ML20247L700
| ML20247L700 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/19/1989 |
| From: | Traficonte J MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20247L708 | List: |
| References | |
| CON-#389-9199 OL, NUDOCS 8909250044 | |
| Download: ML20247L700 (25) | |
Text
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~ UNITED STATES OF AMERICA'
- ,,h. _ w Hy.f NUCLEAR REGULATORY COMMISSION ATOMIC' SAFETY'AND LICENSING BOARD Before the Administrative Judges
p,
'Ivan W.
Smith, Chairman
[0 s $~
Dr.~ Richard F.
Cole pug e Kenneth A. McCollom
.[
)
In the Matter of
)
Docket;Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE. COMPANY
)'
-(Full-Power Licensing)-
OF NEW HAMPSHIRE, ET AL.
)
)
(Seabrook'. Station, Units 1 and 2)
)
September 19,-1989
)
INTERVENERS' INFORMATIONAL SUPPLEMENT TO THEIR LOW-POWER
_.__SQliTENTIONS EILEE_0N_ JULY _11_ANR_ARGUST 28. 1109 The Massachusetts Attorney General'(" Mass AG"),.the Seacoast Anti-Pollution League ("SAPL"), and the'New England Coalition on Nuclear Pollution ("NECNP") (collectively, the " Interveners")
submit
.the attached excerpts'from the transcript of an NRC-1/
Interveners note that the 11RC Staff has characterized Intervenor efforts at filing low-power testingLcontentions as
" unauthorized filings. "
NRC Staff Response to Motion to Admit Reply to Applicants' and Staff's Responses to Interveners'
[ July 21] Mot' ion to Admit Contention or in the Alternative to Reopen the Record and Request for Hearing, September 14, 1989, at 4 n.
7.
No clearer indication of the Staff's disdain for the public's right to a hearing has as yet come to light in this case.
Not only did Interveners seek a schedule for the filing of low-power contentions but, as the Staff is well aware, Interveners have'an affirmative obligation to timely file contentions and additional bases when necessary and sufficient information supporting such contentions and/or bases becomes available.
Apparently, the Staff would have this Board resolve the issue of the Interveners' rights to a hearing on low-power testing events by simply rejecting Interveners' filings of contentions as " unauthorized filings."
It is not hard to imagine that the extreme prejudice against the Interveners' hearing rights which led the Staff to this bizarte 8909250044 890919 b
PDR. ADOCK 05000443 g
s 6
sponsored public meeting held on September 6, 1989 in Durham, New Hampshire as additional support for the low-power testing contentions filed to date.
The Interveners assert that the attached excerpts provide additional information regarding Intervenor allegations that:
1) the Seabrook operators are inadequately trained; 2) the operators did not grasp the safety and operational rationale for the 17% manual trip under the specific conditions of the natural circulation test; and 3) the Applicants presently do not meet the regulatory requirements for start-up testing.
Interveners incorporate the atttched excerpts into both their contentions statement attached as Exhibit 1 to their August 28, 1989 Motion and into Exhibit 1 to their July 21, 1989 Motion.
Respectfully submitted, COMMONWEALTH OF MASSACHUSETTS JAMES M.
SHANNON ATTORNEY GENERAL l
/3 hn Traficonte
[(lepartment lief, Nuclear Safety Unit of the Attorney General One Ashburton place Boston, MA 02108-1698 (617) 727-2200 DATED:
September 19, 1989 l
1/
(cont.)
characterization of Interveners' requests foi a hearing has also affected its overall legal judgment on the real issues facing this Board with regard to any low-power testing litigation.
The weight assigned to the Staff's analysis should be adjusted accordingly.
l l
L_______________..___
i
v i
UNITED STATES NUCLEAR REGULATORY COMMISSION i
q PUBLIC HEARING TO DISCUSS THE.:
1 1
RESULTS OF NRC REGION 1 ON Docket No. 50-443
)
SEABROOK UNIT 1 AND RECEIVE A
PUBLIC COMMENTS RECEIVED SEP 131989 NUCLEAR SAFETY UNIT Pages:
1 through 185 Place:
Durham, New Hampshire Date:
September 6, 1989
============================================
HERITAGE REPORTING CORPORATION ost*fA,=*rr 1220 L Street, N.W., Salle 4W Washington, D.C. 20006 (202) M
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MR.-GRILLO:
Called by phone from the turbine 2
' building, the control room is notified that the valve is l
3 wide'open.
At this point, the pressurizer level is at 14-4 1/2 percent, the lowest it ever reaches during the event.
5 The operators immediately shut the malfunctioning 6
valve.
Within a minute and a half, pressurizer level is 7
restored to a point above the 17 percent shutdown criteria.
8 At the same time, the reactor coolant system 9
pressure also is increasing.
As you will see in the next 10 segment of the tape, the operators now turn their attention 11 to the pressure increase.
Because of the continued increase
'12 in pressure, and the difficulty in re-establishing pressure 13 control, the unit shift supervisor determines that a manual 14 shutdown of the reactor is necessary.
15-The unit shift supervisor realizes that without 16 such a manual shutdown, the reactor will shut down 17 automatically if pressure continues to increase past a 18 predetermined point.
19 At the end of this next segment of tape, the unit 20 shift supervisor indicates his intention to order a reactor 21 shutdown.
22 Let's take a look.
23 (Videotape shown) 24 MR. GRILLO:
The unit shift supervisor has decided 25 to shut down the reactor.
Heritage Reporting Corporation (202) 628-4888
1 4
n 21 1
However, in the next segment of tape, operator 2
number one asks the unit shift supervisor to delay the 3
reactor shutdown.
1 l
4 He says to the unit shift supervisor, quote:
"Can i
5 you give me a couple of seconds more?"
Close quote.
He l
6.
asks for the delay because he now realizes he is close to j
J 7
stopping the pressure increase.
The unit shift supervisor'
(
8 denies operator number one's request to delay the shutdown 9
and takes decisive actfon to direct the operator number two 10 to initiate a shutdown.
11 Operator number two shuts down the reactor and 12 normal audio signals sound.
13 Responding as trained to this shutdown, operators 14 then initiate the shutdown checklist and report the 15 different plant conditions to the unit shift supervisor.
16 Let's view the final segments of this tape.
17 (Videotape shown) 18 MR. GRILLO:
As vau saw, the control room remained 19 calm, competent and professional throughout the event.
20 Public safety was naver at risk.
21 However, as you also saw, the specific procedure 22 governing the test was not followed.
23 Speaking for my staff of operators, and for 24 myself; I want to emphasize the seriousness with which we 25 regard the events of that day.
Since June 22, we have Heritage Reporting Corporation (202) 628-4888
33 1
(Jeers) 1 2
VOICE:
The NRC works for the nuclear industry.
3 (Loud jeers) 4 MR. MARTIN:
Mr. Brown, before you have your 5
closing-remarks, there are.some issues that I have not'found 6
addressed --
7 (Applause) 8 (Jeers) 9 VOICE:
Do you believe your own lies or do you 10 just spew them out?
That's what I really want to know.
11 VOICE 2:
Get him out of here.
12 (Jeers) 13 VOICE 2:
You've had too much cocaine.
14 VOICE:
Spew and spew and spew day after day after 15 day after day.
16 VOICE 2:
Throw him out, i
17 VOICE:
Do you really believe it?
18 VOICE 3:
Get him out.
I 19 MR. MARTIN:
Mr. Brown, in reading our report, in
{
20 reading your report, there are a number of other issues that l
l 21 neither report addresses that I think we need to get
'l 22 clarified tonight.
23 With regard to the test procedure that was 24 utilized, what was its genesis; what was the basis for the 25 17 percent trip; did the people reviewing the procedure and Heritage Reporting Corporation (202) 628-4888
34 1
recommending its approval understand it; and was that 2
information communicated to the operators?-
3
. MR. BROWN:
I'd like to ask Mr. Drawbridge to 4
respond to that question.
5 MR. MARTIN:
That's fine.
6 MR. BROWN:
Mr. Martin, as you are probably well 7
aware, a number of these type of natural circulation tests 8
have been done in the industry.
9 One test.that was done was at the North Ann plant.
10 We looked at the procedure that was utilized at North Anna 11 and in that procedure they concluded the 17 percent trip 12 criteria.
13 There were other procedures utilized in the 14 industry that did not need or did not have, include, that 17 15 percent criteria.
16 In the case of North Anna, it is my understanding 17 that they included that 17 percent criteria because they had 18 other trip conditions that they had in bypass.
19 In our case, we had an individual that came from 20 North Anna.
We looked at the North Anna procedure when we 21 were developing our own procedure.
22 It was felt at that time that it would be 23 conservative to leave that trip in.
It was not necessary in 24 hindsight since we did not have the same type of trips 25 bypassed as they did at North Ann 1.
However, the trip was Heritage Reporting Corporation (202) 628-4888 1
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left'in as part of the criteria for that procedure.
2 The procedure was reviewed, reviewed at SORC, and 3
it was then implemented.
4 MR. MARTIN:
My question remains, though, when 5
PORC, your onsite review committee, reviewed it, did they 6
understand the reason the 17 percent trip was in there?
And 7
did they make an overt decision that that was the right 8
trip to leave in that procedure?
9 VOICE:
It's all lies.
Don't listen to him.
I 10 MR. DRAWBRIDGE:
To my knowledge, I am unaware of 11 the specific SORC discussion that went on for that 12 particular procedure.
To my knowledge, I am unaware whether 13 they specifically discussed that particular trip as it
{
14 applied to North Ana.
15 MR. MARTIN:
What do you regard as the onsite i
16 review committee's obligation when they review a procedure 17 and run across a step of that nature?
Are they expected to
\\
18 challenge it if they don't understand it?
j 19 MR. GRILLO:
Mr. Martin, I'm Joe Grillo, the 20 operations manager.
21 As a SORC member, we reviewed the test, and we
~
22 viewed that as an enveloping criterion, and would not 23 necessarily have questioned it beyond the fact that it l
24 enveloped.
25 Under normal operating conditions, we do not have i
Beritage Reporting Corporation l
(202) 628-4888 L____----_----------
36
'1 any low pressurizer level automatic trip.
2 MR. MARTIN:
During this test, you operate without 3
reactor coolant pumps.
Therefore, you.do not have the 4
normal sprays for the pressurizer.
5 Therefore, when you isolate auxiliary spray, you 6
lose letdown in the. process, and you secure your heaters, 7
you have lost pressure control.
8 That's the reason it was in the North Anna 9
procedure.
You were under the same situation.
The fact 10 that you didn't have strong pressure control
,.s 11 subsequently indicated when the steam dump valve tras shut 12 and the pressure came back as you continued to charge at a 13 high rate, I think about 123 gallons per minute.
And the 14 pressure went right up and went on the high side.
15 That is the reason that trip is in there.
It is 16 needed in there.
And I don't understand why the onsite 17 review committee didn't, if they didn't understand why it 18 was there, that they didn't challenge it.
19 MR. GRILLO:
As Bruce mentioned, there are many 20 other procedures out in the nuclear industry that do not 21 have the 17 percent trip criteria.
North Anna was the only 22 one that we had been able to find.
23 MR. MARTIN:
I recognize that.
24 The second area is that the shift supervisor 25 allowed the initiation of this test without confirming that Heritage Reporting Corporation (202) 628-4888
o.
1 39 1
downside-to tripping the plant.
2 Did you_ explore that?
3 MR. BROWN:
Yes, sir.
We concluded that the
'4 downside was personal pride in stopping the test.
The 5
individual has been counseled that he should have followed 6
procedures.
He felt comfortable in view of his normal 7
operating procedures, knowing that he was within his design 8
operating envelope.
He was wrong.
9 MR. MARTIN:
Does the individual appreciate that
'10 now?
11 K
1 OWN:
Absolutely.
12 MR. MARTIN:
Do his fellow unit shift supervisors 13 appreciate that?
14 MR. BROWN:
Absolutely.
They questioned it even 15 as we were doing our post-trip review.
16 MR. MARTIN:
A third area that is of interest to 17 us, we note that you have established a single point of 18 contact for the NRC following transients.
19 Who is that individual going to be and is it going 20 to be a person in the management chain who can give us 21 definitive answers on what management's plans are for that 22 plant?
23 MR. BROWN:
Yes, sir.
It's the station manager, 24 the assistant station manager, or the on-duty, site 25 emergency director.
Beritage Reporting Corporation (202) 628-4888
45 1-re-oriented the procedures and revised the philosophy.se 2
that the operators now feel responsible for those.
And we 3
are interested in your actions to ensure that people that 4
are in charge of the whole station, like the shift 5
supervisor, especially in times where there is no other 6
management there, he may be the senior management person 7
onsite, that he feels responsible for the other health 8
physics procedures and maintenance procedures and so forth, 9
that certainly are not in the operations manual, your checks 10 of these types of activities.
Are they going to look into 11 that area?
12 MR. FEIGENBAUM:
Since we've received our zero 13 power license in 1986, we have actually been operating under 14 operating-type conditions for that period of time for almost 15 three years.
16 We've gone back and we've looked at our quality 17 trends and our own inspections and our own evaluations of 18 our operations personnel and their adherence to procedures, 19 and we have not found any indication that there is any 20 problem with an understanding on the part of our operations 21 personnel and the people that run the plant on the back 22 shifts and swing shifts, or during normal daytime hours, 23 that there is any indication that they have a 24 misunderstanding with dealing with other department 25 procedures.
Heritage Reporting Corporation (202) 628-4888
4 46 1
They understand their responsibilities for 2
operation of the plant in accordance with procedures.
What 3
we had during this' event was somewhat of a unique condition 4
on their understanding of test procedures as guidance.
5 It was more than just' ownership.
It was a feeling 6
that as long as they were in their operating space, they 7
felt comfortable and that they could carry on the test and B
continue operation.
9 That was a mistake, as Mr. Grillo and all of us 10 have said, a misunderstanding.
But as far as adherence to 11 procedures in the broad sense, we have not witnessed the 12 problem in the larger sense in the past three years.
13 MR. MARTIN:
Vic, do you have any questions?
14 MR. NERSES:
I just need a clarification from Mt.
15 Drawbridge or Mr. Grillo.
16 When you spoke that other plants did not have the 17 trip criteria, were these plants in a condition that they 18 were at critical, like 3 percent power with the pumps off, 19 or were they using decay heat?
20 MR. DRAWBRIDGE:
It is my understanding that they 21 did have the reactor critical and they were using that to 22 simulate decay heat.
23 MR. NERSES:
Okay.
Thank you.
24 MR. MARTIN:
Noel?
25 MR. DUDLEY:
I'd like to touch a moment on the t
Beritage Reporting Corporation (202) 628-4888 I
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training is at issue here as opposed to the adequacy, 2
because the training that was given, was it given with 3
respect to this test specifically or was it done in 4
accordancw with EOPs which would have covered an already 5
tripped reactor?
6 And the question is, even if the training that was 7
given had been given recently, would it have adequately 8
. prevented what happened?
9 MR.-GRILLO:
Mr. Corne, I can answer that.
10 I would have to go back and re-characterize a 11 comment or a question from Mr. Jordan.
12 In the process of doing normal procedures, we 13 normally can get into a situation where we have to exit 14 those procedures, enter abnormal procedures, do what you 15 have to do to bring the plant back to a ctable condition and 16 then re-enter those procedures you were already in.
17 The unit shift supervisor who was in charge that 18 day felt that the startup test procedure was of a similar 19-nature.
He felt that he could exit that procedure, go into 20 his abnormal for recovering from a loss of letdown, and as I 21 stated before, this was a bad decision, because of the trip 22 criteria.
But he felt that ir his mind he had the latitude 23 to enter an abnormal procedure from that procedure and then 24 re-establish letdown, re-enter the procedure again.
He was 25 wrong.
Beritage Reporting Corporation (202) 628-4888 l
t 53 1-We are training in the future on the procedures sa 2
Mr. Corne had mentioned by looking at the Ebnormal 3
occurrences that could happen during a test procedure where l
4 you would have to make a' decision on exiting the procedure 5
or terminating the procedure.
l 6
In the training that we had, we did not test the 7
I-envelope.
It was a t-
.ning where we discussed how we would l
8 get through the natural circulation, and didn't prove the 9
what-ifs.
10 In the future, we will.
That is our plan.
11 MR. MARTIN:
Any other questions?
12 (Person dressed as puppet enters room) 13 MR.-MARTIN:
I respectfully request that you 14 remove yourself from this area.
This is a Federal 15 Government meeting with their licensee.
16 Mr. Brown, the three reports of this event, the 17 one ey the State of New Hampshire, the one by your staff and 18 by the NRC, come to very similar conclusions.
)
19 I agree that the safety significance of the actual 20 event is minor.
You should be aware, and I think you ably 21 expressed it in your opening remarks, that it was our
~
22 concern of how the operators would respond in subsequent 23 events where they were similarly challenged to follow their 24 procedures.
25 From what I have read, relative to your Heritage Reporting Corporation (202) 628-4888 I
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they indeed lost control'of the situation and went'over the l
1 2'
upper trip limit or heading toward the upper trlp limit.
l g:
i 3
Do you understand why they did not have control of i
4 the reactor when they began to initiate those corrective 5-actions?
6 MR. MARTIN:
Oh, exactly.
l
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7 MR. MOYER:
Can you explain that to me?
8-MR. MARTIN:
When the level dropped to 17 inches, l
9 there is'a set point that says --
'10 MR. MOYER:
In the pressurizer we are talking l
11 about?
12 MR. MARTIN:
In the pressurizer. 'Which says I am 13 about to uncover my heaters that are in the pressurizer.
14 And these heaters are immersion heaters, they are used to 15 being under water, So to protect the heaters, the heaters 16 turn off.
In addition because they do not want to lose any 17 more water, the let down valve isoir.ces, because that is a 18 way that lifts water out of the reactor system to be cleaned 19 up and pumped back in.
20 And obviously one of the things that might be 21 causing the water level to go down is you are letting down 22 toc auch water, so that valve goes shut.
- Well, 23 unfortunately when that goes shut, that stops flow to the 24 regenerative heat exchanger that they were using to heat up 25 water before they injected it into tne pressurizer to Heritage Reporting Corporation (202) 628-4888
4 4
66 1
prevent cold shock.
2 So now they have lost two things.
They have lost 3
the heaters which are used to increase pressure, they have 4
lost the sprays that are used to decrease pressure, and they 5
have very little control now over pressure.
And what 6
happened when they finally turned around and added too much 7
. water, the pressure came back very fast.
Without pressure 8
control, sure enough it was going up fast.
It was going up 9
at about 1.7' inches, 1.7 percent per minute or something 10.
like that.
11 MR. MOYER:
Is it true that.the main cooling pumps 12 are shut off during all but natural circulation tests?
13 MR. MARTIN:
No, sir, they are normally operating.
14 MR. MOYER:
They are normally operating, but they 15 were shut off in this case?
16 MR. MARTIN:
Because it would not be a natural 17 circulation test if they were running.
18 MR. MOYER:
Okay.
19 MR. MARTIN:
That is forced circulation.
20 MR. MOYER:
Did that exacerbate the problem in 21 this case?
22 MR. MARTIN:
Certainly.
Because normally when the 23 pumps are running --
24 MR. MOYER:
That gives an added measure of 25 control.
Heritage Reporting Corporation (202) 628-4888
67 1
MR. MARTIN:
you have a tube that sits down in 2
the main coolant that collects water, and that would have 3
-been used to inject.into the pressurizer.
Because the 4
reactor' coolant pumps were off, you did not have that source 5
of pressurized water.
So you had to use this spray water 6
that came through this regenerative heat exchanger.
7 MR. MOYER:
And they lost that?
8 MR. MARTIN:
Yes.
9 MR. MOYER:
One more question, does the NRC have 10 any procedures to deal with a scenario in which the licensee 11 ignores your third phase, the order from the NRC, and could 12 you explain what.that is?
13 MR. MARTIN:
I happen to have my lawyer right here 14 with me.
15 MR. REIS:
If the NRC believes that there is a 16 danger to the public health and safety in what is happening, 17 it can step in and give the order.
Normally that is 18 reserved to the Chairman of the NRC.
When an incident is 19 happening, he has the ability to delegate that to the people 20 on the site.
Generally that is very closely held.
It is 21 closely held with the idea of having the utilities be 22 responsible, because the government cannot run everything, 23 and it is necessary for that reason.
24 But we do have the ability to do so.
We have a 25 data hookup into Washington with a control room in Heritage Reporting Corporation (202) 628-4888 L
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planes th'emselves.
2 MR. MOYER:
Right.
Thank you very much.
3 (Applause.)
4 MR. MARTIN:
The next individual that I would like 5
to call is Mr. John Traficonte, Massachusetts Attorney 6
General's Office.
7 (Applause.)
8 MR. MARTIN:
John, you have a following.
9
. MR. TRAFICONTE:
I have the benefit of not having 10 somebody holding a sign immediately over.my head too.
I 11 want.to make a statement first very briefly because I do 12 represent the Attorney General of the Commonwealth of 13 Massachusetts, and I am going to ask some fairly technical 14 questions.
15 So before I do that, I want to make two general 16 statements.
The first by now is rather obvious.
That the 17 Commonwealth of Massachusetts opposes the licensing of 18 Seabrook Station.
I 19 (Applause.)
20
, MR. TRAFICONTE:
The basic reason that we think 21 that it should not be licensed is that we think that the 22 site is inappropriate, and that there is no effective and 23 adequate emergency plan in the event of a serious accident 24 particularly in the summer.
I will add however that the 25 events at low power in our view cause us great concern about Beritage Reporting Corporation (202) 628-4888
I 0
71 1
the adequacy of operator training and management culture and 2
a variety of other issues, which we are in the process as I 3
am sure your attorney is aware of attempting to litigate 4
before the licensing boards of the Nuclear Regulatory I
5 Commission.
6 The second point is a little bit less general and 7
that is that I would like to express my frustration, and 8
again representing the Commonwealth here, that I have to 9
stand here in this format and ask technical questions which 10 I think are better posed to the licensee directly.
11 (Applause.)
12 MR. TRAFICONTE:
I am frustrated in having to do 13 that because the questions that I am about to ask you are 14 fairly technical and I am afraid that you may very well tell 15 me that the best people to ask that are the licensee and 16 they left sometime earlier this evening.
17 The reason that I bring that up is because under 18 your own procedural regulations in order to litigate or have 19 a hearing on these issues, we the Commonwealth as well as 20 any other Intervenor must in a timely manner present 21 adequate information to the licensing boards before the 22 matter would be open for litigation. Yet at the same time, 23 we are absolutely unable to get the information necescGry to 24 put the papers together, and to secure the hearing rights 25 that Congress intended in the Atomic Energy Act.
And that Heritage Reporting Corporation (202) 628-4888 i
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simply is not appropriate and not in accordance with the l-2 congressional intent as to how nuclear energy was to be 3
regulated in this country.
4 Now I have specific questions.
I would like to 5
ask you, Mr.' Martin.
You asked the licansee a very good 6
question about their understanding of the safety correlation 7
with ' regard to the 17 percent manual trip criterion.
And I I
B sat in the audience and was very uncomfortable with the 9
answer.
That is to say that I heard them talk about the 10 North Anna circulation test.
I heard a question from 11 Mr. Nerses as to whether at other sites was the reactor 12 critical or not critical.
i 13 I would like to put it directly to you i
14 Mr. Martin, is there something about the conditions of the 15 plant when the pumps are down and you are conducting a 1
I 16 natural circulation test when the reactor is critical, is 17 there something about the 17 percent manual trip criterion l
18 that is actually safety connected, does pressure for 19 example -- you already told us this evening that you lose 20 let down automatically and I know that the sprays go down at 21 17 -- is pressure very volatile when the pumps are down such 22 that if you do not shut down at 17 and you have the 23 situation that they had and the pressure will rise very 24 quickly and immediately ascend past the 2385 which is the 25 automatic trip?
Heritage Reporting Corporation (202) 628-4888 1
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1 MR. MARTIN:
Let me respond to your question.
It 2
will not rise by itself, but you are right that the pressure 3
is far more difficult to control with the loss of those 4
systems.
And it is our belief that. that is an appropriate 5
parameter to have in there.
And we have heard the 6
licensee's explanation and we chose to disagree.
7 MR. TRAFICONTE:
I heard the licensee this evening 8
more or less indicate, and of course the record will speak 9
for itself, but I heard the licensee indicate that after l
10 review that they are of the view basically that it was not f
11 inappropriate for the operators to keep their eye on the 12 envelope of the toch specs, i.e. the 5 percent cutoff, that 13 the 17 percent trip criteria was guidance and really had no 14 safety connection, and you are telling me that that is 15 wrong?
16 MR. MARTIN:
I am telling you that it is wrong, 17 and I am also telling you that their documents do not say 18 that now.
That was their original position, I agree.
That 19 was the original position that was used as explanation to us 20 of why operators performed the way that they did.
The
_1 21 licensee has subsequently decided that it was inappropriate 22 action, and they do see that there is some rationale there, 23 but they do not see a strong safety correlation.
The 24 difference is that they say yes, it is more difficult to 25 control but it is not mandatory for safety.
Heritage Reporting Corporation (202) 628-4888 1
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74 1-They are correct that there are other limits that 2
are further out that would also be controlling.
They 3
acknowledge that those are controlling.
That is fine.
My 4
concern remains that there was no reason to deviate from the 5
procedure and they did, and therefore we will be seeing them 6
in the enforcement space tomorrow.
7 MR. TRAFICONTE:
The next question is having read 8
your report, their report, and every piece of information 9
that I obviously can get my hands on, that it is my 10 understanding that the licensee has represented that the 11 reason why the trip did occur when it did, and I think that 12 the pressure was at 2310 when the actual trip occurred, they 13 had represented in their papers that they did that because 14 they were approaching the manual trip criterion of 2340 15 which is the natural circulation test criterion.
My 16 question is a rather obvious one.
17 MR. MARTIN:
That is correct.
18 HR. TRAFICONTE:
Okay, that is correct.
My 19 question is an obvious one.
There is something frankly 20 contradictory about them representing that on the one hand 21 their operators treated these test criteria as guidance, 22 i.e. they can be disregarded and we can go past 17 on the 23 down side with regard to pressurizer level, but they are 24 certainly not treating the same test criteria as guidance 25 when the pressure begins to go up and gets to 2310 and they Heritage Reporting Corporation (202) 628-4888
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75 1
manually trip before they reach 2340.
2 In exactly the same test the same operator treated 3
one of the criterion not just as guidance but as something 4
that required a trip, but with regard to another test 5
criterion he treated it as guidance.
6 The question is how credible is their explanation that the problem was that they understood the criteria in a
the text as just guidance, is that a credible explanation?
9 MR. MARTIN:
It is a credible explanation if you 10 take into account that when they went through the first one 11 that it was very slow, it only went down to 14.5 percent, 12 and they actually turned it.
They felt that they had 13 control of it and were recovering.
I do not think that they 14 recognized though how sensitive the pressure control became.
15 And when they started coming back in pressure, it came back 16 very fast.
And so if they did not trip it at the 2340, 17 there is a trip at 2385.
The plant would not have tolerated 18 them sitting on their hands much longer.
{
19 HR. TRAFICONTE:
You do not find an inconsistency?
20 MR. MARTIN:
I do.
1 21 MR. TRAFICONTE:
You do?
22 MR. MARTIN:
It is prima facio to me.
i 23 MR. TRAFICONTE:
The last question.
I have many, 24 many questions.
Obviously there are many other people who 25 want to ask you questions and comment.
This is going to be l
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my last question, but I have many others.
2 You stated, Mr. Martin, that it is your view at L
3 least and perhaps the staff's in general, you stated that 4
this test revealed and I quote "an endemic problem with 5
your," and again you are talking to the licensee, "your 6
organization."
That was just a few minutes ago.
7 Could you identify for us on the record what the B
staff's view or what in the staff's mind is the endemic 9
problem with the New Hampshire Yankee organization as 10 revealed by this low power?
11 MR. MARTIN:
In this particular case, I was 12 focusing on the fact that a number of operators did not 13 regard those trip criteria as requirements.
And based upon 14 our interviews, there was more than one individual who 15 professed that it was guidance and that it was not a 16 requirement.
And that is completely contrary to their 17 administrative procedures, and we just did not understand
{
18 how they could come to such a conclusion.
19 Pete, do you have any comments on that?
20 MR. ESELGROTH:
Not other than the guidance 21 issue --
I 22 MR. MARTIN:
Would you use the microphone.
23 MR. ESELGROTH:
You were mentioning earlier the 24 seeming contradiction on the one hand treating something as 25 guidance and later on not.
That is one way to look at it.
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Another way to look at your observation is that you are 2
reenforcing the team's finding which was that they were 1
3 coming up with a hierarchy approach to their different 4
limits and requirements, and that was one of the main 5
problems that we saw.
6 MR. TRAFICONTE:
Well, just to follow up.
In fact 7
the 2340 criterion ir a test criterion and not a tech spec.
8 So it is not as if they are using a different set of 9
procedures when they tripped at 2310.
They are using 10 exactly the same test criteria, at one point treating it as 11 guidance and --
12 MR. MARTIN:
John, I acknowledge that.
But the 13 explanation again, the one I told you, had they not done 14 something, it is an anticipatory type thing, had they not 15 done something the plant no longer would have been tolerant.
i 16 It would have taken them out automatically.
17 VOICE:
How do you know that?
]
i 18 HR. MARTIN:
Because I know what the trip set l
19 point is.
20 MR. TRAFICONTE:
There is an automatic trip set l
21 point at 2385.
The reactor would have automatically l
22 tripped.
23 I take it then that as the pressurizer level 24 descended past 17 that there was no intolerance, is that the l
l 25 point?
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MR. MARTIN:
It just turned off the heaters and it 2
isolated.and let down, but it did not cause a reactor trip.
I 3
So now you have got more sensitive pressure control.
But 4
now when you are coming back up in pressure,.there is a high 5
pressure trip.
6 MR. TRAFICONTE:
Is there an automatic shutdown at 7
five percent when the pressurizer level gets below five?
8 MR. MARTIN:
There is a low pressure trip.
If 9
water were to continue to drop and pressure were to continue 10 to drop, yes, there would be.
11 MR. TRAFICONTE:
A pressure, I see.
12 MR. MARTIN:
But not a level.
13 MR. TRAFICONTE:
I see.
Thank you very much.
14 MR. MARTIN:
The next person that I would like to 15 call is Dolly Weinhold, chairman, Hampton municipal budget 16 committee.
17 MS. WEINHOLD:
Yes, the name is Dolly Weinhold.
I 18 am chairman of the Hampton municipal budget committee, but I 19 am here as a private citizen.
My main concern was that 20 after we discovered that there was a so-called safety 21 problem at Seabrook, that the civil defense director was not 22 notified, and no town official was notified, and as far we 23 knew no one knew what had happened until they read it about 24 it in the newspaper.
25 And I am wondering what is the protocol for such l
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