level displays, what would draw the operator's 11 attention to those lower-level displays if it was not on 12 the upper-level display?
(~h 13 A I can't imagine what would draw them.
(_/
14 Q Another deficiency identified in your testimony 15 that could affect the operator's ability to rapidly and 1
16 reliably determine plant safety status is the data 17 validation methodology; is that correct?
18 A That is correct.
19 Q And at the beginning of your testimony you 20 state that "The Seabrook SPDS should not increase the 21 potential for operator error;" is that correct?
22 Q But doesn't the Lawrence Livermore audit team 23 report included with your testimony state that in fact the 24 validation methodology employed ensures that the operator 25 will be misled about safety function status in the event of ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationside Coverage 800-336-6 4 6
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.. -00000101 971
{}lsarysimons
-1 large instrument errors or on-scale instrument failures?
2 A That is what the report states, yes.
3 Q And doesn't.the report further state that the 4 uselof average values without additional validation checks 5 does not guarantee that the operator will be consistently 6 misled in the conservative direction?
i 7 A That is what the report states,.yes.
- 8 Q Do you not agree with that report?
' 9 A. No,-I agree with that.
10- Q Your testimony also calls into question the 1
11 usualness of the Seabrook SPDS lower-level display format 12 in aid operators to rapidly assess plant status; is that I
() 13 correct,7 14 A Yes, it is.
L 15 Q What is the function of these lower-lever 16 display formats?
17 A The lower level display formate are diagrams of 18 the logic trees for the critical safety functions. Their 19 purpose is to indicate to the person monitoring the SPDS i
20 the condition of that critical safety function.
21 Q Do you consider them an aid then to the j 22 operator in assessing abnormal conditions?
23 A Yes, we consider them an aid. Our problem is 24 we don't understand quite why they were not used during ---
, 25 Q Well that was going to be my next question.
4
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p) b ACE-FEDERAL REPORTERS, INC.
l Nationside Coverage 800-3364 646 202-347-3700 i,_... . _ _ . _ . . . _, _ . _ _ _ _ , _ , , , , . . . . - ,_,...., _ __,._ _ ,,.... _ .. _ ,_ ,_._ _ _ _. , , . . _ _ , _ _ . _ , _ _ _
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00000101 972
/~N marysimons
's J
.1 A Okay.
2 Q Have you evaluated the reason why the lower-3 level displays at Seabrook at not useful?
4 A No. That is what we have asked the utility to 5 do.
6 Q So I take it then that you don't know whether 7 it is a problem with format or a problem with the type of 8 information available or some other problem?
9 A That.is correct, we don't know that yet.
10 Q At any rate, is it correct that when the audit 11 team was observing the operators were not accessing this 12 potentially useful information on the lower-level displays l) 13 to determine plant status?
14 A That is correct. They did not access it. They 15 were using hard copy.
16 Q Did you see that they were using hard copy?
17 A Yes, ma'am, I was there.
18 Q Do you know why that isn't mentioned in the 19 audit report?
20 A I don't know that there was any need to mention 21 it in the audit report. Our concern was the SPDS. The 22 hard copy is not part of the SPDS.
23 Q Could you tell me the significance of knowing 24 availability calculations for SPDS?
25 A I believe that really is related to having a ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-33MM6
00000101 973 marysimons
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1 continuous display. We would like it to be available and 2 so we have -- although there is no requirement for.the 3 number, the actual value availability, we have in our 4 guidance generally given it a 99 percent availability.
5 Q Did you just say that there is no criteria for 6 what would be an acceptable availability?
7 A That is correct.
8 Q So just as an example, if the availability was 9 found to be 50 percent ---
10 A We would be very much concerned about that, 11- yes.
12 Q And it is true that you don't yet have accurate-() 13 availability calculations for Seabrook's SPDS; is that 14 correct?
15 A The calculations we have are simply lacking two 16 of the items which had not been in SPDS yet and we want it 17 redone when those items are in SPDS.
18 Q Well, it is possible, isn't it, that if the 19 RVLIS and RDMS availability were factored into-the overall 20 SPDS availability calculations that the SPDS availability 21 could be significantly lowered?
22 A Significantly? Would you define that, ma'am?.
i 23 Q Well, could it be lowered?
. 24 A Lowered? Yes, it could be.
25 Q Could it be lowered to 50 percent?
U(~T ACE-FEDERAL REPORTERS, INC.
6 202-347-3700 Nationside Coverage 800-336-6646
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i I
. 00000101 974 p marysimons 1 A No, ma'am. .i 2 Q Is that possible?
3 A No, it is not.
4 Q How do you know that?
A The RVLIS and the RDMS are only providing some 5
6 .of the parameters that go into SPDS. Therefore, it could 7 only reduce the availability on those parametero. SPDS 8 would still be there with all its other indications.
9 -Q Do you have any idea how much'it could pousibly 10 be lowered?
11 A No, I don't. That is why we have asked them to 12 calculate it.
()~ 13 Q In your testimony you also state that the SPDS 14 system response time has only been tested during a lightly 15 loaded sequence; is that correct?
16 A Yes. That lightly loaded sequence is the one J
17 we observed in the simulator.
18- Q Now in the event of a severe accident at 19 Seabrook a large number of nearly simultaneously processing 20 demands will be made on the main plant computer; is that 21 correct?
22 A That is a very good chance, yes.
23 Q And such high demand could significantly slow 24 down the update rate of the Seabrook SPDS; is that so?
25 A It depends on what priority the SPDS has in the 1.
ACE-FEDERAL REPORTERS, INC.
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00000101 975
(^^3 marysimons V
1 main plant computer operation, and we don't know what that 2 is. I was asked that earlier today and I don't know what 3 that priority is.
4 Q Well, if the update rate was slowed down, the 5 operator could be making decisions and taking actions based 6 on out-of-data; isn't that so?
7 A No, that is not correct. The. operator at the 8 SPDS does not take actions at the control panels. He is 9 provided information and he gives advice.
10 Q Well he could be making advice then based on 11 out-of-date data; is that so?
12 A That is correct, but he still does not make the
((,~) 13 decisions on the operations.
14 Q Do you happen to have any statistics on during 15 what period of operation accidents were more likely to 16 occur?
17 A No, I don't.
18 MR. SNEIDER: Those are all my questions.
19 JUDGE WOLFE: Do you have a copy of your cross-20 examination plan with respect to SAPL Supplemental 21 Contention 6 with respect to applicant's witnesses and the 22 staff witness?
23 MR. SNEIDER: Yes.
24 JUDGE WOLFE: Would you hand it to the 25 reporter.
- ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-66t6
i Y
00000101 976 marysimons 1 That plan shall be incorporated into the record i 2 as if read.
3 (SAPL Supplementa1' Contention 6 cross-i 4 examination plan follows:)
5
)
6 l 7
8 9 t 10 11 12 13 14 15 16 17 18
' 19 20 i -21 22 23 r
- 24 25 O
1 ACE FEDERAL REPORTERS, INC.
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CROSS-EXAMINATION PLAN OF THE COMMONWEALTH OF MASSACHUSETTS SAPL SUPPLEMENTAL CONTENTION 6 (FORMERLY NH-10) j.
The Commonwealth of Massachusetts will cr'oss-examine
' witnesses testifying on SAPL Supplemental Contention 6 on the
' rollowing points:
APPLICANTS' WITNESS
- 1. . "SPDS is not considered a safety system." Applicants Testimony at 1-2.
O .a. SPDS contributes to safety.
D. SPDS nelps ensure faster, more reliable operator response to accicent conditions.
- 2. Continuous oisplay of SPDS.
- a. SPDS display snould De continuous--continuous uisplay an aid to safety,
- c. Lengtn of time it would take for Applicants to modify SPDS to ensure a continuous display.
- b. Length of time it would take Applicants to add tnese parameters to SPDS.
-f
-k
() 3
- 4. Containment Isolation Display--difficultot'o read and interpret from primary SPDS location.
- a. Knowledge of Containment Isolation--critical to safety.
- o. Lengtn of time it would take Applicants to add a
! satisfactory Containment Isolation Display to 1-SPDS.
S. SPDS uoes not aisplay sufficient radiation variables, i.e., steamline and stack raciation parameters.
- a. Neea for aisplay of-these parameters on SPDS.-
- o. Lengen of time it would take applicants to add these parameters to SPDS.
- 6. Two CSF (suocriticality and core cooling) status trees
()--
N- are not mode-cependent,
- a. Could mislead'the operator.
- o. Wnen will Applicants correct this deficiency?
- 7. Data valication algorithms not sophisticated enough to ensure valid aata displayed to operator.
d
- o. Len9tn of time it would take Applicants to satisfactorily correct this deficiency.
- 8. Display call-up methoc appears awkward,
- a. Could prevent operators from making use of lower level aisplays.
"N o. Do the Applicants intend to correct this? When?
(d
t' y
l'%) 9. 'Oserulness of lower level SPDS display formats is in question.-
- a. Importance of lower level SPDS display format.
D. Have Applicants investigated why lower level cisplays not used?-
- c. Wnat co Applicants intena to do with respect to tnis ceticiency? When?
- 10. Availaoility calculations do not include RLVIS or the RDMS.
- a. Importance of SPDS ovailaoility.
- b. wnen will appropriate availaoility calculations be performed?
- 11. System loaa test needed to verify system response time.
- a. Rapio system response time necessary for safety.
- 12 . Validation festing of Seacrook SPDS.
- a. No cocumentation to support conclusions set forth in Applicants Testimony at p. 8.
4 SfAFF'S WITNESS i - 1. 80 REG-0737, Supp. 1, requirement tor prompt imp'lementa' tion of an SPDS.
- a. For Seabrook, celay in implementing a satisractory SPDS until first fuel reloading violates requirement of prompt implementation.
- o. Four years a more than adequate amount of time to develop and implement a satisfactory SPDS.
b(~N k
.e. -
's t
((s) 2. Need tor SPDS. -
- a. Purpose of SPDS.
- o. History of its requirement, i.e., accident _at TdI-2.
- c. SPD5 contrioutes to safety.
- e. Displays elsewnere in the control' room do not satisfy'the requirement of a SPDS.
- 3. Criteria for cetermining the adequacy of a SPDS.
- 4. Wnat criteria employed for determining whether to allow operation of a plant at full power despite.an incomplete SPDS?
gs
\- S. SPDS display not continuous,
- a. Need for continuous SPDS display.
D. Absence of continuous SPDS display could lead to operator error.
- 6. dHR flow and nydrogen concentration variables not alsplayed on SPDS. '
- a. Accurate and timely assessment of CSFs is critcal to sarety.
D. RHR flow and nydrogen concentration variaoles are two of tne minimum parameters necessary to assess CSFs.
O 4-
)
A
,c ,
- c. Wnat criteria, if any, does staff employ'to b' )
determine when.it is acceptacle for critical parameters to be displayed elsewhere in the control room instead of on the SPD5.
- d. Availaoility of this information elsewhere in the co.ntrol room is not sufficient.
- c. Failure to include RHR flow and hydrogen concentration variables on the SPDS could lead to operator error and compromise the safety of the public off-site.
- 7. containment Isolation Display--difficult to read and interpret from primarf SPDS location,
- a. Knowledge of containment isolation critical to s.
sateti.
- o. Misinterpretation of information on Containment Isolation Display could lead to operator error and compromise the safety of the public off-site,
- c. Wnat Justification, if any, for leaving Containment Isolation Display where it is?
- 8. SPDS coes not aisplay sufficient radiation variables, i.e'., steamline and stack radiation parameters.
- a. Need for display of these variables on SPDS: two 3-of tne minimum parameters necessary to assess i
CSFs.
D. Failure to include these parameters on SPDS could lead to operator error and compromise the safety or the public off-site.
i
.~.-- _ _ _,
s
.s.
(^s. Two CSF (subcriticality and core cooling) status trees
( ,! 9.
are not mode depenaent,
- c. These aeficiences have the potential for misleading tne operator.
- o. Failure to correct these ceficiencies could lead to operator error and compromise the safety of tne puolic off-site.
- 10. Data validation algorithms not sophisticated enough to ensure valid cata aisplayea to operator.
- a. Deficiency ensures that operator will in some circumstances ce misled.
- b. Failure to correct deficiency _could lead to operator error anc compromise tne safety of the n'
' puolic orf-site.
- 11. 03efulness of lower-level SPDS display formats to the operator is in question.
- a. Information derived trom lower level display tormats can De important to safety.
- o. wny aren't tne lower level aisplays useful?
Proolem witn format or with type of information availaole?
- c. Failure to correct oeficiency could lead to operator error and compromise the safety of the public off-site.
- 12. Availability calculations ao not include RVLIS or RDMS.
- a. Importance of SPDS availability to safety.
i a
I) o. How inclusion of RVLIS or RDMS could affect calculations of SPDS availability.
- c. wnat is tne'NRC's criteria for availability of oPDS?
- 13. Sistem load test needed to verify system response time,
- a. Rapid system response time necessary for-safety.
- o. Wnat is enc slowest that computer could update critical cata during an emergency?
2 c. Slow response time could lead to operator error ano compromise the safety of the public off-site.
- d. Justification tor allowing full-power operation oefore veritying system response time.
- 14. Considering all tne aforementioned ueficiencies, and O
l the purpose of SPDS, now does witness justify conclusion that ene SeacrooK dPDS is a satisfactory SPDS ror the period of operation prior to rtrat fuel reloading?
- 15. Wnat justitication, if any, can there ce for requiring tne ten dericiencies noted in tne SER, Supp. VI, to be correcteu piror to first fuel reloading, out not prior to full-power operation?
- a. Statistics on during what period of operation acciuents are more likely to occur.
D. Are first eighteen months of operation safer than later periods of operation?
- Depencing on the responses given and the nature of SAPL's
)
cross-examination on tnis contention, the Commonwealth may cnoose not to cross-examine the witnesses on all the issues set forth doove.
00000101 977
(~) marysimons
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1 MR. DIGNAN: Your Honor, may I be indulged on 2 examination on a point that came from this witness for the 3 first time under cross-examination?
4 JUDGE WOLFE: Any objection?
5 MR. SNEIDER: I didn't hear the question.
6 JUDGE WOLFE: Would you speak louder, please.
7 MR. DIGNAN: I would like to examine the 8 witness regarding points that came up for the first time 9 during the cross-examination. Nothing on his direct 10 because I filed no cross-examination plan.
11 JUDGE WOLFE: Any objection, Mr. Perlis?
12 MR. PERLIS: The staff has none.
() 13 JUDGE WOLFE: Ms. Sneider?
14 MR. SNEIDER: No objection.
15 JUDGE WOLFE: Mr. Backus?
16 MR. BACKUS: No objection.
17 CROSS-EXAMINATION 18 BY MR. DIGNAN:
19 Q Mr. Eckenrode, you were asked and testified as 20 to the distance from the control board to the shift 21 technical supervisor who would be on the SPDS console and 22 you indicated that that was about 26 feet. Am I recalling 23 your testimony correctly?
24 A That is what I recall it to be, 26 feet.
25 Q How far is the operator of the plant from the l
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1 main control board?
2 A The operator using that board would be probably 3 one or two feet from the console, and the display then is 4 about two feet behind. A maximum probably of four feet.
5 Q From the main control board?
6 A Yes.
7 Q With respect to the RHR system that has been 8 talked about so much, what does RHR stand for?
10 Q Could you describe for us for the record what 11 is the basic function of a residual heat removal system, if 12 you know?
',)
O
( 13 A It is my understanding it is to remove heat 14 from the system long after an accident has occurred. It is l
15 one of the final uses.
16 MR. DIGNAN: That is all I have.
I
! 17 JUDGE WOLFE: Redirect, Mr. Perlis?
18 MR. PERLIS: Brief redirect, Your Honor.
! 19 REDIRECT EXAMINATION l
20 BY MR. PERLIS:
l t
! 21 Q Mr. Eckenrode, you were asked today as to how 22 far the RHR information and the hydrogen concentration 23 information was from what we will call the SPDS display 24 area. Are any mitigations or corrective actions to be 25 taken at the STA display area?
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.marysimons 1 A No actions are taken at the STA area using the
- 2 SPDS.
'3 Q' .Are any mitigative or corrective actions 4 supposed to be taken based solely upon SPDS readings?
5 A Definitely not.
6 Q Could you just describe briefly what readings 7 are supposed to be used for the taking of actions?
8 A. Readings from the qualified instrumentation on 9 the control board.
10 Q Now you asked a little bit this afternoon.about 11 the lower-level. display formats.
12 A yes.
f 13 Q Have you looked-at.a description of the lower-1 4
14 level display formats for the Seabrook SPDS?
15 A yes, we looked at them all.
16 Q Did you have any specific problems with the l 17 material that you saw in those descriptions?
I-18 A No, only the human engineering discrepancies e
19 that we discussed earlier and the information appears to be
{ 20 there.
I Is it fair to say that the problem you have 21 Q l- 22 referenced in your testimony and SER with respect to the -
1 23 lower-level display formats is solely the fact that they-24 were not used by the operators at the time of the audit I
25 insofar as you had a problem with the lower-level display i
()
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1 formats?.
2 A Yes. I-don't know what the reason was that 3 .they were not used. They obviously used the information i
4 because they used hard copy of the same displays.
i-5 .The question we have.is are those lower-level 6 displays, is there a format problem or something that makes 7 it more difficult for them to use than the hard' copy?
8 Q Let me clarify something that was asked on
'9 Wednesday. You were asked a few questions about-the color 10 coding of the SPDS. Could you describe briefly the color 11 coding system that the'Seabrook SPDS uses?
- 12 A Yes. When the critical safety function turns'
() 13 red that function and that branch of the function is in 14 extreme challenge. If it is orange it is considered to be -
1 15 -- I don't know the adjective that.is used, but it is in a
! 16 lesser but still challenge. The yellow color then is just 17 ' challenged and the green of course is okay.
2 18 Q So-the SPDS system then has four colors?
19 A Yes, it does.
+ 20 Q The last question. You were asked a number of' 21 questions both Wednesday and today that were based upon the 22 response you gave to Interrogatory No. 9. Do you have that, 23 interrogatory in front of you?
24 A My question 97 I'm sorry.
25 Q Your answer to SAPL's Interrogatory No. 9.
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l 00000101 981
(~T marysimons o
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1 A No, I don't have that.
2 MR. PERLIS: I would like to hand my copy of 3 that document to the witness.
4 (The copy was given by Counsel Perlis to the 5 witness.)
6 BY MR. PERLIS:
7 Q Do you have that document in front of you now?
8 A Yes, I do.
9 Q Your answer there references the draft 10 technical report. Just so that the record is clear, would 11 your answer be changed at all if you referenced the final 12 report-rather than the draft report?
A
( ,) 13 A No, the answer would not change.
14 Q So any changes between the draft technical 15 report and the final technical report do not affect your 16 overall conclusion?
17 A That is correct.
18 MR. PERLIS: I have no further questions.
19 JUDGE WOLFE: We will proceed with Board 20 questions.
21 Judge Luebke.
22 BOARD EXAMINATION 23 BY JUDGE LUEBKE:
f 24 Q Mr. Eckenrode, I was interested in your remarks i
25 earlier today to the effect that implementation of the SPDS 1
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(
1 throughout the-United States has been difficult. Could you 2 elaborate a little more on what makes it difficult, like it-3 is a very complex system or people are lazy?
4 A We believe that the concern has come from the 5 fact that in deference to the industry that the industry --
6 well the power industry probably was a little slower in
.7 accepting computer technology than many other industries 8 such as the space industry or military and so.forth.
9 Uniquely enough, Seabrook is one who brought in 10 the computer long before most other utilities did. They 11 still obviously are having problems trying to get an SPDS
! 12 that we think with the staff, and the staff thinks will do
() 13 the job that we believe the lessons learned from TMI have 14 asked.
15 As I said earlier, I don't believe there is an 16 operating plant which has a completely satisfactory SPDS 17 yet. They may have it, but we have not reviewed those that 18 say they have it. It has been a long time in development 19 in bringing the computer system in. Some of the lessons 20 that other industries have learned are now being learned by 21 the power industry.
22 Q From your discussion then would it be correct 23 that with the other power plants in the country you are 24 also having these review sessions and negotiations that you 25 are having like with Seabrook?
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00000101 983
}.marysimons 1 A That is correct. We do have in fact several 2 with license conditions.that are precisely like this, that 3 have the same parameters and so forth in them.
4 Q -As insofar-as it involves the use of computer 5 technology in a nuclear reactor control room, then I take 6 it from your remarks this is kind of a pioneering effort in 7 the utility industry? I mean they are not accustomed to 8 it?
9 A That is correct.
10 Q To follow up on your remark that there is no 11 SPDS that is totally operational-in existence today in the 12 United States, does that infer -- we have been talking that
() 13 Seabrook now has some SPDS installed and has been tested -- '
14 is that the case with other nuclear power plants that they 15 have a partial SPDS perhaps operating but not the complete 16 one with all the pieces that you desire?
17 A yes, that is correct. We have written many 18 safety evaluation reports on other plants that essentially 19 say that you can go ahead with the implementation, and we
- 20 find no safety problems with it, go ahead with the 21 implementation and consider it to be an interim SPDS until i
i 22 the final system is in place.
23 Q And this partial SPDS in other plants is 24 perhaps at a similar state or fraction of the complete that 25 Seabrook is now involved in and comparable?
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00000101 984
[ marysimons 1 A We have seen them much worse and seen them much 2 better.
3 JUDGE LUEBKE: I see. It is in between.
4 Thank you, sir.
5 JUDGE WOLFE: Judge Harbour.
6 BOARD EXAMINATION 7 BY JUDGE HARBOUR:
8 Q Mr. Eckenrode, in reference to the RHR flow you 9 indicated that this would come late in an accident 10 sequence. Can you tell me relative to the hydrogen 11 concentration in containment, first of all, can you 12 indicate to the best of your knowledge what the source of
() 13 that hydrogen would be?
14 A No, sir, I can't.
15 Q You don't know where this hydrogen might come 16 from?
17 A Do I know?
18 Q Yes.
19 A No, I don't. Well, I assume it comes out of 20 the water, but I don't know the process.
. 21 Q So if you don't know where it comes from, do 22 you know what part of a potential accident sequence or 23 sequences it might come from?
24 A No, I don't know that.
. 25 Q If one of the purposes or functions of the SPDS i
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00000101 985 j^ marysimons L)'
I to pull together a number of parameter values so that the 2 _STA or other operator can handle a large number of off-3 normal conditions or at least recognize that these are and 4 _ recognize some pattern to their occurrence?
5 A Yes, sir, that.is the purpose.
6 Q Is it also a purpose of the.SPDS to pick out' 7 single instrument values of a single parameter to inform.
8 the operator that action needs to be taken?
9 A Well, you have to understand that normally the 10 top level display would be up which has not individual 11 parameters on it. It is a picture of the critical safety 12 functions themselves in general.
() 13 Q If a single parameter within one of those 14 critical safety functions went out of normal limits and it -
15 caused the critical safety function to go into one of its i
l 16 challenge modes, then the top level display would have that
., 17 indication and he would be directed or his immediate action 18 probably would be to go to the lower level display to see 19 what it was, what the individual parameter was.
20 Most likely the individual parameter would
. 21 already have been picked up by another operator at the I
22 control board through an alarm of whatever it was that 23 caused that item to go out.
1 24 Q Is it also a purpose of the SPDS to shorten the 25 amount of time for recognition of what might be going wrong f'
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v 1 in the safety systems?
2 A I don't that that is a purpose. It certainly 3 might work that way.
4 Q With regard to the RHR flow indicators, if they 5 were or were not working on the SPDS do you think that 6 there would be any difference in time between the reaction 7 of the plant operators to a difficulty in the RHR system 8 with and without the SPDS?
9 A I don't believe so.
10 Q What about with regard to the containment 11 isolation status display?
12 A Well the containment isolation status display
() 13 is there, and when it is corrected for its human 14 engineering deficiencies it certainly will be adequate.
15 Q What about in relation to the steamline and 16 stack radiation parameters? If those were available on the 17 SPDS could there be any shortening of the time of reaction 18 to the difficulties that would be indicated by those 19 systems as contrasted with no SPDS?
20 A Probably not since they are also alarmed on the 21 RDMS display.
22 Q Do you know what stack is being referred to 23 when they talk about the stack monitoring?
24 A No, I don't, sir.
25 Q Can you determine from the list of the 11 ACE-FEDERAL REPORTERS, INC.
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.00000101 987
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1 discrepancies which you have on your list whether there 2 would be any of those that would contribute to reducing the 3 time of reaction in the event of off-normal conditions if 4 they were added or required to be added-to the SPDS prior 5 to operation at full power.
6 A I would have to look at each one individually 7 if you would like me to do that.
8 Q Could you take the time, please, to examine 9 them in that light.
10 (Pause while the witness complies.)
11 A The SPDS being non-continuous would have no 4
12 effect. We just discussed I believe the RHR flow and the 4
(). 13 hydrogen concentration variables. I don't believe that 14 those would have any effect on the speed with which they 15 would operate. Containment isolation, no, because there is 16 an operator that is actually handling the containment 17 isolation part of the board and any actions are taken by 18 him and not by the STA.
19 Q But as far as recognition, would there be a i~
20 difference of time?
21 A I believe there is also an alarm for the 22 containment isolation. You see, if containment isolation 23 is called for, that is when you would be wanting to look at 24 those to make sure that all valves have-isolated, have closed. So there wouldn't be anything there. I 25 l
! l
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1 Q No. 47 2 A The irradiation variables, we just discussed 3 that, and I don't believe they would have any effect.
4 The human engineering discrepancies, the ones 5 we talked about were the access to lower level displays.
6 That is a matter of the difference between maybe a half a 7 second and one and a half to two seconds. In getting to a 8 lower level display I can't imagine that having any 9 effect.
10 The mode dependency has been corrected. That 11 is Item 6.
12 Item 7 is the isolation device between RVLIS r)h
(, ~ 13 and SPDS. That has been corrected.
14 Data validation algorithms have nothing to do 4
15 with speed at all. They might have to do with whether or 16 not the STA gets the same value that is on the displays for 17 the other operators.
18 Q Is there likely to be any confusion that could 19 occur?
20 A I don't believe so. There is always that 21 potential and that is why we asked that it be looked at 22 again, j 23 The usefulness of the lower-level display 24 formats, no, the scenario that we went through on the 25 simulator was handled very well with the hard copy i
(~)
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1 displays, and again that happens to have been one scenario 2 and we don't know how the SPDS is used in all the other 3 scenarios.
4 The RVLIS and the RDMS availability, that is 5 just simply calculations of availability. That has to do a
6 with whether those items will lower the availability of 7 being able to determine radiation parameters on the SPDS.
8 So that wouldn't have anything to do with time.
9 System response time, that currently is not a 10 deficiency. We are asking that it be checked.
11 Q Now will it be necessary for the reactor to be 12 in some operational mode in order to check that?
() 13 A yes.
14 Q Is it possible on the simulator to obtain a 15 simulated heavy load?
16 A I am not sure it is. I think the times might 17 be different. That is why we have asked that it be done 18 and checked really on the live system.
19 Q Will this be part of a low-power testing 20 program?
21 A I am not sure it can be. I don't know. My 22 answer to that would be I don't know.
23 Q I think that goes through the 11 items.
24 JUDGE HARBOUR: That is all I have.
25 JUDGE WOLFE: Judge Luebke had another O
(_/
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b}. marysimons 1 question.
4 2 BY' JUDGE LUEBKE:
3 Q Mr. Eckenrode, getting back to other plants in 14 the United States with SPDS, would you happen to know 5- whether the Davis-Besse plant had a partial SPDS?
6 A Yes, I-believe it has a partial SPDS. It was t
7 not operating at time time of that last ---
8 Q That was my next question of whether ---
9 A Which goes to the availability problem.
4 10 Q --- whether we had a chance to measure its 11 effectiveness?
12 A That was one of our complaints about the
_ () 13 problem. It was not operating.
14 JUDGE LUEBKE: Thank you.
15 JUDGE WOLFE: Cross-examination on Board 16 questions, Mr. Backus?
17 MR. BACKUS: Yes, I have a few questions.
18 CROSS-EXAMINATION
{ 19 BY MR. BACKUS:
20 Q I have a few questions.
21 Mr. Eckenrode, I think in response to Judge 22 Luebke you mentioned that there were other plants where i
23 there were licensed conditions pertaining to not having 24 fully implemented SPDS systems; is that right?
i 25 A Yes, sir, that is correct.
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00000101' 991
. (Ni marysimons U
1 Q Has the staff ever taken enforcement action for 2 failure to meet a licensed condition regarding an SPDS?
3 MR. DIGNAN: Objection, relevance.
4 MR. BACKUS: Well, Judge Wolfe, I see you are 5 looking over here. So maybe I will say something.about the 6 relevance. It seems to me that the staff's position here 7 is that under NUREG they are entitled to and consistent 8 with reasonable assurance can defer assuring a fully 9 compliant SPDS until the first refueling outage and that 10 that will be enforced by a licensed condition.
11 I think this bears on the question of whether 12 that licensed condition will actually have a meaningful
() 13 role in assuring that we eventually do get a fully 14 compliant SPDS. And I think the witness' testimony gives 15 rise to a basis for believing that that is an appropriate 16 question since I do not recall the witness saying anything 17 that would suggest so far as he is concerned that there 18 could not be upon request the granting of further 19 deferrals.
20 (Board conferring.)
i 21 JUDGE WOLFE: This is assuming that conditions 22 were imposed and, secondly, your question assumes that the 23 conditions were violated; is that correct, Mr. Backus?
24 MR. BACKUS: yes, or not met.
25 JUDGE WOLFE: All right, objection overruled.
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-(ss}
1 Answer the question.
2 THE WITNESS: I believe your question was has 3 it happened yet, and I don't believe it has yet, no.
4 JUDGE HARBOUR: Which of these things hasn't 5 happened yet?
6 THE WITNESS: His question I believe'was has 7 any plant been licensed with conditions and have the 8 conditions been violated. And, no, I don't believe that 9 has happened yet.
10 BY-MR. BACKUS:
11 Q I take it from your testimony though, Mr.
12 Eckenrode, and let us just suppose hypothetically that the
()' 13 applicants had not by the first refueling outage corrected o 14 the remaining deficiencies with the SPDS and let us assume 15 further that they have some reasonable basis for not having 16 done so other than laziness, as Judge Luebke suggested at 17 one time.
18 Can you say what position you would take in 19 recommending a further extension of the license condition 20 is you responsible to sta!' the staff position at that 21 time?
22 MR. DIGNAN: Objection. What that is going 23 into is the hypothetical situation where amendment to the 24 license is sought. There is a procedure in the regulations 25 for seeking amendments procedures for noticing the public ACE-FEDERAL REPORTERS, INC.
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1 on the subject and the ultimate decision would not be Mr.
2 Eckenrode's anyway. So his view as to how he would come 3 out on this hypothetical situation is irrelevant.
4 (Board conferring.)
5 JUDGE WOLFE: You have no comment, Mr. Backus?
6 MR. BACKUS: No, I don't think I need to add 7 anything.
8 JUDGE WOLFE: I will sustain the objection.-
9 BY MR. BACKUS:
10 Q Let me put a different question then. Would it 11 be your position in the event the licensed condition had 12 not been satisfied by the first refueling outage that in
() 13 that event the request for any change or continuation and 14 the date for compliance, would that in your opinion present 15 any significant hazards consideration?
16 MR. PERLIS: Objection.
17 MR. DIGNAN: Objection. The question of what 18 is a significant hazards consideration is purely a question 19 of law under the Commission's regulations.
20 MR. PERLIS: For what it is worth, that was my 21 objection as well.
22 MR. BACKUS: I always thought it was certainly 23 a mixed question of fact and law.
24 MR. PERLIS: It is ultimately a question of 25 law.
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. 00000101 994 Emarysimons 1- (Board conferring.)
2 JUDGE WOLFE: As phrased,-I will sustain the 3 objection.
4 BY MR. BACKUS:
5 Q Now, Mr. Eckenrode, when you give an applicant 6 an extension by means of not requiring the SPDS at the time 7 of fuel load or full-power operation, but-to first' 8 refueling, do you'take'into account-factors such as 9 population density around the facility in question?'-
10 MR. DIGNAN: I object. Relevance to the issue 11 before the Board. I come back to the original Board's 12 ruling. The only question'before.the House here is
'( ) 13 assuming these things aren't put in, is there reasonable 14 assurance for the public health and safety withuut these 15 items'until the first fuel load.
4 16 MR. BACKUS: I assume that that is relevant to i 17 the question.
18 (Board conferring.)
- . 19 JUDGE WOLFE
- Objection sustained.
20 BY MR. BACKUS:
21 Q Now going to Judge Harbour's questions. I 22 think you were asked about whether it was not one of the 23 purposes of an SDS to enable operators to shorten reaction l
24 time to accident conditions in a plant, and if I recall 1
25 your answer was that was not one of the purposes, but that ACE-FEDERAL REPORTERS, INC.
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00000101 995 I marysimons
{')!
us i
1 could be one of the uses of the SPDS; is that right?
2 A I believe that was my answer, yes.
3 Q Wouldn't the purpose of the SPDS to shorten the 4 time for reactor response be implicit in the requirement of 5 4.1. that the SPDS should aid operators in rapidly and 6 reliably determining the safety status of the plant?
7 A I believe operators can currently rapidly do 8 that process.
9 Q But doesn't the requirement say that the SPDS 10 is to aid them to rapidly determine plant status?
11 A That is what it says, yes.
12 Q And in sub (e) of 4.1 isn't it further a
() 13 purpose of the SPDS to be designed so that displayed 14 information can be readily perceived and compreherided by 15 users?
16 A That is correct.
17 Q And in light of those statements from the 18 governing document here, wouldn't you agree that it is a 19 purpose of the SPDS to -- state it however you will -- but 20 to shorten reaction time for operators?
21 A Not necessarily for the initial problem that 22 has occurred. That is what the alarm systems are for. I 23 believe that when we are talking in a relative situation it 24 could shorten it or it might follow up the primary 25 instrumentation. The matter of time I don't think really ACE-FEDERAL REPORTERS, INC.
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- 1 gets into that part of it.
[ 2 Q So your testimony is indeed that it is not a.
3 purpose of the SPDS to shorten reaction time on the part of-4 station operators? '
i' 5 A I believe that is whatlI stated, f' 15 MR. BACKUS: Judge Wolfe, I have a few 7 questions that were raised.by the cross-examination of the.
- 8 other parties. Those are all the questions I have on the i,
9 Board. And I wonder if I might proceed with that?
! .10 JUDGE WOLFE: Is this in the way of recross?
11 MR. BACKUS: Yes.
12 JUDGE WOLFE: All right. I wish you would,
, (). 13 please next time, please advise timely after the redirect j 14 that you do want to have recross.
, 15 MR. BACKUS: Oh, immediately after parties?
16 JUDGE WOLFE: Yes, prior to the Board's 17 questions.
i
, 18 MR. BACKUS: I thought -- all right, I will.
! 19 RECROSS-EXAMINATION 20 BY MR. BACKUS:
21 Q I wanted to turn to the document now marked as 22 Massachusetts Exhibit 1, if you have that, j 23 A Yes, sir.
24 Q Which is the guidance you referred to in your 25 testimony, and the next to the last sentence of the first i
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- marysimons y 1 paragraph, "A key item-is the acceptability of a certain 2 schedule without further negotiations."
- 3 Do you know iffthe use.of the word " item" there
~
4' is' intended to refer to Item 1-D-2 of NUREG 07377 Is that 5 your understanding of that?
6 A I don't believe so, no.
., 7 Q The first sentence of the next paragraph 8 states, does it not, "In general for those plants that have
, 9 not yet received an operating license, a commitment by the j 10 applicant to have implemented all of the requirements in 11 time for the. staff to complete its evaluation prior to the
! 12 fuel load date is acceptable," correct?
() 13 A That is' correct.
- ' 14 Q But you would not take it from that that a f'
i 15 failure to have implemented all of the requirements in time 16 before fuel date is unacceptable, right? ,
- 17 A That is correct.
1 F 18 MR. BACKUS: That's all.
19 Thank you very much.
- - 20 JUDGE WOLFE
- Ms. Sneider, cross on Board I
i 21 questions.
22 MR. SNEIDER: Yes, and I also have some 23 recross.
- 24 4
' 25 f
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00000101 998 i- marysimons f'/ .
4 1. RECROSS-EXAMINATION
-2 BY MS. SNEIDER:
3: Q Mr. Eckenrode, if in your opinion there:is no 4 difference in reaction time, operator reaction time with )
c i 5 out or without an SPDS, why is an SPDS necessary?
6 A As'I said, the purpose was for reaction time. l
< j 7 The purpose of the SPDS:is to bring together a lot of i 8 different parameters to show a general picture, a more i 9 general picture of the plant's safety. I don't think that 1
10 has an awful lot to do with reaction time.
11 As I said earlier, the operator of the SPDS 12 does not react to any condition by performing an operation.
() 13 Q -Yes, but isn't it so that the STA advises the 14 operator of an abnormal condition because he notices it i 15 first on the SPDS?
4-16 A That is possible, yes.
{, 17 Q So the purpose then I take it of the SPDS is to 18 draw the operator's attention to some critical parameter 19 that may be an indication of a problem at the plant?
20 A Yes, if he hasn't already seen it based on his
-21 current instrumentation, the operator.
22 Q But it would be possible that the operator may 23 not have seen it and that is why there is a requirement for i 24 an SPDS?
25 MR. PERLIS: I am going to object at this 4
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v marysimons 1 point. I think he has been asked a number of times and 2 answered a number of times what he believes-the basis for 3 the SPDS requirement is.
4 JUDGE WOLFE: I am certain that is true, Ms.
5 Sneider. Is there a particular reason for going over this 6 again?
7 MR. SNEIDER: Well, it relates to the questions 8 the Board was just asking about reaction time. It was my 9 understanding that it did aid in reaction time.
10 JUDGE WOLFE: All right, go ahead.
11 Objection overruled. Go ahead.
12 THE WITNESS: I'm sorry, would you ask the
() 13 question again, please?
14 MR. SNEIDER: Could the reporter repeat the 15 question?
16 (The pending question was read by the 17 reporter.)
.18 MR. DIGNAN: Could I inquire of counsel, is 19 that question designed to elicit the only reason for an 20 SPDS7 As phrased that is what it does. We are almost to 21 the point where we are arguing with the witness. The 22 witness has stated his beliefs in this matter. Obviously 4
23 counsel is not happy that the witness does not think that 24 its primary purpose is to increase reaction time, and that 25 can be argued in a brief, but the witness has made his view ACE FEDERAL REPORTERS, INC.
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1 clear.
2 'And as phrased the question is asked for the-3 singular reason for an SPDS.and the witness has made'it 4 clear that isn't the singular. reason.
5 MR.~SNEIDER: Is-that a reason.
6 MR. DIGNAN: I withdraw the objection.
7 THE WITNESS: As I answered Judge Harbour's 8 question, I believe it is one process that could be 9 improved, yes.
10 BY MS. SNEIDER:
11 Q Do you know how many separate alarms there are 12 in the control room?
() 13 A Seabrook also has a unique alarm system which 14 is also on computer. I believe hard wired alarms, 15 somewhere around 100. The computer system I believe picks 16 up somewhere around 3,000 different points displaying no 17 more than four at a time.
18 Q Does that mean.then in the event of a multi-19 failure accident that there could be a number of different 20 alarms going off at once?
21 A Most accidents of any significance have more 22 than one alarm going off roughly at the same time,-yes.
23 Q And isn't it the case that the accident at 24 Three Mile Island that there were so many different alarms 25 going off at once that the operators didn't know where to ACE-FEDERAL REPORTERS, INC.
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1 look?
2 A I believe that is correct.
3 Q So isn't that then another purpose for the SPDS 4 so that the operator will more readily know what is wrong 5 at the plant?
6 MR. DIGNAN: Could we be clearson whether that l
7 question really means the operator or the shift technical' 8 supervisor because they are not the same people and these 9 questions apparently are assuming they are.
10 MR. SNEIDER: I am assuming that the shift 11 technical adviser then advises the operator based lon his 12 observations at the SPDS.
O)
(, 13 THE WITNESS: I am sure the shift technical 14 adviser doesn't advise the operators. He advises the shift 15 supervisor.
16 MR. SNEIDER: I stand corrected.
17 Could the reporter repeat the last question.
18 (The pending question was read by the 19 reporter.)
20 THE WITNESS: yes, that is the purpose of the 21 SPDS to get a general picture of the safety condition of 22 the plant.
23 MR. SNEIDER: I have a couple of questions with 24 respect to your response to Mr. Dignan's question on the 25 RHR flow.
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j 1 BY MS. SNEIDER: !
2 Q Isn't it the case that the RHR system is used 3 when it is not longer practical to use the steam generator 4 for decay heat removal because the reactor coolant system 5 pressure has dropped?
6 A That is beyond my technical competence.
7 Q Well, you stated in response to Mr. Dignan's 8 question I believe that the-RHR flow system is only turned 9 on after an accident.
10 A yes, I believe that is true.
11 Q Couldn't it be necessary to use the RHR system 12 during the duration of an accident?
() 13 MR. DIGNAN: Could I hear that question back, 14 please. I'm sorry, I didn't hear two of the words.
15 (The pending question was read by the 16 reporter.)
17 MR. DIGNAN: Could I have a definition of 18 " duration."
19 MR. SNEIDER: Well, in the course of an 20 accident. I am not talking about the initiating event.
21 MR. DIGNAN: My objection is with that 22 parameter not defined, Your Honor, the question is 23 meaningless. RHR cuts in, without trying to testify, very 24 late in a cool-down process, whether it be accidental or 25 otherwise. And I don't mind the question if we have a V
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1 definition of duration, because if you are calling the 2 duration of an accident from the time of the initiating 3 event to the time when the plant is in cold shutdown 4 condition, I will stipulate that it cuts in before that.
5 But that wasn't the thrust of my question or 6 the thrust of the witness' answer. So I think we need a 7 fairly precise questions here because time is a very 8 important variable given the question of relevance before 9 the house.
10 MR. SNEIDER: I will try a different question 11 and maybe that will help.
12 BY MS. SNEIDER:
) 23 Q If the RHR system were not operational is it {
1 14 true that you would then be unable to remove decay heat and 15 core damage could result?
16 A I can't possibly answer that.
1 17 Q When you responded to Mr. Dignan's question, I l
l 18 when you used the word " accident," were you using the word i 19 " accident" to refer only to the initiating event?
i l 20 A Would you like to ask me Mr. Dignan's question l l
l 21 again? I am sure I don't know what that was.
I 22 MR. SNEIDER: I don't recall the exact words of 23 Mr. Dignan's question.
24 As I recall it, the substance of Mr. Dignan's 25 question was isn't the RHR system used after an accident?
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1 MR. DIGNAN: That wasn't Mr. Dignan's question.
2 MR. SNEIDER: Well, could the reporter read 3 back Mr. Dignan's question?
4 JUDGE WOLFE: I think that is going back too 5 far into the transcript.
6 JUDGE HARBOUR: It may have been one of my 7 questions, and I believe that my question was in effect is l 8 the RHR system called into use late in the course of an 9 accident.
10 MR. SNEIDER: I guess I thought that was the 11 same question I was asking, and if you have already asked 12 it, then I will rest.
O 13 JUDGE HARBOUR: Just to be sure, can the
(_/
14 witness answer it again?
15 THE WITNESS: The answer is yes, it is used 16 late in the course of an accident.
17 JUDGE WOLFE: Redirect, Mr. Perlis?
18 MR. PERLIS: I have no further questions, Your 19 Honor. I would ask that the witness be excused.
20 JUDGE WOLFE: All right, you are excused 21 permanently, Mr. Eckenrode.
22 THE WITNESS: Thank you, sir.
23 (Witness Eckenrode was 24 excused permanently.)
25 JUDGE WOLFE: Is there any other outstanding O
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1 matter? j 2 MR. PERLIS: Your Honor, that is the completion i 3 of'the staff's case.
4 MR. BACKUS: We had marked certain exhibits and 5 I think just three for identification, and I would like.to 6 move their admission. I don't know if these can be l 'T incorporated into the record at this point. It is 8 certainly much more convenient if they could be.. So I
, 9 would request that if it is possible. ,
10 First as SAPL 1 is the SNB letter 499 that was
. 11 produced in response to a document. request.
12 JUDGE WOLFE: Now the Board has already ruled
() 13 on SAPL Exhibit 1 I believe and did not admit it. Isn't 14 that correct?
i 15 MR. BACKUS: I don't recall-the Board ruling on 16 that. I would point out that SAPL Exhibit 1, in addition 17 to the cover letter ---
18 MR. DIGNAN: Your Honor, could I make one
{ 19 point. SAPL Exhibit I was utilized with a witness who is 20 long gone, and I think to make the offer for the first time 21 after the witness has left the stand and decisions have 22 been made on whether to conduct redirect and other 4
23 examination on the basis of the exhibit never having been 24 offered, it is a little late to come in and offer it today.
25 MR. BACKUS: Well, Mr. Dignan ---
l ()
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1 MR. DIGNAN: It was not offered yesterday, Mr.
2 Backus.
3 MR. BACKUS: Your Honor, the gentleman who was 4 interrogated in regard to this is sitting right next to Mr.
5 Dignan and, you know, how many angels can dance on the head 6 of a pin?
7 (Laughter.)
8 There is attached --- .
9 MR. DIGNAN: Wait a minute, Your Honor. I have 10 a fundamental objection here. I mean I know people get 11 upset because I tend to worry about things like the rules, 12 but that is the way it is. It is a legal proceeding.- I
() 13 didn't invent the system. The Congress of the United 14 States did.
15 Now the question before the house is whether we-16 are going to adopt a practice that somebody cannot offer an 17 exhibit when the witness under interrogation is on the 18 stand, have.the witness permanently excused and come back 19 in the next day and make the exhibit offer.
20 MR. BACKUS: Well, I have never know there to i
21 be a problem with that. I would point out to the Board 22 that at the time I said I was going to defer offering these 23 exhibits until the conclusion of the evidence. There was 24 no objection from any party to that procedure, and I am 25 doing it now.
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(.)T 1 MR. DIGNAN: No such statement was made at that 2 time of Exhibit 1. I was very carefully watching that one 3 .because I almost invited the offer and the offer was never 4 made and it is too late now.
5 MR. BACKUS: In administrative with which I am 6 familiar it is a very common practice to offer the exhibits 7 marked into identification as full acceptance at the end of 8 the proceeding, and I don't see how that can possibly work 9 any prejudice to anybody.
10 JUDGE WOLFE: Now SAPL Exhibit I was dated 11 what, please?
12 MR. BACKUS: That is dated April 14th, 1983 and
() 13 it' bears the designation SBN-499. It consists of a letter 14 from Yankee Atomic's Project Manager of five pages and 15 attached diagrams, and this is part of the reason for the 16 offer, attached diagrams of the technical support center, 17 the operational support center and I think of particular 18 interest and then it will be informative to review this 19 record, it attaches photocopies of the critical safety 20 function displays, top-level displays and the sample of the 21 status tree displays.
22 JUDGE WOLFE: Well, at page 749 of the 23 transcript that document was identified. Then Mr. Dignan 24 objected to a question being directed to the witness with 25 respect to what is now marked as SAPL Exhibit 1 for a
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1 identification.
2 I sustained the objection on the following page 3 750 that this document went to the history.
4 Then you answered, "Okay. At this point I am i
5 going to offer for identification copies of this letter to C be marked, and I offer three copies to the court reporter.
7 "Mr. Dignan: Could I ask is it offered for 8 identification or is it be marked for identification?
9 "Mr. Backus: It is being marked for 10 identification, but I don't understand the distinction. If 11 it is marked it is offered for identification.
12 "Mr. Dignan: You are not offering it into 13 evidence?
14 "Mr. Backus: No. I don't think I can do that 15 in light of the Chair's ruling, but I am making it for 16 identification because there may be another tribunal 17 somewhere that might be interested in it."
18 And this was repeated at transcript 828. So I 19 was led to believe and I have reviewed this, last night I 20 was led to believe that you weren't going to offer this 21 ever into evidence, that it would follow the transcript and '
l 22 would be used solely for appellate purposes. Now you are 1 l
23 making a new offer having misled certainly me into thinking )
24 that this was merely being offered for appellate purposes 25 in light of the Board's ruling on the question being ACE-FEDERAL REPORTERS, INC.
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1 addressed to it, namely, going back into the history of the 2 timing of implementation.
3 MR. BACKUS: Well, I think -- of course, the 4 Board and the applicants have the advantage of having a 5 transcript before them which I don't ---
6 MR. DIGNAN: Mr. Backus,-I will be glad to lend 7 you mine if it is going to help you. I don't want to take 8 any unfair advantage. There it is.
9 (Mr. Dignan hands a copy of the transcript just 10 quoted from to Mr. Backus.)
11 MR. BACKUS: I do recall that dialogue, Judge 12 Wolfe, and I think at that time the focus was on the fact
() 13 that the Board was ruling, that the text of the letter 14 dealt with what the Board felt was outside the admissible 15 scope of the contention pursuant to its September 15th 16 ruling, and I am now offering this, as I say, particularly 17 with reference to the diagrams that are attachments to it 18 that were not the subject of the discussion at that prior 19 time.
20 I am not going to be surprised if the Board is 21 consistent in its rulings that the contention as limited by 22 the Board would not permit this to be evidence in chief, 23 but it does seem to me that the diagrams here are very 24 pertinent to be illustrative of the testimony which the 25 Board has been hearing on this issue for the past three ACE FEDERAL REPORTERS, INC.
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1 days.
2 JUDGE WOLFE: Well, as Mr. Dignan points out, 3 even assuming that this might.be so, who is going to answer 4 any questions that might;arise with respect to these 5 diagrams? They don't speak for themselves, and that is why-6 you should offer exhibits in a timely manner and-get'the 7 Board's ruling and then they are in or they are out.
8 This is too late. I'm sorry.
9 MR. BACKUS: I think on the record, Your Honor, 10 at one time I did offer to put some exhibits in and you 11 told me to defer doing it1until a later time.
12 JUDGE WOLFE: As I remember, you asked me'if
) 13 you could defer it until a later time and I said yes, but I t
i 14 don't remember at page 750-that you asked to defer it. You 15 just said you were going to use it for appellate purposes.
16 The ruling is it remains marked for l 17 identification. We will follow the record.
18 Now how about your Exhibits 2 and 3, Mr.
4 19 Backus?
20 MR. BACKUS: Well, I am going move to move 21 those into evidence and request that they be incorporated.
22 Exhibit 2 is the SBN letter 920 of January 6th, 1986, which 23 was the subject of examination with Mr. Eckenrode and of 24 which copies have been provided to all parties. That is 25 also from the applicant and provides a description from the O
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( }~ marysimons 1 FSAR. It.also includes an attachment, Seabrook Station's 2 safety parameter display system, a reported dated December
- 3. 1985, and again is offered because of the testimony 4 discussed with Mr. Eckenrode concerning the fact that this 5 was reasonably representative of the hard copy that was 6 used by Seabrook Station operators as referred to in the 7 audit which Mr. Eckenrode testified about.
8 MR. DIGNAN: I have no objection to Exhibit 3.
9 I object to Exhibit 2 and ask to be heard.
10 JUDGE WOLFE: May I have that again? It is 2 11 that you object to?
12 MR. DIGNAN: It is 2 that I object to and wish O
(_) 13 to be heard on.
14 JUDGE WOLFE: All right.
- 15. MR. PERLIS: I will take mine after Mr. Dignan 16 speaks. As confusing as this may be, I have an objection 17 to No. 3. I don't object to most of No. 2 with a 18 qualification.
19 JUDGE WOLFE: All right, Mr. Dignan.
20 MR. DIGNAN: My problem with No. 2, Your Honor, 21 is if you recall how this came up with this witness, it was 22 utilized in the setting of asking the witness whether 23 concerning the RHR matters and concerning whether or not 24 there was hard copy of the nature we have talked about with 25 secondary display systems that told the operator about the ACE FEDERAL REPORTERS, INC.
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(~') marysimons s-1 RHR, and the witness said no, but procedure do and we moved 2 on, and an implication is an implication is left in the 3 record that is somehow deficient.
4 The problem is it is an extract of the 5 attachments. The full attachment in that letter is this 6 document here, and if one goes through that document, ones 7 finds, for example, accident sequences laid out, all of 8 which underline the proposition that Dr. Harbour and I 9 examined the witness on of how late the RHR flow cuts in.
10 So this exhibit as it stands with just a part 11 of the attachment is totally misleading, especially in the 12 context the witness was questioned about it because there O)
(_ 13 are other parts of that document that make it patently 14 clear that RHR is late in an accident.
15 There are accident sequences laid out, and I am 16 looking at one here where it shows RHR cutting in at 34 17 minutes after the initiating event. And I think under 18 those circumstances the document should be excluded unless 19 it is made complete. I have no objection if Mr. Backus 20 wishes to produce the full attachment and put it in 21 evidence. But with its truncated form it is a misleading 22 exhibit.
23 MR. BACKUS: Well I really have no objection to 24 the full document, except I don't have the photocopying 25 facilities to photocopy the whole darn thing. That is the ACE FEDERAL REPORTERS, INC.
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) marysimons 1013 1 only problem.
2 The offer was not intended in any way to make a 3 misleading. exhibit, but because the witness said these were
~4 representatives of the hard copy that was described in his 5 testimony and in the attachment to his testimony, and that 6 was the purpose of the offer and I am willing to have it 7 limited as I have described if that is necessary.
8 MR. PERLIS: Judge Wolfe?
9 JUDGE WOLFE: Yes.
10 MR. PERLIS: Maybe it would be better if we 11 took the exhibits separately.
12 JUDGE WOLFE: All right.
g3
(,,) 13 MR. PERLIS: We certainly have no objection to 14 the wh' ole document coming in. If the whole document isn't 15 produced, we have no objection to the figures 4.1-1, 4.2-1, 16 4.3-1 and 4.4-1 coming in. I believe those are the only 17 figures the witness was asked about. He was asked whether 18 those are -- and I don't recall it exactly, but I believe 19 he was asked if those are roughly the description of the 20 hard copy or if that is what the hard copy looks like.
21 The witness' answer I believe was, yes, that is 22 roughly what the hard copy looks like.
23 Under those circumstances, we certainly don't 24 object to those four figures coming in for that purpose.
25 Frankly, I don't know what the other figures relate to ACE-FEDERAL REPORTERS, INC.
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1 because the witness wasn't asked, and I don't believe those 2 should be if the whole document isn't going to be in, but 3 we have no objection to just the four figures I indicated 4 being admitted into evidence.
5 JUDGE WOLFE: May I have those figures again?
6 MR. PERLIS: Figure 4.1-1, 4.2-1, 4.3-1 and 4.4-7 1, and it is my recollection, and I hope that either 8 counsel will correct me if I am wrong, that those were the 9 only four figures that were brought to the witness' 10 attention. He was asked if those were representative of 11 the hard copy, and his recollection I believe was that yes, 12 they are similar to the hard copy.
) 13 If it is offered for the purpose of indicating 14 what the hard copy looks like given the witness' answer, we 15 don't object to it.
16 MR. BACKUS: And I have no objection to 17 eliminating a few pages from this exhibit. The less paper 18 we have to deal with, all of us, I am sure the better we ,
19 are. So that can be stripped.
20 MR. DIGNAN: Mr. Backus, are you also adopting 21 Mr. Perlis' limitation on the purpose for which it is 22 offered?
23 MR. BACKUS: I think I already stated I was 24 offering it for a limited purpose of representative hard 25 copy as described in the verification and validation V
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1 report.
2 JUDGE WOLFE: You are not listening to Mr.
3 Dignan. Are you accepting Mr. Perlis' statement that he 4' has no objection if the offer is made for the limited 5 purpose of showing what.the witness. testified to with.
6 respect to the Figures 4.1-1, 4.2-1, 4.3-1 and 4.4-1. Do 7 you accept that?
8 MR. BACKUS: I think that is right, yes. That 9 is what I said I thought.
10 MR. DIGNAN: Then I will withdraw my objection.
11 JUDGE WOLFE: All right. For that limited 12 purpose then as explicated by Mr. Perlis, SAPL Exhibit 2 is
() 13 admitted into evidence, 14 (Board conferring.)
15 JUDGE WOLFE: And, further, the attachments 16 ~which are attached to SAPL 2, all those which do not 17 relate to the figures that I called out should be removed 18 from the exhibit. The ones that remain are the ones that I 19 called off and that Mr. Perlis spoke to. So any other 20 figures should be removed from this document before it is 21 tendered to the court reporter.
22 MR. PERLIS: Judge Wolfe?
23 JUDGE WOLFE: Yes.
24 MR. PERLIS: I don't have a position on this.
25 I just would request a ruling as to whether the front page O
x_-
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1 cover letter would be included or not. I don't take a 2 position on that one way or the other, but just to make it 3 clear where the figures are coming from.
4 JUDGE WOLFE: Mr. Dignan, do you have a 5 position on the letter of January 6th which is the covering 6 letter for SAPL Exhibit 27 7 MR. DIGNAN: Assuming that the letter is 8 attached on the front for purposes of identifying the 9 figures and for no other is it admitted, I have no problem.
10 JUDGE WOLFE: With that limitation then the 11 covering letter of January 6th, 1986 is made a part of this 12 exhibit.
) 13 (SAPL Exhibit 2, previously 14 marked for identification, 15 was admitted into evidence, 16 .. subject to the LIMITATIONS 17 as described above.)
18 (SAPL Exhibit No. 2 follows:)
19 20 21 22 23 24 '
25 U,s ACE FEDERAL REPORTERS INC.
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n/m SEABROOK STATION Engineering Office
? ; '
v Putisc Service of New HampsNro January 6, 1986 Now Hampshire Yankee Division SBN- 920 United States Nucicar Regulatory Commission Washington, DC 20555 Attention: Mr. Vincent S. Noonan, Project Director ,
PWR Project Directorata No. 5
Reference:
(a) Construction Permits CPPR-135.and CPPR-136, Docket Nos. 50-443 and 50-444 (b) PSNH Letter, dated October 10, 1985, " Compliance with NUREG-0737: Clarification of TMI Action Plan Requirements," J. DeVincentis to G. W. Knighton
Subject:
NUREG-0737 Task I.D.2, Plant Safety Parameter Display Console
Dear Sir:
In Reference (b) we indicated that the Seabrook Station will be equipped with a Safety Parameter Display System (SPDS).
Enclosed herewith please find the description of this system (Attachment 1) and marked-up FSAR Page 1.9-9 (Attachment 2) which indicates Seabrook's compliance with NUREG-0737, " Clarification of TMI Action Plan Requirements." This information'will be incorporated into the FSAR by a future amendment.
The Seabrook Project would very much appreciate any effort on the NRC staff's part to include the resolution of this item in the next supplement to Scabrook Station's SER. Should the NRC staff require any additional support regarding this item, please do not hesitate to call.
Very truly yours, 7
John DeVincentis, Director Engineering and Licensing Attachments cc: Atomic Safety and Licensing Board Service List g ,
- 8601090333 860106 3 ()@ AD - J. KNIGHT (ltr only)
) PDR ADOCK 0500 EB (BALLARD) s F j
- EICSB (R03A)
PSB (GAMMILL) .
PSB (BERLINGER)
P.O. Box 300 + Socbrook.NH 03874 Telephono(603)474 F03 (BENAROYA) ,
' I SBN-920 i
ATTACllMENT 1 l
Description of Seabrook's SPDS -a l
1 l
lO l t<
1 l
[
l e - -
.N-a -- w=- - --*- T
- w* ----
- r
. . : ; ATTACllMENT 2 L SBN-920 -
'SB 1 & 2 Amendment 56 FSAR November 1985
. 4.
Response
- 0: h :h C:stica will N cq;;ipp ? ui-t-h : Safety Pa* = rar niaplay_ System k
-T;.. ..ys- m. the F211 ef 1985_ %
A cop! oT' Senbmok " kfe Lh 5F5-5 will L) 1 sound tc the-NRC R ruwGder Disblct LIn$Yeet" Sf wcts sebmi#ucl 4c -tWe #cc. vict telter SBN 'l o [deded Janucy 6, IclM).
Task I.C.1 Training Requirements (NUREG-0660)-
Position:
Licensees will (1) define training prior to loading fuel and (2) conduct.
training prior to full power operation.
Response: ,
-A set of low power tests to be performed will be identified three month's
. prior to fuel load. However, since Seabrook has a site specific simulator.-
which is maintained current with Unit.1 design as per ANSI /ANS 3.5-1979,
- each operating crew will perform the designated low power tests on the simulator. Therefore, only the crew on shift need perform the low power-testing on the actual plant.
Task II.B.1 Reactor Coolant System Vents (NUREG-0737)
J Position:
Each applicant and licensce shall install Reactor Coolant System (RCS) and reactor vessel head high point vents, remotely operated from the control room._ Although the purpose of the system is to vent noncondensibic gases from the RCS which may inhibit core cooling during natural circulation, the vents must not lead to an unacceptable increase in the probability of a Loss-
-Of-Coolant Accident (LOCA) or a challenge to containment integrity. Since
.these vents form a part of the reactor coolant pressure boundary, the design
- of the vents shall conform to the requirements of Appendix A.to 10 CFR, Part 50, " General-Design Criteria". The vent system shall be designed with
~
sufficient redandancy that assures a low probability of inadvertent or irreversible actuation.
Each licensee shall provide the following inforcation concerning the design l_ and operation of the high point vent system.
(1) Submit a description of the design, location size, and power supply for the vent system along with the results of analyses for loss-of-coolant accidents initiated by a break in the vent pipe. The results of the analyses should demonstrate compliance with the
- acceptance criteria of 10 CFR 50.46.
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SEhBROOK STATION , .;
SAFETY PARAMETER DISPLAY SYSTEM a.
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!.~__._~..________._.._..._.-___.____. _
TABLE OF-CONTENTS
(" ',
( ;Page .
. 1. 0 INTRODUCTION.................................................... 1
-2.0 CRITICAL SAFETY FUNCTIONS....................................... 3
'~
2.1 Barriers to Radiation Release............................. 3 2.2 Safety' Functions for Each Barrier......................... 4
'2.3 imp l ementation of the Critical Safety Function Concept....
6 3.0 . STATUS TREES.................................................... 9 3.1 Status Tree Format........................................ 9 3.2 Definition of Priorities.................................. 10 3.3 Example of Status Tree Usage.............................. 13 4.0 BASIS FOR CRITICAL SAFETY FUNCTION STATUS TREE PARAMETER SELECTION....................................................... 18 .
i
[ 4.1 Suberiticality Trec....................................... 18 4.2 Core Cooling Tree......................................... 20 4.3 Heat Sink Tr00............................................ 23 c 4.4 Integrity Tree............................................ .
25
- 4.5 Containment Tree.......................................... 28 4.6 Inventory' Tree............................................ 29 f
- O
- (.) 5.0 SPDS CRITICAL SAFETY FUNCTION STATUS TREE DISPLAY ORGANIZATION AND INTERNAL PROGRAMMING........................................ 40 5.1 SPDS Display Organization................................. 40 -
5.2 SPDS Internal Programming................................. 41 5.2.1 Suberiticality (SUBC) Program..................... 41 5.2.2 Core Cooling (COCO) Program....................... 46 5.2.3 Heat Sink (HESI) Program.......................... 52 5.2.4 Integrity (INTEG) Program......................... 55
] 5.2.5 Containment (CONTA) Program....................... 60 A' 5.2.6 Inventory (INVEN) Program......................... 62 5.2.7 Heatup Cooldown (HUCD) Program.................... 65 f- 5.2.8 Core Exit Thermocouple Averaging-(THERPO) 4 69 Program...........................................
-6.0
6.1 Steam System Piping Failure............................... 83 E' '
6.2 Loss of Normal Feedwater F1ow............................. 86 6.3 Complete Loss of Forced Reactor Coolant Flow.............. 88 6.4 Uncontrolled Rod Cluster Control Assembly Bank l
Withdrawal at Power....................................... 90 6.5 Inadvertent Operation of the Emergency Core Cooling System During Powcr Operation............................. 93 J- 6.6 Largo Break L0CA.......................................... 96
,1
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-)
3 !
TABLE OF CONTENTS (continued) l .-
, , %/ -
Page 1
7.0 VALIDATION OF SPDS WITH EMERGENCY RESPONSE PROCEDURES........... 125 7.1 Steam Line Break Accident................................. 126 7.2 Inadequate Core Cooling................................... 127 j 7.3 Loss of all Feedwater..................................... 129
'; 7.4 Anticipated Transient Without Scram (ATWS)................ 130
. 7.5 Steam Generator Tube Rupturo (SGTR)...'.................... 131
? 7.6 Multiple Events........................................... 132 l'
$ APPENDICES
- , A Back5 round Information for Pressurized Thermal Shock A-1 ll ' B Seabrook Station Emergency Response Procedures B-1
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SUBCRITICALITY STATUS TREE I i I 4
I (RED) , GOTO
- .*- FR-S.1 i (ORANGE)
P-S.
"O NEUTRON FLUX .
lji ENTER h LESS THAN 5%
(RTP) YES 0 (YELLOW)
SO aO TO
]j e FR S.2
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INTERMEDIATE go RA G 8 l INTERMEDIATE no OR
- NEGATIVE YES
('~' R0 OR YES THAN-0.2 DPM NEGATIVE CSF (GREEN) SAT "O
SOURCE
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RANGE FNERGlZED YES
.i NELLO,Wj GO T3 o FR-S.2 o
SOURCE NO RANGE SUR ZERO OR l- NEGATIVE YES
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FIGURE 4.1-1
CORE COOLING STATUS TREE ym t'
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(RED)
GO TO FR C.1
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FR C.1 j- CORE EXIT NO p so ENTER.h THAN 1200*F a
TCs LESS -
- GREATER -
YES THAN 40 % YES l -
1 CORE EXIT NO -
GO TO
- TCs LESS - (ORANGE)
. FR C.2
- i THAN 700*F YES GO TO (ORANGE) -
NO FR C.2 AT LEAST ONE RCP -
NO
~ RVUS.
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THAN 40% yes
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- GO TO RCS SUBC00UNG NO (YELLOW) FR C.3
., GREATER lj MAN 30*F YES (ORANGE) = GO TO
=
F R-C. 2 l RVUS-
_ DYNAMIC NO r
HEAD _
GREATER f' YES THAN 44 %4RCPs T
30 ' %3RCPs GO TO
- 20 %2RCPs 13 %1RCPs FR C.3 l
, 4 (GREEN) CSF
.O' SAT
- FIGURE 4.2-1 l -
I' l-
llEAT SINK STATUS TREE (RED) -. , GO TO 9+Y F R- H .1 .
TOTAL
- FEE 0 WATER NO
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! * ^o go.
", (YELLOW) GO To oooooo0000 FR-H.2 SG NR -- PRESSURE IN
'i LEVEL IN No ALL SGs no AT LEAST ENTER ONE SG LESS YES THAN 1255 GREATER YES
- ^ "
- PM A A (YELLbW) ;
GO TO l FR-H.3
$ k NARROW
' RANGE no LEVELIN ALL SGs LESS THAN YES l NONADVERSE ADVERSE (Y LLOW) A GO TO SETPOINT SETPOINT OOOoOOO ^
j FR-H.4 35%
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5% PRESSURE IN gg ALL SGs A A LESS 3
1185 PSIG YES i
(YELLON) GO TO !
8 F R-H .S NARROW i c m TA N NT "U RANGE LEVEL BUILDING NO IN ALL SG3 PRESSURE GREATER YES GREATER THAN 28%
THAN YES 4.3 PSIG r1 I 1 CSF SAT
- , (GREEN) i )
FIGURE 4.3-1 l
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INTEGRITY STATUS TREE j '
, (A i i ACHMENT A) 2 .
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f a: Ti T2 COLD LEG TEMPERATURE
, (RED) ~ GO TO "N
{ F R- P.1 Att RCS PRESSURE (ORANGE) GO TO NO r't C3 C':2 C3 C3 COLD LEG [f F R- P.1
- t TEMPERATURE o l POINTS TO YES
"$,"T A ALL RC3 NO L COLD LEG TEMPERATURE (YR I ON)o
- O O
o }FR-P.2 GO TO GREATER THAN YES 250*F (Ti) ALL RCS TEMPERATURE COLD LEG NO OECREASE IN NO TEMPER- -
ALL COLD ATURES <
j ENTER h LEGS LESS titan 100*F YES GREATER THAN 280*F (T2 )
IN THE LAST 60 uinuTES l
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(ORANGE)g - GO TO
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? ALL ACS COLD LEG NO 1 ( A i i ACH M ENT B)c- TEMPER-j ATURES RCS PRESSURE YES 4 GREATER THAN 4 LESS THAN NO 250*F (Ti )
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- ARMING BISTABLE SETPOINT
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f FIGURE 4.4-1 0 ,_
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- - . . . ~- _
t 00000101' 1017
( :marysimons
- 1. JNDGE WOLFE: Now with respect to SAPL Exhibit' 2 3 ---
3 MR. BACKUS: Yes, I would move that be admitted
~4 : as an exhibit. 'Now also that of course is a meeting
- f5 summary document that had a stamp date of 24 June 1986, and 6 that was the basis of some cross-examination of Mr.
7- Eckenrode this morning.
8 JUDGE WOLFE: And Mr. Dignan said he has no
' -9 objection.
10 MR' DIGNAN:
. I had no objection.
11 JUDGE WOLFE: Mr. Perlis?
r 12 MR. PERLIS: The staff did have an objection to
- () 13 this one. Not only was the witness not present_at this 14 meeting, but I believe his testimony was he didn't believe 15 the summary was relevant to the SPDS issue. Therefore,~we l 16 don't believe the exhibit is relevant to the contention.
17 ' JUDGE WOLFE: In fact,~I think he was even more
. 18 dogmatic than that is my recollection.
, 19 What did you ask him dogmatically?
20 JUDGE HARBOUR: I asked him if it had any 21 relation to the SPDS whatsoever?- ,
22 JUDGE WOLFE: And your recollection of his i
23 answer?
i 24 JUDGE HARBOUR: My recollection of his answer i
25 was no.
!-(:)
i ACE-FEDERAL REPORTERS, INC.
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. - -, _ . 202-347 3700
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00000101 1018 (j marysimons 1 MR. PERLIS: It is solely on relevance grounds 2 that we challenge this.
3 MR. BACKUS: I believe we asked follow up 4 questions and the witness did acknowledge the relation' ship 5 between this and the SPDS. We will have to stand on the 6 record on that, but that is my recollection.
7 JUDGE WOLFE: It is our recollection that 8 whoever was dogmatic, most certainly the witness, Mr.
9 Eckenrode has said that what is now SAPL Exhibit 3 marked-10 for identification had nothing with the SPDS.
11 Therefore, it being irrelevant, its 12 admissibility is denied and it remains SAPL Exhibit 3 s
s 13 marked for identification and it will follow the record.
14 MR. BACKUS: Can these exhibits, although the 15 Board has not admitted them, can they be incorporated in 16 the transcript for ease of reference in the future?
17 JUDGE HARBOUR: No.
18 MR. BACKUS: I would make that request.
19 JUDGE WOLFE: No, they cannot be.
20 So your SAPL Exhibit 2, if you will give three 21 copies of that, which has been admitted for a limited 22 purpose, we will proceed.
23 (Board conferring.)
24 JUDGE WOLFE: Did you wish this SAPL 2, which 25 has been admitted for a limited purpose after you take out
- ACE-FEDERAL REPORTERS, lNC.
202-347-3700 Nationwide Coverage 800-336-(M6
m _- _ _ _ , . _ _
. 00000101 1019
.marysimons 1 those figures that I said-should not be attached, do you 2 want this incorporated into the record?
.3 MR. BACKUS: Well, if the rest of them aren't, 4 why bother. I don't care. Whatever is the pleasure of the 5 Board. I don't care.
6 JUDGE WOLFE: All-right. You have one copy of 7 .SAPL Exhibit'2 with the relevant attachments.
8 (The reported nodded affirmatively.)
9 That will be admitted into evidence and 10 incorporated.into the. record for the limited purpose stated-11 by the Board.
12 MR. BACKUS: Lastly, I would like to mark for
() 13 identification, if I could , the draft design verification 14 and audit that staff produced for us this morning. I i 15 request that it be marked SAPL 4 for identification.
16 (The document referred to was 17 marked SAPL Exhibit 4 for 18 identification.)
19 MR. DIGNAN: Your Honor, I obviously have no 20 objection because to quote our Chief Judge in 21 Massachusetts, you can mark the phone book for t 22 identification, but I sure would like to have a copy of the
- 23 document since, as you say, it will follow the record, and 24 I don't have one. I gave mine up to the Board if you will 25 recall.
ACE-FEDERAL REPORTERS, INC.
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.- - . . . . . _ . . , . - . . , . . - . , . . , - . - . - - . . . _ . _ _ . - . . . - - . . - . . - . . - _ ~ . - - . , . . , , . . . . . ,
I 00000101 1020
~h marysimons (V
1 JUDGE WOLFE: Mr. Dignan, I will return your 2 copy to you.
3 You have no objection to its incorporation into 4 the record, admitted and incorporated into the record?
5 MR. DIGNAN: My understanding is he has marked 6 to mark it for identification. I can't object to that. I 7 don't understand it to have been offered in evidence.
8 JUDGE WOLFE: I see. All right.
9 (Board conferring.)
10 JUDGE WOLFE: Have you had a chance to review 11 it, Mr. Dignan?
12 MR. DIGNAN: I am familiar with the document,
( 13 Your Honor.
14 JUDGE WOLFE: All right, do you now make an l
15 offer of the exhibit?
l 16 MR. BACKUS: Yes.
l 17 MR. DIGNAN: Could I have the purpose of the l 18 offer of a draft audit report?
l 19 MR. BACKUS: Well, the witness testified in l
l 20 Interrogatory Answer A-9 that this was a basis for his i
21 conclusion on -- and I will have t- get the interrogatories 22 out to see which particular 1* to the acceptability SPDS l
23 he said this was.
{
\
24 MR. DIGNAN: Is the document offered, Your 1 l
25 Honor, for the truth of the matters contained? That is I l(()
l l
l ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-3364 646
00000101 1021 marysimons
} {
I 1 what I want to know. 1 2 bht. BACKUS: Yes, it is. l 1
3 MR. DIGNAN: Then I object to it because it is I 4 clearly a draft report and we are clear that changes have 5 been made in the document, and to offer it for the truth of 6 the matters contained would be misleading because no one 7 has sponsored it as speaking truth. Indeed, the evidence 8- is what speaks truth is the final, which is always the 9 case. If it is offered for impeachment or if it is offered 10 for a basis, that I understand, but it is being offered for
- 11. the truth of the matters contained, I object, because 12 clearly the final document must be offered for that
) 13 purpose.
14 MR. BACKUS: Well, I think the document is 15 offered because the witness adopted it as a basis for his l 16 recommendation as he set forth in his interrogatory answer 1
17 and as he testified here.
18 I don't understand that the truth may
- i. 19 necessarily reside in a final report more than in a draft l
20 report.
21 MR. DIGNAN: If it is offered solely for the 22 purpose of showing the basis et a witness' decision on the
[
23 theory that is what he testified, I have no objection. But 24 the difficulty I have with the document is you have a final 25 document which represents the final position of the author, ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646
00000101 1022 I'h marysimons V
1 and unless you are offering the draft for some sort of 2 impeachment purpose or some other limited purpose, it can't 3 go in for the truth of the matters contained at least under 4 the Rules of Evidence as I understand them.
5 JUDGE WOLFE: Now which is it, Mr. Backus? Are 6 _you using it as a basis or are you using it for the truth 7 of the statements contained in it?
8 MR. BACKUS: I am offering it as an exhibit for 9 all purposes for which exhibits are competent. That.would 10 certainly include impeachment, but I believe based upon the 11 testimony we have heard and the reliance of the witness on 12 this document as well as the final report that it should be O
(_/ 13 admissible for all purposes.
14 MR. DIGNAN: I understand in their offer for 15 all purposes to include an offer for the truth of the 4 16 matters contained, and I object to it on the grounds that 17 it has clearly been established as a draft document of the 18 author.
19 JUDGE WOLFE: Mr. Perlis?
20 MR. PERLIS: Two comments. The staff also does 21 not oppose its admission into evidence insofar as it serves 22 as basis and the witness testified that he relied upon it 23 to some extent.
24 The etaff does object to the document being 25 introduced for the truths of the matters asserted.
l l
l ACE-FEDERAL REPORTERS, INC.
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.[
00000101 1023 (f marysimons 1 The staff also just wishes to point out one 2 caveat, and that is we appended the final report to the 3 SER. Not all of the final report is relevant to the 4 contention and we don't believe a. good portion of the. draft 5 report .is relevant to the contention.
6 We have no objection to the whole document 7 . coming into the record, but we just want to make clear _that 8 we do believe a portion of the' document is not relevant.to 9 the contention, s
. 10 JUDGE WOLFE: Well then you really have:two 11 objections.
12 MR. PERLIS: I don't believe the second one is J ) 13 really an objection. I just wanted to note for the record 14 that we are not conceding that the whole report is relevant 15 to the contention. Portions of it, just as portions of the 16 final report, are not relevant.
I However, I don't believe there is ever an 17
!. 18 objection to a whole document coming in as opposed to 19 portions of the document.
20 So I don't object to the whole document as i
21 opposed to portions of it. I just want to make clear our 22 position that the whole document is not relevant, but 23 portions of it may be. ;
24 JUDGE WOLFE: Well, the Board would have 25 admitted SAPL Exhibit 4 marked for identification if it had ACE-FEDERAL REPORTERS, INC.
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. . - _ . . . _ , _ . . _ . . , . _ . . - . , ~ , _ . - _ , _ - - . ~ , _ . . _ _ . _ , _ - _ _ . - _ _ , _ _ . _ , , . _ . - - . . - , . - - _ ,
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00000101. 1024 l
-(}-marysimons I been offered for a limited purpose, but.since it is being 2 offered for all purposes, including the truth of the J
,' 3 matters stated therein, and in light of the objection, I
- 4 will have to sustain the.cbjection.
5 So SAPL Exhibit 4 remains marked for 6 identification'and will follow the record.
~
7 I will now proceed to give instructions to the 8 parties.
- 9 Pursuant to 10 CFR Section 2,754, the parties are 10 directed to file and will be deemed in default if they do
- 11 not file proposed findings of fact and conclusions of law, L 12 briefs and a proposed form of order or decision.
) 13 Applicants shall file their proposed findings-
, 14 of fact and conclusions of law and briefs and a proposed 15 form of order or decision with 30 days after the record-is 16 closed, i.e., by November 3', 1986.
]
4 L 17 Intervenors shall file and interested States 1
18 may file proposed findings and conclusions of law within 40 19 days after the record closed, i.e. by November 12, 1986.
20 The staff shall file within 50 days after the 21 record is closed the above identified submissions, i.e., by 22 November 24, 1986.
23 Applicants shall reply within five days after 24 the filings of proposed findings and conclus;ans of law and 25 briefs by the other parties; in other words, by December 1, ACE-FEDERAL REPORTERS, INC.
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00000101 1025
] ). marysimons 1 1986.
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2 Proposed findings of fact and proposed 3 conclusions of law shall-follow the format in Section 4 2.754(c).
5 Further proposed findings:
t 6 1) They should not summarize pleadings and 7 filing dates; 8 2) They should not summarize testimony;.
9 3) They should not summarize prior rulings in 10 the case except when necessary; 11 4) They should be set forth in declarative 12 sentences and use the active voice.
- () 13 5) -Uncontroverted findings should be set forth 14 first.
15 6) Ultimate findings of fact should be
- 16 supported by subsidiary findings; 17 7) Those parties filing after the applicants 18 should wherever possible incorporate by reference 19 applicants' proposed findings with which they really do not
- 20 disagree.
o -21 8) Proposed findings should be integrated and
- 22 based on the original record and the instant record.
23 The August 1983 transcript should be cited 1-24 Transcript followed by the page number. This is done to 25 distinguish it from the September-October 1986 transcript.
4 ACE-FEDERAL REPORTERS, INC.
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i l,
.. 00000101 1026 I()-marysimons l 1 The parties should file a brief. discussing the 2 important issues and how they should be resolved. The 3 brief should set forth the caption " Contentions," discuss 4 the reasons why the contentions should be resolved in favor 5 of the submitting party andlshould cite controlling 6 . statutes and case law and should cite the supporting-7 findings by~ number.
8 If there are no other questions, the 9 evidentiary record is herewith formally closed.
2 10 As I said, the evidentiary hearing is formally 11 closed, but we will hear limited appearance statements 12 between 7 and 10 p.m. this evening.
) 13 MR. PERLIS: Judge Wolfe, I have a question.
14 JUDGE WOLFE: yes.
15 MR. PERLIS: I believe you indicated the 16- parties could incorporate by reference proposed findings 17 with which they did not disagree. Is that advisory or 18 mandatory? Or put another way ---
19 JUDGE WOLFE: It is not mandatory. You may 20 incorporate by reference earlier findings proposed by 21 another party.
22 MR. PERLIS: But need not.
23 JUDGE WOLFE: But need not.
24 MR. PERLIS: Thank you.
. 25 C:)-
4 i
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f 1-00'000101- 1027 marysimons 1 JUDGE WOLFE: All right. Thank you very much.
2 (Whereupon, at 3:50 p.m., the: evidentiary -
3 hearing formally concluded with limited appearances to 4 reconvene at 7:00 p.m., the same day.)
5 * * * * *
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8 9
10 11 i
12 13 14 15 4
16 i 17 18 i
19 20 4
21 22 t-23 24 25 4
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CERTIFICATE OF OFFICIAL REPORTER t
V(^
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter-of:
NAME OF PROCEEDING: PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al.
(Seabrook Station, Units 1 and 2)
DOCKET NO.: 50-443 OL, 50-444 OL; ONSITE EMERGENCY PLANNING-AND TECHNICAL ISSUES PLACE: PORTSMOUTH, NEW HAMPSHIRE
- 0
'/ DATE: FRIDAY, OCTOBER 3, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) !A MM (TYPED)
MARY C. SIMONS Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation O
- -- -- . _ . - . _. -- .- - .