ML20202D149
| ML20202D149 | |
| Person / Time | |
|---|---|
| Issue date: | 03/15/1995 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20199L462 | List: |
| References | |
| FOIA-97-325 NUDOCS 9712040158 | |
| Download: ML20202D149 (74) | |
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 +++++
4 OFFICE OF INVESTIGATIONS 5 INTERVIEW I
6 ------------------------------X 7 IN THE MATTER OF: :
8 INTERVIEW OF : Docket No.
9 JOHN WIEDEMANN : (not assigned) 10 :
11 -------------------------------x 12 Wednesday, March 15, 1995 13 14 Second floor Conference Room 15 Administration Building 16 Public Service Gas & Electric Co.
17 Nuclear Business Unit IS Hancocks Bridge, New Jersey 19 20 The above-entitled interview was conducted at 21 10:28 a.m.
- o. 8 0' 22 BEFORE:
5 '
& n 23 KEITH LOGAN Investigator to N N' 24 BRIAN McDERMOTT Nuclear Engineer S2 O 25 R8 g NEAL R. GROSS EXHIBIT- r CASE ND. 1-95-0l'3 wuar ateoatras ^~o tai ~scascas PAGE ian anoot isuso avenut. ~ w / OF 7'YPAGE(9 qqt)c t/0n' &' <
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- 2 i
i 1 APPEARANCES 2 On behalf of John Wiedemann:
3 IGRK J. WETTERHAHN, ESQUIRE 4 IGRCIA R. GEly.AN, ESQUIRE !
1 5 Winuton and Strawn 6 1400 L Street, N.W.,
7 Washinijton, D.C. 20005-3502 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W (202) 2344433 WASHINGTON. D.C 20005 (202) 2344433
3 1 PROCEEDINGS -
2 (10:22 a.m.)
- 3 -
MR. LOGAN: Would you swear in the witness, 4 please? .
i 5 Whereupon, ;
6 JOHN WIEDEMANN
~
7 having been first duly sworn, was ca11ed as a witness i i
8 herein and was examined and testified as follows:
9 MR. LOGAN: Thank you, Mr. Wiedeman. If you 10 would please say your last name, spell your last name --
11 I'm sorry --state your name and spell your last name for 12 the record.
13 THE WITNESS: John Wiedemann, that's 14 W-I-E-D-E-M-A-N-N.
15 MR. LOGAN: And my name is Keith Logan. I'm 16 an investigator with the U.S. Nuclear Regulatory 17 Commission, King of Prussia, Pennsylvania.
18 This is a continuing interview. We spoke last 19 on February 15th and ve'd like to continue some of the 20 issues that we talked about there.
21 I have with me today Mr. Brian McDermott.
. 22 MR. McDERMOTT: -My name is Brian McDermott.
~
23 I'm an inspector with the NRC's Pegion I, Division of 24 Reactor Safety.
25 MR. LOGAN: And as with last time, you're NEAL R. GROSS t
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4 i 1 appearing here today with counsel, is that correct? [
2 THE WITNESS: That's correct.
3 MR. LOGAN: Mr. Wetterhahn? '
4 MR. WETTERHAHN: Let me identify myself for 5 the record. It's Mark J. Wetterhahn with the firm of a
6 Winston & Strewn, same address and same appearance at last 7 time.
8 MR. LOGAN: And you're here today with Ms.
9 Gelman also?
10 MR. WETTERHAHN: With Ms. Gelman, Marcia 11 Gelman of our office is joining me today and we're 12 representing Mr. Wiedemann, and he is aware we're 13 representing other individuals in the company in this 14 matter.
. 15 MR. LOGAN: And it is your desire to have them 16 here today as counsel?
17 THE WITNESS: Yes, it is.
18 MR. LOGAN: Okay, thank you.
19 EXAMINATION 20 BY MR. LOGAN:
21 Q Mr. Wiedemann, I'd like to get into one area 22 today and that's the POPS issue. We discussed that 23 briefly last time. I'd like to get into a little more 24 detail with it. ,
25 Sort of as a starting off point, could you NEAL R. GROSS COURT REPORTERS AND TRANSCR$ER$
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5 1 toll us when you first became aware that there was an 2- ' issue with regard to POPu?
3 A I know that we had received a Westinghouse 4 notice from Nuclear Engineering. I believe it went to 5 Nuclear Engineering lirst. And I want to say it was 6 probably around June or July of '93. I think that was the i
7 time frame.
. 8 0 And how was that broght to your attention?
9 A It was through the mail system, just another '
lo document that I reviewed and I believe just parsed on to i 11 System Engineering. I receive correspondence from Nuclear 12 Engineering, from various organizations, and that was one 13 piece that came over, and it may have also been assigned 14 to us in what we call the Action Tracking System, the ATS 1 15 System.
16 0 What is that system? Can you explain that?
17 A That is an cdministrative tool that we have to i
18 track different work projecta that are assigned to the 19 different groups. This POPS issue may have been an ATS item, I'm not sure, but that's pretty possible.
20 21 Q L a don't recall specifically it being one or 22 not being one, though?
23 A That's correct.
- Ag 4% 17p< 06 44MM TD N'6- -
g q 24 BY MR. McDERMOTT:
25 Q Mr. Wiedemann, what type of items are in the NEAL R. GROSS COURT REPOATER$ AND TRANSCRIBEAS 1323 AHODE ISULND AVENUE, N W (202) 234M33 WASHINGTON. O C. 20005 (2C2) 2344433
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6 1 ATS System?
2 A These would be industry type events, SOER's, 3 Info Information Notice, NRC bulletins. That characterizes !
4 the type.
5 0 okay. of those items, is there an expectation 6 as to what the safety significance of those are when 7 they're put into that system? ;
8 A I'm not sure if I understand what you mean by ;
9 expectation, but any item that is placed in the ATS System 10 is something that is tracked to completion, and it can go 11 from multiple departments. It may originate in one i 12 department, that may lead to an assignment being made to 13 another group within the organization.
14 Q Okay.
15 A Not all of the issues in ATS may necessarily 16 be safety related or safety significant. They go to all 17 the disciplines on the Island. It could be an 18 administrative type issue. It can be balance of plant, 19 nuclear steam supply.
20 Q okay.
21 A It covers the whole gambit.
22 Q so if someone in your organization is 23 reviewing an ATS item and they identify a potential safety 24 concern, what is your expectation as a manager, as to 'what 25 action that engineer would take?
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7 1 A As a supervisor,-my responsibility is to !
+
2 review it and insure that at least I agree with what is 3~ being presented.
4 Q Rreview what?
5 A I would' review the response that the system 6 engineer has made to the ATS item. So if he's responding 7 to say an information notice, it-would come to me for 8 approval to -- and when I look at it, it's to insure that :
9 the isaue that's addressed in the information notice or 10 SOER, whatever the ATS item is, is adequately responded to 11 in the response.
12 Q Okay.
13 A I also look at the technical nature, insure 14 that, you know, there aren't any glaring errors. That's 15 about it.
16 0 Okay. If, in the course of reviewing that 17 item, the engineer has a safety concern, is there any 18 process, established process here at Salem, that they 19 would initiate with that concern?
20 A Well, there is a -- the system engineer or any 21 employee has access to the NRC resident inspectort. They 22 have access to off-site safety review. It doesn't-23 necessarily have to be-restricted to something that is 1
24 uncovered or found during the response to an ATS item.
25 But, if during the ATS research of a NEAL R. GROSS COURT REPORTER $ AND TRANSCRIBERS 1323 RHODE t$ LAND AVENVE, N W (202) 234 4433 - WASHINGTON. D C. 20005 (202) 2344433
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i particular issue, someone determines that there is an 2 applicability, that that specific bulletin applies to 3 Salem Station, then we take the next-step of seeing what l 4 organization is responsible for implementing a fix. And l 5 it would then go to the next level, or the next group.
6 ror exarnple, if someone decides that the way I 7 to resolve an SOER is through a procedure change. A new 8 procedure needs to be developed. Then the system engineer 9 woulo institute the procedure changes. And then an ATS 10 item would be assigned to the procedure writing group, to il . develop the procedures.
12 Q Let me ask you --
13 A So it's a sequential type of approach.
t 14 0 With your example, in reviewing that piece of 15 information, until those procedure changes were 16 implemented, the plant would perhaps be in violation of 17 s6me type of requirement. What process would that 18 engineer have to get that information out to the rest of 19 the organization?
20 A Oh, if we were in violation of design basis, 21 then that would be an incident report. >
22 0 Okay. Is there another process that could 23 also be used for an engineering type potential deficiency?
24 A We would write an incident report, if we felt 25 we were in violation of some type of design basis issue. '
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1 If it's a maintenance type issue, then we also have
- 2 recourse to write a deficiency report, trying to resolve 3 it along those lines. That's kind of rare. I'm not that l 4 familiar with ever having to write a deficiency report in !
5 responding to an ATS item.
6 Q Okay. Regarding the POPS issue, did Mr.
7 Lashkari bring to you e. draft of an incident report?
8 A Okay, I'm making an assumption that when we're 9 referring to the POPS issue, it's the nil-ductility ncn- '
10 conservative set point. That's when we're dealing with Il POPS.
12 0 That's correct. Tnere could be many issues 13 over time with a given system. The issue that we're !
14 referring to now is the one that was first brought to 15 Salem by means of an NSAL from Westinghouse in March of 16 i 1993, and the draft incident report that I'd like you to 17 take a look at is dated January 31, 1994, and it was 18 reported by Mr. Lashkari. It appears to be a draft
. I 19 document.
20 Would you take a look at that?
21 MR. WETTERHAHN: Take your time.
22 THE WITNESS: Okay, I remember this one. This 23 deals with an issue that Charlie was reviewing4in response MN 24 to the concern Westinghouse had raised, that under a 25 specific scenario you could achieve a high pressure rpike NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 Rr400E ISLAND AVENUE. N W.
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10 1 that would lead to a failure of the reactor vessel. And 2 as I recall now, thcs particular issue as described by 3 Westinghouse differed slightly in how the Salem plant was 4 configured. And that the means of mitigating the pressure S spike at Salem was provided by not only the POPS system, 6 but also the RH3 value on the RHR system.
7 1 beJieve I discussed this with Charlie at 8 length and we had an understanding that we were not 9 challenged by this particular sequence of events because 30 the RH3 would lift well in advance before we would achieve 11 a pressure spike as identified in the Westinghouse 12 bulletin. <
13 But the concern was as to whether the RH3 14 valve, because it's not specifically defined as a POPS 15 valve, that we could take credit for the valve.
16 I believe I had directed Charlie to take this 17 issue rmd assign it to the Licens.ng and Regulation Group, 18 to determine if the RH3 credit could be taken, and let 19 them determine what would be the next step.
20 So writing the incident report in my mind 10 THE A 21 means that we had an event that fit the definition +L 4- g 22 NAP, and therefore we needed to document it via an 23 incident report.
24 I believe at this time, in the January time 25 frame, we were not complete with our evaluation, and we NEAL R. GROSS COURT REK)RTERS AND TRANSCRIBERS 1323 RHODE ISLAND A%TNUE. N W.
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. 11 1 still needed to look at the RH3 and whether you could take 2 credit for it.
3 So, as I recall, I told charlie that it was 4 premature to issue an incident report at this time, let 5 Licensing take a look at this and let them follow up on 6 it.
7 And it's my understanding that's what charlie did.
8 BY HR. McDERMOTT 9 Q So, at that point, you understood that the RH3 10 valve was not part of the system, the POPS system, as 11 defined in tech spec and the tech spec basis?
12 A That's correct. ,
13 0 Okay. And did you not consider that a 14 condition outside the design bacis then? i 15 A Well, the condition that's postulated by c
16 Westinghouse was based on an isolation of the RHR system 17 so that your only means of relieving the pressure spike 18 was through the POPS system.
19 The Salem Station had made a modification to 20 the RHR system around the 1988 time frame -- I think it 21 was '88, '89 -- where we had removed the interlock that 22 would have isolated the RH3. So the description of the 23 event that Westinghouse was postulating would be -
24 applicable to a plant that still had this pressure 25 interlock in place, and because we didn't have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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33 1 pressure interlock in place, therefore that event couldn't 2 occur at Salent.
3 So the POPS non-conservative set point issue 4 would be applicable to a plant that relied solely on the 5 POPS system to relieve this type of pressure spike. So 6 that's why I felt that we were*within the POPS set point, 7 POPS set point under this condition. In Mode 5 RHR 8 operation wasn't an issue, 9 The concern that was raised was whether the -- l j 10 and I use the term " credit," -- credit could be taken for i 11 the RH3, and that was outside of my scope, it was outside 12 of Charlie's scope, but Licensing made the call on that.
13 So as far as the ATS item, it would then progress to 14 the hext step. We had done our work. The system INFO 00lX C208t!O. $lNel 15 engineering 7 There was still additional work that needed 16 to be done, and then we could make a determination as to 17 how Salem wanted to re:ipond.
18 Q Regarding the tech specs and the POPS system, 29 was it clear to you at that point that the POPS system 20 that was described in the tech spec would not be able to 21 perform its design function?
22 A No, that was not clear to me. The design 23 function of the POPS system, to relieve pressure at 375, 24 was still there.
25 0 This system would still relieve at --
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13 2 A At 375. >
2 0 Have you read the Westinghouse letter? :
3 A Yes, I have.
4 Q Okay. And then, based on reading that, you '
5 understand that the issue addressed in that wac with 6 reactor coolant pumps running, that the set point for the 7 POPS system may be off by as much as 100 pounds, i.e., if 8 the set point is 375 pounds, the system would not begin to 9 relieve until 475 pounds?
10 A Yes, that's correct. That the sequence of i
11 events postulated in the Westinghouse bulletin would 12 require a number of scenarios to fall in place at once.
13 The POPS system would still relieve at 375, but the 14 concern was whether the pressure spike that would be 15 generated by the sequence of events occurring at the 16 center line of the reactor vessel would be relieved by the 17 POPS system. And what we had determined through our 18 evaluation was that due to the hydrostatic head changes 19 and the pulse that was postulated to occur by the start of 20 the RCP, that pressure spike would have been relieved by 21 the RH3 relief valve.
22 So the POPS system was still oprable and was 23 still able to relieve when its set point sensed 375. But 24 the RH3 would relieve well before that.
25 0 Okay.
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14 1 MR. WETTERHAHN: Was that your understanding -
2 - you were asked if that was your understanding. Was that 3 also your understanding in January of 19947 4 THE WITNESS: Yes. This is my understanding 5 of the investigation that was done by System Engineering, 6 that Charlie had performed, and when I had reviewed it, 7 these were the issues that we had.
8 MR. WETTERMAHN: Thank you.
9 MR. McDERMOTT: Okay.
10 BY MR. McDERMOTT:
11 .
O The pressure spike that's assured in the 12 design basis of this system, is the injection, the start 13 and injection of a single safety injection pump into a 14 solid reactor coolant system. That would be the 15 initiating event.
16 The fact that the reactor coolant pumps are 17 running is going to cause a difference, as you mentioned, 18 between the pressure sensed by the POPS system and the 19 actual pressure in the reactor vessel.
20 A Correct.
21 Q So that when you made the statement that POPS 22 would relieve at 375 pounds, it would be at 375 pounds as 23 sensed by the system?
24 A That's correct.
25 Q And not actually the pressure in the reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRSERS 1323 RHODE ISLAND AVENUE, N W.
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2 A That's correct.
3 Q So then based on what you knew at this time in 4 discussions with Charlie, Mr. Lashkari, could the single 5 power operated relief valve relieve the pressure spike 6 caused by this desigm basis event?
, 1-7 A Well, this was not the design basis event, and 8- that's what Westinghouse was postulating, saying that if 9 this -- if the egolpment loaded in the following sequence 10 spuriously that you had to evaluate your-planIto htW nee if 11 you were susceptible, if your reactor vessel-was 12 susceptible to this pressure spike, that could exceed the 13 maximum allowable stress for the materird that the vessel 14 was made out of.
15 So we had performed that evaluation and 16 determined that that pressure spike would not occur at 17 Salea because of the modifications we had done to the 18 plant.
19 0 Okay, so your understanding was that the plant 20 would be protected from a safety perspective because of 21 RH37 22 A That's correct.
- 23 Q Okay. Now, as far as meeting your license, as 24- far as the POPS system being able to perform its function
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25 as described in its design basis, did you believe at that NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 RHODE ISLAND AVENUE, N W.
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16 1 time that it could?
2 A I didn't know whether we had a clear position 3 on the RH3 and that's why I deferred to the Licensing and 4 Regulation Department for their expertise in resolving 5 that.
6 From a System Engineering perspective, what we 7 had determined is that the plant was not challenged, that 8 our vessel was not susceptible to this type of failure 9 mechanism, and to figure out again whether the RH3 was the 10 credit that we wanted to take.
11 As I recall, there was also another option 12 where you can apply for an extension of the maximum 13 allowable stresses that the vessel is made out of. That's 14 an ASME code case.
15 So we had a couple of options in which we 16 could have responded to the Westinghouse bulletin, and 17 they appeared to be more in the realm of Licensing as far 18 as which was more advantageous in the long term, which was 19 -- which addressed short term issues, and in what 20 direction we wanted to head, that we wanted to take on 21 this.
22 So that's why it was my direction to Licensing 23 and Regulation to determine which was the Public Service 24 position. From the Engineering perspective, it did not 25 challenge che vessel on either unit.
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1 Q Okay. So is that what you're referring to 2 'when you say that this failure mechanism, your reactor 3 vessel is not susceptible to this failure mechanism, 4 you're referring to the pressurized thermal shock and 5 Appendix G limits?
6 A The start of the -- the spurious start of the 7 reactor coolant pump in Mode 5 with the other -- I'm not 5 sure of the other sequences without having a bulletin in 9 front of me, but there were a number of issues that had to 10 fall in place for this pressure spike to develop, and when 11 we had reviewed that sequence of events, it was determined 12 that the vessel would not experience.that pressure spike, 13 if that sequence of events occurred at Salem.
14 Q And it would not physically experience that 15 pressure spike because of the RH3 valve, ir that correct?
16 A Correct.
17 Q Okay. Moving on to the --
18 MR. WETTERHAHN: Let me add this. And even if 19 it -- the RH3 wasn't there, it was your understanding that 20 it would not be a safety issue because of the additional 21 margin afforded by the ASME Code, in the case he just 22 mentioned.
23 THE WITNESS: Well, yes, that was the other 24 avenue that Public Service could pursue by applying for 25 the code case that would extend the maximum allowable NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 MHODE ISLAND AVENUE, N W (202) 2344433 W ASHINGTON. O C. 20005 (20m 2344433
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I stress.
2 So that depending upon which avenue we wanted
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3 to pursue, we were covered on both cases as far as any 4 safety challenge to the vessel.
5 The approach that we would take was to be -
6 determined by Licensing and Regulation. We could do our 7 evaluation and determine what the current impact was on 8 the plant.
9 10 BY MR. LOGAN:
11 Q And you did all of this evaluation by January 12 31st, 1994, when Charlie brought the IR to you?
13 A Well, I believe Charlje har about six
- 0cimR.a4 cast $4 p)g.f4r 14 months ande was working on it. And I - ago had 15 assistance from Nuclear Engineering, from the thermal 16 hydraulic specialist, all looking at what would be the 17 magnitude of the spike, would the RH3 indeed lift and 18 relieve the pressure before you reached the 475 psi in the 19 center line of the reactor vessel.
20 So there was a significant amount of work to 21 de'.erm..ne what our susceptibility was with the sequence of 22 events.
And Charlie had been working on this for about 1
23 Q 24 six months prior to the January submittal?
25 A I believe so. As I said earlier, I think we
{FOR. )NFD ODW- 4mWW @t WT1W & N bett.Oh ~
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L 19 1 may have received the initiel documents in the June or 2 July time frame. To the best of my recollection.
3 Q Did Howned Berrick have tracking 4 responsibilities on this?
A H hT5 M h @ 2l d 5 A Howard Berrick had- PC3 was our contact in 6 Nuclear Engineering.
7 Q You say that Charlie worked with Howard on 8 this?
s 9 A Correct.
10 Q And - go ahead.
11 A It's a combined teata responding to a bulletin.
\-
12 In this particular case, System Engineering h 13 had a piece of it.
F 14 Q So Charlie had a piece of .. out Berrick had 15 the lead on it?
16 A I guess I'm -- I don't recall who actually had ,
17 the lead. I know we all had a responsibility in resolving 18 the Westinghouse bulletin. Station had a piece, Nuc3eur 19 Engineering had a piece, Licensing had a piece.
20 Q At what point was it resolved then?
21 A I think we finally resolved this in -- I want 22 to say probably October, September or October of '94, I 23 think when we put all of the pieces together.
24 Q So was it re. solved at the end of DecemLer with 25 Berrick's letter?
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20 1 A No. We had additionaliwork that was ongoing.
2 I believe the final position that Licensing-took on thin 3 was to apply for the code case in the short term'and that 4 we would look at the RH3 as a long term.
5 BY MR. McDERMOTT:
6 Q Ckay, regarding the draft incident report from 7 Mr. Lashkari, when he presented this to you, did you 8 discuss the fact that he felt that technical 9 specifications were being violated?
10 A I'm sorry, I'm reading the response. It 11 -
states here in the end -- I'll road it verbatim: "It is 12 being assumed that Salem does not use more than one RCP 13 below 200 degrees. Still Unit I tech spec heat up/ cool 14 down curve limits are violated."
15 I think-what I recall in that time frame 16 discussing with Charlie was that we still had additional 17 work to do before we could, I think, make a statement like 18 that.
19 So as far as I knew, we had not violated the 20 heat ur and cool down curves. Okay? Y 21 Q Well, the 1: sat up and cool down curves, would 22- you agree, would only be violated' if you actually,.
. -23 physical.ly had the pressure spike?
24 A Correct.
25 -Q Okay? And what we're talking about here is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER 4S 1323 RHOOE ISLAND AVENUE N.W.
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21 1 t
..nor or not the system would have proteLted the reactor 2 vessel from that spike?
3 A Yes.
4 Q That's calculational?
5 A Right. We had over pressure protection by the 6 POPS system as well as the RH3. And again, the question 7 was whether the RH3, you could take " credit for it. And 8 our scenario, as I stated before, the scenario that 9 Westinghouse presented was slightly different at Salem 10 Station because of the pressure interlock DPC that was 11 done a number of years ago.
12 Q Okay.
13 A And I can speculate that when Westinghouse 14 issued the bulletin, they didn't have the information that Pet.PetsteMHe 90 ;
15 Salem had p;rf;;;;n : desi n change. You know, it went out 16 to all Westinghouse plants for evaluation.
17 Q I would like you to take a look at a page 18 here, it's a copy of Page B344-12 of the Salem Unit II 19 technical specifications, Basis Section. Would you please-
-20 take a look at that?
21 A Okay.
I 22 Q I'll have to ask you for that back.
23 A Sorry.
24 Q In this section, it states that either POPS, 25 POPS referring to the power operated relief valves, would NEAL R. GROSS COURT REPORTERS AND TRANSCRISERS 1323 RHODE ISLAND AVENUE, N.W. l (202) 2344433 W)3HINGTON, D.C. 20005 4
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l 22 1 have cd;qucto rolicving c0pability to protect the RCS from 2 over-pressurization when the transient is limited to 3 either, one, the start of an RCP would be secondary water 4 temperatures steam generated, less than or equal to 50 5 .
degrees above the RCS cold lake temperatures, or, two, the 6 ' start of a safety injectior. pump and its injection into a
- h 7 water solid RCS.
8 The second transient there is the one of 9 interest, the start of the safety injection pi.mp and 10 injection into a water solid RCS.
11 At the time you discussed this in January, was 12 it your understanding that either PORV was capable of 13 protecting the RCS from an over pressurization resulting 14 from the start of the safety injection pump and its 15 injection into a water solid RCS?
16 Q At 312 degrees, right. Yes. And the 17 Westinghouse bulletin, I believe, specifically states 18 temperatures it t than 200 degrees.
19 So it's my understanding that the issue is 20 that when you're less than 200 degrees, that the nil-l 21 ductility limits are challenged by the sequence of events.
22 Q At what point is the POPS system required to 23 be operable?
24 MR. WETTERHAHN: If you know.
25 THE WITNESS: I believe it's less than 312 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 FHODE ISLAND AVENUE. N W.
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23 1 degrees or 350 degrees, something like that.
-2 OY MR. McDERMOTT: -
3 Q Okay. I'm going to ask you to take a look at e 4 a letter, a memorandum. It's dated December 30th, 1993, 5 from Howerd Berrick to Fred Schnarr. I'll give you a 6 moment to read that, and as a particular note, if you ,
7 would, take a look at the table in the back whica 8 summarizes the analysis, 9 MR. WETTERHAHN: Let's get some basis on the 10 record.
11 Have you seen this letter before?
12 THE WITNESS: Yes, I hav.e.
13 MR. WETTERHAHN: When did you see it?
14 THE WITNESS: I would say shortly after 15 December 30th. Maybe it was sometime in Jaratry.
16 MR. WETTE HAHN: You previously tastified that 17 you take correspondence from other groups --
18 THE WITNESS: That's correct.
19 MR. WETTERHAHN: -- and pass it on to System 20 Engineers. Is this one of the types of pieces of 21 correspondence you would have sent along?
(
22 THE WITNESS: That's correct. And what I have 23 initialed on the upper right-hand side, this looks like my 24 writing. Where I said, "For your information" to Bob 25 Lemberger and Charlies Lashkari, and I also made a note to NEAL 3. GROSS COURT REPORTERS AND TRANSPR18ER1, 1323 RHODE ISLAND AVENUE. N.W-(202) 2344433 WASHINGTON, D.C. 20005 (202) 2344433
l- 24 ,
1 1 note the procedure changes that are being identified in 2 the response from Howard Berrick. l 3 MR WETTERHAHN: Do you need a minute to 4 rtview this letter?
5 THE WITNESS: Yes. ,
6 MR. WETTERHANN: Okay.
7 MR. LOGAN: Can we go off the. record, please?
8 (Whereupon, a discussion was held off ths 9 record) 10 MR. LOGAN: Back on the record.
11 BY MR. McDERMOTT:
12 Q Mr. Wiedemann, have you had a chance to 13 refresh your memory, 'aoking through the document? Wcs 14 that document. discussed at the time, the January time 15 frame, when Mr. Lashkari was discussing with you his draft 16 incident report?
17 A I would have to assume that it was, because we 18 almost copied verbatim some of the terminology from this 19 letter and again, I get back to what I originally stated, 20 that tL,ere was a potential for this to occur.
21 Westinghouse notified the industry of this potential. .And 22 I believe what Howard Berrick has stated in this letter, 23 and I'll read to you -- he talks about that there's a 24 potential for this to occur.
25 Well, I'?.1 point out that nowhere in the NEAL R. GROSS
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. 25 IJ 1etter that was dated'in December'did we mention the RH3
? '
2 that Charlie had been working on, as well as myself.-
. 3 MR. WETTERHANN: .Okay, you were asked a 4 question whether you specifica11'y recall discussing. You-3- speculate that you might have. Do you specifically recall' 6 discussing it?.
- 7. THEWITNNSS: Specifically, no.
8 MR. WETTERHAHN: Thank you.
I 9.
10- BY MR. McDERMOTT:
, 11 Q Okay, can I refer you to the table that's 12- attached to that? And regarding-the calculated peak 13 pressures that would occur w'th i two reactcr coolant pumps 14 running, could you read for me what the predicted peak 15 pressure would be?
16 A In Unit I, the manimum pressure with 2-RCP's 17 running -- and I'm assuming this is outside of how we 18 operate. The issue that Westinghouse is referring to is
- 19 when you're on RHR cooling. So we d.on't have the reactor 20 coolant pumps in service.
f' 21 So-I think what he's postulating here is that 22 on a. spurious start of two reactor coolant pumps, the Unit 23- I pressure was calculated:to be 485 pounds. And the Unit l
24 II was 485, 485 pounds as well. So it's the same for both 25 units. ,
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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26 1 Q Mr. Wicdsmant;. what gave you the understanding '
3 2 that it required the spurious start of reactor coolant 3 pumps?
4 A During the Mode 5 conditions, the reactor 5 coolant pumps are out of service.
6 0 Okay. And is there a potential for reactor 7 coolant pumps to be in service below 312 degrees?
8 A As se either heat the plant up or cool the
, 9 plant down, we will place reactor coolant pumps in service 10 as an attempt to heat the plant up and we drop reactor 11 .
coolant pumps out of service as we're cooling the plant 12 down.
13 Q Is there a potential for reactor pumps to be 14 running with the plant below 312 degrees?
15 A Possibly. But it's either a -- it's a planned g09t 0T)0v M 4W6 16 weal m en. It's not a spurious start.
17 0 okay. During my inapection of this issue in 18 t.he December time f rame, I was told that, in the December 19 '.93 time frame, that there was no procedural requirements 20 existing at that time to restrict the number of reactor 21 coolant pumps operating'below 312 or even in Mode 5. Is 22 that your understanding?
23 A There may not be procedural guidance but our 24 mode definitions restrict us as far as RCS temperatures.
25 So you cre allowed to place RCP's in service as you're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE l'LN2D AVENUE, N W.
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27 1 heating the reactor coolant system up, but by definition, 2 being in Mode 5 requires that you're on RHR cooling.
3 So in the Westinghouse scenario, again, as I 4 recall the Westinghouse scenario, is with -- our concern 5 was with the reactor coolant levels and 200 degrees, so 6 that, by definition, has us in Mode 5 operation, without
~
7 any RCP's in service.
8 So that's why I'm sayi_; that that would be a 9 spurious start of a reactor coolant pump. That's my 10 understanding of how this pressure spike developes.
11 0 So you -- do you have any knowledge of any 12 procedures that would limit you.from running rea,: tor 13 coolant pumps when you're below 312 degrees?
14 A I don't have any knowledge of that. I will 15 defer to the procedure writers or the 0:>erations 16 Department for the specifics of that. What procedures are 17 in place which covers which pumps go in operation, that 18 sort of thing.
19 Q Okay. As far as Mr. Lashkari's explanation to 20 you of this concern, in his draft incident report, he 21 refers to Westinghouse has now calculated --
22 MR. WETTERHAHN: Can we get that back, please?
23 BY MR. McDERMOTT:
24 Q Westinghouse has now calculated dynamic effect 25 of 31 psi for one RCP operation. When this 31 psi is NEAL R. GFK3SS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHOD 8! ISLAND AVENUE. N W.
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I 28 1 added to the 446 psi, which is peak RCS pressure, due to 2 POPS set point at 375 and the transient causing RCS 3 pressure increases.
4 Although the wording of that may be difficult 5 to understand, what was your interpretation of what Mr.
6 Lashkari was trying to tell you at that time?
7 A This is a -- it's simply a repeat of the 8 Westinghouse bulletin as to how you can achieve a pressure 9 spike in a reactor vessel .inder a specific sequence of 10 events occurring.
11 And essentially what Charlie is trying to say 12 here I believe is he's recouping the Westinghouse bulletin 13 in a couple of sentences.
14 Q Okay. And did you believe at that time that 15 you would have no reactor coolant pumps running?
16 A As I stated earlier, the conversations that we 1
17 had in January time frame was that we had a numbar of 18 options in which to address the bulletin. Both options 19 were available and in place, and insured that we didn't 20 challenge the reactor vessel, and that it's a question for 21 Licensing to determine which position we wanted to take, 22 and again it gets us back to whether we could take credit 23 for the pressure spike mitigation by the RH3 valve.
24 Uow, Charlie was aware of that and I believe ,
25 thct was part of the discussion that we had, that Charlie
, NEAL R. GROSS COURT REPORTERS AND TRAWSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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. 29 I cnd I had, that indicated it was premature to submit the 2 incident report at this time before we had completed our 3 evaluation and determination as to what you could take 4 credit for.
5 Q Did you and Mr. Lashkari have a disagreement 6 on whether or not RH3 could be credited for negating'this 7 transient?
8 A Well, Charlie didn't know if we could take 9 credit for it. I didn't know whether we could take credit 10 for it. But we both recognized that the physical location
, 11 of the RH3 in the plant was below the pressure tap set 12 points that Westinghouse had, so it eliminated the concern 13 with the static elevation change and it was also in a 14 position at the same size valve as the POPS, so in one
- 15 aspect, it looks like you have three valves available to 16 relieve the pressure, but they're located at different h
c 17 elevations.
18 So to ancwer your specific question, did 19 Charlie and I have-the same understanding that the RH3 20 could relieve the pressure spike, yes.
21 It was a question of whether -- how do you 22 take credit for it, and that was outside of the System 23 Engineering function and that's why we sent it to 24 Licensing. So to write the incident report at that time
. 25 was premature.
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30 1 Q So the fact that you knew you needed to take j 2 credit for RH3 --
3 A Or the code case.
4 Q -- or the code case, wouldn't that indicata 5 that you knew that the PORVs that were defined as part of 6 the POPS system, that one of those valves alone would not 7 be able to mitigate the transient?
8 A Well, the Westinghouse bulletin was that your 9 vessel was susceptible to exceeding the maximum allowable 10 stress because this pressure spike would develop. But if 11 you could show that the pressure spike couldn't develop, 12 then we weren't outside of the heat up and cool down J3 curves and we weren't outside of a POPS non-conservative.
14 Q So the pressure spike, in having to consider 15 the pressure spike at all, is not part of the Westinghouse 16 document. I can give you a copy of that now, to review.
17 It's the Westinghouse NSAL, March 15th, 1993. I'll give 18 you some time to review that.
19 MR. LOGAN: We'll be off the record for a 20 minute.
21 (Whereupon, there was a discussion held off 22 the record) .
23 MR. LOGAN: We'll be back on the record.
24 MR. McDERMOTT: It's just general.
25 MR. WETTERHAHN: Wasn't there a pending NEAL R. GROSS COURT REPORTER $ F ' V4 SCRIBERS 1323 RHODE L .6NUE, N W (202) 23u433 WASHINGTON. O C. 20005 (202) 234-4433 -
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, 31 1 question?
2 MR. LOGAN: He asked you if you-were familiar 3 with it.
4 He's looked at it and'he's now familiar with ;
5 it.
6 MR. WETTERHAHN: Wasn't there a pending 7 question with regard to some question of whether it was a 8 pressure spike or a pressure spike in there.
9 MR. LOGAN: Okay.
10 MR. WETTSRHAHN: So we're going to go back to 11 -
that question. -
12 MR. McDERMOTT: We're going to go back.
13 MR. WETTERHAHN: You're now familiar with it?
14 THE WITNESS: Yes.
15 MR. WETTERHAHN: Okay, thank you.
16 BY MR. McDERMOTT:
17 Q Mr. Wiedemann, would you agree from your 18 previous reading of the technical specification basis for 19 this system, that the POPS system is designed to micigate 20 a pressure transient that's caused by the injection, of 21 the safety injection pump into a water solid RCS?
i 22 A That's correct.
23 Q Okay. And then further that the Westinghouse 24 letter that you've just finished reviewing indicates that 4
- 25 there may be a difference in the sensed pressure when the NEAL R. GROSS COURT 9EPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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32 1 POPS systcm would respond, and the actual pressure at the
~
2 midpoint of the reactor vessel?
-3 A Well, what the Westinghouse bulletin says is 4 that there is a potential that the set point may exceed 5 cold over-pressurization limits. It says an additional 6 evaluation, in order to confirm continued structural 7 integrity of the reactor vessel, is not required. Until 8 such time as you can determine applicability of this issue 9 to your plant, reasonable assurance of safe plant 10 operation is provided by the results of post event stress 11 analysis, so on and so forth.
12 And then it also says, this issue is not a $
13 substantial safety hazard because the pressure increase is 14 bounded by the previous post event stress analysis and as 15 a result, the integrity of the vessel has not been 16 impacted in regards to public health and safety.
17 This information is provided so that assurance 18 of safo plant operation and determine applicability of 19 your plant.
20 So that's what we were doing, determining the 21 applicability of this bulletin to Salem Station.
22 Q I would like to refer you to Sheet 4 of 5, 23 Item No. 1.
24 A Under Issue Description?
25 Q Yes.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
33 1 A Okay.
2 Q Would you read that statement,_please?
3 A. As a result,cthe following non-conservatisms-4 were identified. For the design basis mass injection 5 transient under normal full flow circumstances, the 6 pressure at the reactor vessel core mid-plane elevation 7 used for Appendix G, Pressure Limit, is anticipated to be 8 less than 100 psi above that measured at the wide range 9 pressure instrument.
10 Q Okay. So in substance, what this letter is 11 telling.you is that there is potentially a difference 12 between the pressure at the critical point in the reactor 13 vessel and the pressure --
14 A At the mid plane.
15 0 -- Right, at the mid-plane, versus the 16 pressure that's measured by the system.
17 A That's sensed by the POPS instrumentation, 18 that is correct.
19 Q Okay.
20 MR. WETTERHAHN: Does that item give any 21 specific delta? It says it could-be -- it is less than 22 100. Could-it be 17 If reading that letter.
.23 THE WITNESS: Well, what we had to look at, 24- again, is could this pressure spike occur at the midpoint .
25 elevation of the reactor vessel, and in order for the NEAL R. GROSS COURT REPORTERS AND TRANSCruBERS
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34 1 spike to occur, it means you can't relieve the pressure.
2 If you were able to relieve pressure, then you 3 would not get the spike. And that's our applicability to 4 Salem, we verified that you couldn't achieve that pressure 5 spike at Salem Station.
6 MR. WETTERHAHN: Thank you.
7 BY MR. McDERMOTT:
8 Q Okay, the pressure spike you're referrine to 9 is the result of the mass addition transient, correct?
) 10 A Right. That's -- I don't think it's just 11 limited to this. It's any pressure spike that would occur 12 under these Mode 5 conditions.
) 13 Q Okay. But that should be bounded by the 14 design basis of the system, correct?
15 A Correct. Yes.
16 Q Okay. So given the fact that you have to 17 consider the poscibility of having that mass addition 18 transient and now you've added information, new in 19 information from Westinghouse that says that your POPS set 20 point may be off by something less than 100 pounds.
21 What does that do to your original analysis k 22 for the POPS peak, design basis transient pressure?
23 A The original analysis, Westinghouse had 24 postulated a new scenario, and you were to evaluate your 25 original analysis to see if this scenario was applicable NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVENUE, N W.
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35 1 to your plant. ,
2 Q Okay, what was-the peak pressure in the
~
3 original analysis, do you recall?
4 A I don't know.
5 Q Can you tell me if that's written on the draft 6 incident report from Mr. Lashksri?
7 A Charlie has written -- when this 31 psi is 8 added to 446 psi, which is peak RCS pressure due to POPS 9 set point at 375.
10 Q Okay. So is it your understanding that that 11 446 was the original peak transient pressure?
12 A No, I don't know where the 446 cane from.
13 Q If you would refer again to the December 30th -:
. 14 memorandum --
15 A Mr. Berrick --
16 MR. WETTERHAHN: Here, I've got a copy.
17 BY MR. McDERMOTT:
18 -Q And if you would, please, refer to Table I of 19 that document again?
20 A Table I. Yes.
23 Q Third column of that tabJe indicates that the 22 maximum pressure calculated in the POPS analysis was-446 23 psig?
24 A Correct.
25' Q Okay. So Mr. Lashkari's incident report, it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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36 1 cppocrs to ma that he was indicating that the 31 psi had 2 to be added to the original peak based on the concerns 3 raised by Westinghouse.
4 A Yes, this is a concern raised at those 5 Westinghouse plants that would isolate the RHR system at 6 375 psi because they have a pressure interl?ck between the 7 RH1 and RH2 ise),rtion valves.
8 So Charlie was aware, and I had discussed this 9 on many occasions with him, that the PT-403 and 405 interlock had been removed by a design change years ago, 10 11 in 1988, 1989 time frame, so tnat he would not have the 12 same pressure spike develop at Salem Unit I or Unit II 13 that would cause this spike to occur.
14 Q that peak pressure would not occur because of 15 RH3?
16 A That's correct.
17 Q Oksy.
18 A And I believe that was also Charlie's 19 understanding as well.
20 C Okay. Was the POPS system, as de.stribed in 21 your license being the two PORVs, would either one of 22 those PORV's been able to mitigate this pressure 23 transient, given the fact that you had, at that point, 24 unlimited cooling pumps potentially running?
25 A Well, that spike wouldn't occur, so it would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2h33 WASHINFTori D C. 20005 (202) 23 4 433
l 37 1 have relieved at 375.
2 Q And that's based on RH3?
3 A That's correct 4 0 Okay. Assu;ning RH3 f ails, because that was 5 not part of the system as reviewed and approved for 6 mitigating this load tempecature over pressure transient.
7 A As far as what was currently written in the 8 FSAR, we did not have credit t aken for the RH3. That's 9 correct. And again, that was our position that we '.ad to 10 determine if you could take credit for the pressure 11 -
relieving capacity of the RH3 valve.
l 12 Now, if you want postulate that the RH3 would 13 fail as well, I think we're getting outside of the realm 14 of how many failure you have to postulate.~ M fe*rc.
15 0 What you're doing, in effect, is crediting the 15 valve that was not part of the system originally analyzed.
17 A Well, we didn't know whether we could take 18 credit for the RH3 or not, so I suggested --
19 Q Was the RH3 valve described in the basis for 20 that system?
21 A It's ner. written here in the basis for the 22 POPS but it appeared to be the method that the RCS wruld 23 relieve its pressure, should this particular scenario and 24 sequence of events occur.
25 So you could have a situation where you are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W
i .
38 1 not on-the RHR system, so-the RH3 would not be available, '
i .. .
2 but-that is not the case in the Westinghouse event that 3 they're postulating, specific'to a reactor coolant system 4 temperature that' corresponds to being on RER.
5 Lo if we have to postulate that the reactor 6 cooling system is less than 200 degrees, which is where 7 the Westinghouse bulletin comes into effect, then it's 8 perfectly reasonable to assume that when we're at less 9 than 200 degrees, the plant configuration is on RHR. So 10 while we're on RHR, we also have the additional benefit of 11 the RHO val e, so the question is, in Licensing space, not 12 in the reality of how the plant is operating, but in 13 Licensing spacu, do we credit ourselves for the RH3, or 14 could you take credit for the RH37 15 I didn't know. Charlie didn't know. And it 16' appeared that this is something that should be resolved by 17 the Licensing Department.
18 Q Answer this for me, please.
~
19 A That's what I said.
20 Q In the December / January time frame, did 21 calculations for peak pressure show that a single PORV
- 22. would be able to mitigate the. transient?
23- A If you had isolated the RHR syst sm, that is 24 correct.
25 -MR. LOGAN: No.
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I.~ 39 1 BY MR. McDERMOTT:-
2 0 The question was, did calculationJ for the 3 POPS system show that a-single-PORV would be able to 4 mitigate the transient?
4 5 A I don't know.
6 Q I refer you again to the table in the back of 7 the December 30th memorandum.
8 A From Mr. Berrick?
9 Q Yes.
10 A Right. I believe Mr. Berrick's memo does not 11 use any pressure relieving for the RH3.
12 Q That is my question to you.
13 A' All right.
I 14 Q Without RH-3 --
15 A In this memo from Howard Berrick to the 16 Reliability and Assessment Group, I did not see any 17 mention nf the RH3 valve.
18 0 Okay.
19 A But the acenario that's being postulated to
-20 occur will only occur with the RH3 available and in 21 service. So it appears that this did not take into 22 consideration that the pressure spikes that Mr.-Berrick is 23 postulating would not occur at Salem because the RH3 would s
24 relieve.at 375 pounds.
25- Q What we're discussing now, sir, is more of a NEAL R. GROSS
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40 1 Licensing issue.
(
2 A Okay.
3 Q And what I'm asking you is that the analyses 4 that were performed, okay, which added the instrument 5 delta due to reactor coolant pumps, when that was added to 6 the original POPS analysis, which considered a single 7 PORV, as described in the tech spec basis, would that have 8 kept the peak transient pressure to below the limits, PT 9 limits, for Units I and II7 >
10 11 A That was a long question. The pressure spike 12 would not have been mitigated by the. POPS valve, if it's 13 set at 375 psi.
14 Q Thank you.
15 MR. WETTERHAHN: On that same table, okay, 16 there is another column. It says tech specs, PT limits, 17 minimum pressure plus 10 percent, did the memo that was in
- 18 your possession take credit for an additional 10 percent 19 margin?
20 MR. LOGAN: You're referring to the 21 Westinghouse memo?
22 MR. WETTERHAHN: No, this is the Berrick memo.
23 MR. LOGAN: Okay.
24 THE WITNESS: Specifically, I thought that 25 what we had to do was apply for the acceptance of the code NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W
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1
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41 l 1
case that would allow for the extension of the allowable 2 stress. MR. WETTERHAHN: Okay. If the code 3 case was applicable and you could ake credit for it, even 4 without the POPS -- without the RH3 valve, would you have 5 been below acceptable valves and thereby safe at the time?
6 THE WITNESS: Correct. The code case, as 7 identified in the Westinghouse bulletin, allowed you the 8 additional margin that showed that the pressure spike did 9
c.u+ < @ &
not ch;nnel int the vessel. But regardless of whether 10 the code case was applicable or not, we did not challenge 11 the vessel integrity because of the-way the Salem systems 12 are designed.
13 BY MR. McDERMOTT:
14 Q Because of RH3?
15 A That is correct.
16 Q Okay.
.17 A Now, when we would have isolated RH3, then the 18 bulletin is no longer applicable because we're above 200 19 degrees, and that was very clear to Charlie.
20 MR. WETTERHAHN: I have nothing further on 21 that.
22 BY MR. McDERMOTT:
23 Q Could you point out to me, please, where the 24- bulletin says that this only-applies below 200 degrees, 25 the Westinghouse NSAL letter?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHOCE ISLAND AVENUE. N W (202; N33 WASHINGTON. D C. 20005 (202) 234 4433
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l 1 A It has to do with the Appendix G limit, and 2 the limit -- it's my understanding the limit is chal'lenged 3 when the vessel temperature is below 200 degrees, so 4 that's your lowest point on your allowable stress, as far 5 as nil-ductility.
6 Q So below 200 degrees, the Appendix G curves 7 are most restricted?
8 A That's correct.
9 Q However, the POPS system is required to be 10 operable whenever the reactor coolant system temperature 11 is below 312 degrees, is that correct?
12 A That's correct. So if you were to evaluate 13 where your POPS would be non-conservative, and the non-14 conservative is cetermined by how it challenges your 15 Appendix G limits. I believe that's what the crux of the 16 Westinghouse bulletin is, 2;; rex;;;t-
$W ____.
17 Q Going back to Mr. Lashkari's draft incident 18 report, at the time the two of you discussed that issue, 19 did Mr. Lashkari raise any concern about taking credit for 20 the ASME code case without prior NRC approval?
21 A I don't recall. As I recall, the nature of
,, 22 our conversation was that we didn't have a safety concern 23 as far as vessel integrity and that this was more of a 24 Licensing space issue to. determine what was the direction 25 we wanted to take. Did we want to apply for a code case?
T NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVENUE, N W (202) 234M33 WASHINGTON. D C. 20005 (202) 234M33
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<- 43 1 Did we want to take credit for the RH37 '
2 O What process did you use to communicate this 3 ' issue to the individuals you felt were responsible for 4 Licensing issues?
5 A As I recall, I had asked Cha< lie to get in-6 touch with Licensing and get them involved, so we could 7 determine -- we, moaning Public Service -- could determine 8 how we felt best to respond. Did we want credit for the 9 RH3 or did we want credit for the code case?
10 Q Had you considered at the time -- at that 11 -
time, having Charlie or yourself write a DEF on this 12 issue?
13 A I'm not sure if :har13e was going to write one 14 or-if I asked Charlie to write one. I don't recall.
15 BY MR. LOGAN:
6 16 0 You did discuss it, though?
17 A I believe a DEF came up at some point, but I'm i
18 not able to recall the specifics of it, when or where. We 19 have an organization that respends to DEF's. I don't know 20 if-that DEF came Lp as a result of Howard Berrick's work.
21 I thought there was one thet somebody was pursuing on 22 this.
23 Q What's the purpose of the DEF7 1
L
, 24 A It's my understanding that if you have a 25 deficiency that you're not really sure how it impacts the i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS L i323 asooE isuNo AvtNus. N w.
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1 design of the plant, you think that there is an anomo1y * ,
2 between maybe what is written and what is actually 3 installed, that it's evaluated to determine corrective 4 action, if any is required.
5 Q Isn't that the issue here? Isn't that what 6 you just said, that you told Charlie to do? j 7 A I guess you could look at it --
8 Q Resolve the problem and --
9 A Sure.
10 Q And wouldn't a DEF have been the appropriate 11 method of resolving that problem, since you were against 12 him forwarding the IR7 13 A Well, the incident report wasn't at a stage 14 where we should submit it. We had -- there was additional 15 work - "we" meaning Public Service -- had to do before we 16 determined that we met the criteria for an event that 17 needs to be documented as an incident report.
18 0 But didn't Charlie feel that it was at the 19 point where he needed to send it forward.as an incident 20 report?
21 A Charlie had -- it looks like we paraphrast 22 the letter from Mechanical Engineering and was going to 23 submit an incident report in the January time frame.
24 And again, as I had stated earlier, we were 25 not finished yet with our work in determining whether the NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHODE ISLAND AVENUE. N W.
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45 1 RH3 could be taken credit for, or whether we wanted to i 2 take credit for the code case, and in either event,'in 3 either course of action, there was no event La far as 4 violating the structural integrity of the vessel. ,
5 So tn submit an incident report that says we 6 are violating the cool down curves, was premature. And I 7 believe, as it's turned out, we have not violated the heat 8 up and cool down curves that challenge the vessel 9 integrity.
10 0 Okay.
11 A That was my understanding in January.
12 13 BY MR. McDERMOTT:
14- Q Although the werding of this draft incident 15 report-may be open to some question, the concept of the 16 POPS system ar, described in the tech specs not being able 17 to mitigate the transient, appears to have been a concern 18 of Mr. Lashkari's, is that correct?
19 A No .- Tne way the incident report is written, 20- it appears that Charlie's concern was that we had violated 21 the Appendix G cool down curven. He says that the heat 22 up/ cool down curve limits are violated, and I don't feel 23 that that was our position in January, that the pressure
-24 spike, should this scenario occur, would have been .
25 mitigated and we would not have violated the curves.
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, 46 l 1 So'egain, it was an issue'as to what we wanted '
l 2 to take credit for. Code case or RH3.. ;
3 -Q Wh'o makesijudgment calls on incident reports ;
4 aslfar as whether or not it impacts system operability?
5 A The NAP determines what is the criteria for an 6 event, and then based on meeting that criteria determines 7 whether an incident report is required.
l 8 Now, anyone'can write an incident report and 9 it's brought to the Operati ms Department- for their ,
10 review. If you look at our incident report form, it's v
whoever reports it, and it's not restricted to just the 12 domain of the system engineer, then ,it is given to the 13 operations Department for their initial review, 14 Q Okay.
15 A So it does not require my approval. It does 16 not require my authorization to submit an incident report.
17 I guess why I'm stating that, if Charlie felt that l 18 this-was an incident report, there was nothing in the L
19 program that would have prevented him from giving this to 20 the shift.
21 MR. WETTERHAHN: Did you forbid him to give it 22 to the shift?
23 THE WITNESS: No, I didn't forbid-him. I l
24 believe we had an understanding that there was additional i
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i 47 1 whether the RH3 or the code case was the method that i 2 showed we didn't violate the curves.
3 It appears that as it's written, what this 4 tells the Operstions Department on Unit I side is that we 5 had violated the heat up and cool down curves, and I don't 6 think that's the case and --
4 7 BY MR. LOGAN:
8 Q But clearly, while you're stating you didn't 9 forbid him to send that forward to the shift supervisor, 10 you clearly made him aware that you felt that you didn't 11 want it to go forward because he was wrong; is that 12 correct?
13 A No, not necessarily because he was wrong.
14 It's because we had additional work to perform that-would 15 show that we didn't violate the curves. I don't think I 16 told Charlie he was wrong.
17 Q Well, he's saying that you violated the curves 18 and you're saying he's saying you violated the curves, and 19 he turns around -- and you turn around to him and say we 20 didn't violate the curve, and that's what's written here, 21 then you're telling him he's wrong.
22 You're saying that the IR says you violated 23 the curve. You're telling him, Charlie, we didn't violate 24 the curve. Isn't that the same as saying you're wrong?
25 A You could look at it that way, sure.
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48 1 MR. WETTERHAHN: In a hypothetical, based upon 2 your knowledge of incident reports, if this had been' 3 filed, would the senior nuclear shift supervisor have 4 sought information from Licensing and Engineering to 5 determine whether the assertions were correct?
6 THE WITNESS: Absolutely. The shift is made 7 aware of it, and then it would come back to either System 8 Engineering or Nuclear Engineering for evaluation.
9 BY MR. LOGAN:
10 0 s o you would have had to resolve this question 11 eventually?
1 12 A A piece of it would have come back to us and 13 we would have said it's either the RH3 or the ccide case.
14 Go to Licensing and get it resolved.
15 Q And how long did it actually take to resolve 16 Mr. Lashkari's concerns as they were raised in this 17 incident report?
{ 18 A I don't think these were Charlie's concerns.
p 19 This is a synopsis of the letter that we received from 1
20 Howard Berrick that was analyzing pressure spikes.
21 Q That doesn't -- how long would it have taken 22 to resolve the concerno that are raised in thi,s incident 23 report draft?
t l
, 24 A Well, I think most of the work in this 25 particular case was 90 percent completed. So my gut feel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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49 1 is that the last remaining piece was to determine from a 2 Licensing perspective, which direction Public Service 3 wanted to take. Short term, long term, code case, RH3.
4 O But isn't it true that it took at least until 5 October to resolve this POPS issue?
6 A I think that the final documents were 7 submitted to SORC in around that time frame.
8 Q And had this gone forward as an IR in January, 9 you wouldn't have had until September or October to 10 resolve the problem. That would have placed a greater 11 burden on you -- not you, John. Wait a minute. But you, 12 Salem, to resolve this question soon.
13 MR. WETTERHAHN: Could you comment on that?
14 THE WITNESS: I'll comment on it. I would 15 think that the incident report resolution at this point 16 would still go back to Licensing and Regulation because we 17 had completed the Engineering evaluation that showed or 18 our assessment was that this spike could not occur at 19 Salem, Unit I or Unit II.
20 So therefore I don't think there would have 21 been any additional work for Salem Station. It appeared 22 that the responsible party was still Licensing and j 23 Regulation.
l 24 BY MR. LOGAN:
25 O Clearly, this IR goes forward, the burden is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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50 1 on Salem to resolve the issue quickly, not wait until 2 September or October. So there's intentive then for this 3 not to go forward.
4 A No, I can't agree with that. I would say that 5 the resolution of an incident report, the speed at which 6 it's resolved, is directly related to the significance of 7 the incident report.
8 If there is a safety concern, if there is a 9 challenge to nuclear safety, plant safety, plant 10 operability, then that would have a higher level of 11 intensity in resolving it, as opposed to something that is 12 more of a documentation type issue, as to whether there is 13 an actual need to make a change to the plant, versus a 14 need to make changes sc, as to documentation, to insure 15 that the documentation is in line with bulletins or 16 information notices.
17 Q But clearly, if that IR goes -- had that IR 18 gone forward, there would have been an item on somebody's 19 plate that would have had to have been resolved, and by 20 telling Charlie or by dissuading Charlic, for whatever 21 reason, not to go forward with this, you kept the IR out 22 of any tracking system, or this issue out of any tracking 23 syster; is that correct?
24 A No, that's not true. The ATS item that was 25 assigned to the various departments at Salem, will remain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 13r] o- OE ISLAND AVENUE. N W (202) 2344433 ONGTON. D.C 20005 (202) 2344433
51 3 open'until they're finally approved. It's independent of 2 whether an incident report is written or not.
3 Q There was an.open ATS item on this? ,
4 A We have an open ATS item or had an open ATS Co**C yb Wale 5 item that C.'.c.zlie was responding to. So his response to 6- this issue would then kick off the Licensing and 7 Regulation piece.
8 As a supervisor, I directed Charlie to send 9 this to the Licensing and Regulation _ Department to 10 determine whether we could take credit for the RH3 or the 11 code case.
12 Q But didn't Howard Berrick --
13 A That still stays open. Sorry.
14 Q But didn't Howard Berrick's letter of December 15 30, 1993, conclude by saying the ATS open item and NSAL-16 PSE-93-204 is considered closed by this letter? Take a 17 look at that.
18 A His task on this ATS item -- this ATS item can 19 have multiple tasks in multiple groups. Howard Berrick's 20 piece to calculate, maybe a pressure spike, was complete.
-21 His assignment -- and I'm speculating as to what exactly 22 his assignment was in the ATS system.
23 But what I want to make clear is that because 24 Howard Berrick closed out his response to this issue 25 doesn't mean that the Public Service response is complete.
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52 1;
2- Q And who would be the custodian of records for 3 the ATS items so that we could review what offices and 4 what individuals were responsible for certain ATS items -
5 with regard to the Westinghouse letter?
6 A The Salem Station ATS Coordinator would be the 7_ person to speak to.
8 Q And who is that?
9 A Right now, I believe it's Fred Wiltsee, who 10 works in part of the GM staff. But we coordinate our ATS 11 responses so that finally one complete document will be 12 issued. So Howard aerrick's piece inay have been done, but 13 it doesn't -- by no means does that indicate that the ATS 14 item is complete.
15 Q I think that's something we need to look at.
16 BY MR. McDERMOTT:
17 Q So your recollection is that you still had an 18 open ATS item on this issue?
19 A Well, Charlie was working on the Westinghouse D ifd6WTW Aw9% Soc.4and.
20 bulletin or the advisory letter, d ATS item.d Thatwash 21 his assignment.
22 Q So you know if he was working in conjunction-
- 23 with someone in Howard Berrick's group?
24 A Yes, It's my expectation that the system 25 N hY engineer would work with Nuclear Engineering in resolving NEAL R. GROSS
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53 1 all of the issues.
2 0 So even though Mr. Lashkari was perhaps 3 working with Mr. Danak, I belive, in Howard Berrick's 4 ' group, they would have -- they were working together on 5 the project to resoh_ the NSAL ccncerns, but they would 6 each have an ATS tracking item?
7 A Right. They would have a different C,H4tu6 elo sWT H&6 M 4h IM 8 responsibility. 4 m o m 6Pdt,lP W Wts"TD ff>4. .
9 Q Okay. We_'ll need to do some further research 10 into that.
11 BY MR. LOGAN:
12 Q Let me ask you a quick couple questions.
13 A Sorry, before we leave that, in the ATS world, 14 Action Tracking System, there will be tasks and then there 15 will be subtesks and as you complete say multiple 16 subtarks, then that will result in completing a task. So 17 there are multiple pieces in the ATS system, and one piece 18 of that can come to the System Engineering Group. ,
19 Q Hopefully Mr. Wiltsee will be able to resolve 20 that issue for us.
21 A Why I'm clarifying that is because we have a 22 Salem Station ATS Coordinator that will insure that those 23 items that_are assigned to departments w3 thin Salem are 24 tracked. There may -- there has to be an ATS Coordinator
. 25 for Nuclear Engineering as well. Or each department will
- NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 2344433 WASHINGTON, D.C, 20005 (202) 23u433
54
-1 have an ATS Coordinator.
22 So the Salem Station's piece-may be just one 3 part of the overall response.
4 Q Unless you can-tell me what the ATS tracking 5 number was for Charlie Lashkari's resposnibilities?
6 A That would be under the Westinghouse bulletin.
7 I'm not sure of the exact number, but I would offer that 8 in the ATS system, that it would be under Westinghouse 9 NSAL-93, but'I'm not sure' what his task or subtask was.
10 But that's how we would control the work in the ATS 11 system.
12 MR. WETTERHAHN: That's 93005B or 0057 13 THE WITNESS: I'm not sure.
14 MR. WETTEWAHN: Okay.
15 BY MR. LOGAN:
16 Q I would li.se to ask you about two memos, 17 neither one of whom I believe is addressed to you, but l
l 18 both appeared to be authored by Charlie Lashkeri. One is i
L '19 from Lashkari to the Technical Department Manager dated i
I 20 January 30, '94 and the other one is from Lashkari to John 21 Morrison, Manager, Salem. Technical Department, dated April 22 22nd, 1994.
23 I'll ask you to look at the first one, January
- 24. 30th, and tell me if you. recognize that memo. "
l 25 A No, I do not.
l NEAL R. GROSS COURT REPORTERS AND TRAN3CRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON, 0 C. 2000$
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55 1 ? Have you ever seen it before?
I 2 A I've seen them before in the course of this. l I
3 Q But not in the January time frame -- l 4 A That's correct. l 5 0 -- or the following several months?
)
6 A That's correct.
7 Q Okay, the second memo dated April 22nd, do you 8 recognize that one?
9 A No.
10 Q So assuming Mr. Morrison received it, he 11 -
didn't share that with you either, is that correct?
12 A To the best of my knowledge.
l 13 0 Okay. So within the time frame April through 14 perhaps September, October, you hadn't seen that?
15 A Well, I guess, looking at this, I would have 16 to say I wondered whether Charlie sent it. Because John 17 Morrison would take those issues that are applicable to 18 the NSSS Group and then send them to me.
19 Q We'll have to ask Mr. Morrison that question, 20 but what we're looking at right now is whether or not you 21 had seen it.
( 22 A I don't recall seeing this.
l
! 23. Q And even if Charlie hadn't sent it to Mr.
l 24 Morrison, that still would not have precluded him from
! 25 sharing that with you prior to him doing something?
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56 1 A That's correct. I would think that the normal 2 work sequence, our reportability in the Tech Department is 3 that the system engineer reports to the group head, so in 4 these two memos where Charlie would send this to the Tech 5 Department Manager --
6 O It's outside his chain of command? -
7 A It would be something that, based on who it 8 was sent to, I'm out of the chain, so it wouldn't surprise 9 me that I hadn't seen this.
10 Q That was why I asked had you seen it because 11 perhaps he was sending it directly and did a for-your-12 information copy to you prior to the time or whether Mr.
13 Morrison may have shared it with you. But that was the 14 key, had you seen it.
15 A I think the other thing I'd like to point out, 16 in our other documents that we've shown this morning, 17 there's always, at the end, an attachment list or perhaps -
18 a copies list, and none of these have that. So that kind 19 of. indicates to me that perhaps these weren't sent.
20 0 or they weren't sent with the proper 21 distribution markings on it afterwards.
22- A_ Or that nobody was to get a copy of it.
23- Q Perhaps.
24_ A Speculation.
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57 l' do, though, is to get to what did happen and not what 2 might have happened.
3 BY MR. McDERMOTT:
4 Q Were you aware, at any time, of Mr. Berrick or 5 Mr. Ranalli instructing Mr. Lashkari not to report this 6 POPS issue to the controller?
7 A I am not aware of that.
8 Q Okay. And just one more thisg I want to clear 9 up on. In general, incident reports, defici.encies, and 10 action tracking system items, is there a general hierarchy 11 between those three systems as far as the length of time 12 that's taken to resolve icsuest 13 A It's a function of the significance of the 14 issue. If it's an important ATS item that challenges the 15 continued operation of the plant or plant safety, that 16 would have a very high focus en it.
17 0 Would that siso result in an incident report l
18 or a DEF out of it?
19 A It can, yes.
20 Q Would it necessarily?
21 A I'd have to say not necessarily. You can have 22 an incident report that does not result in a DEF. You can 23 have a'DEF that doesn't result in an incident report. You 24 can have an ATS item that doesn't result in either a DEF 25 or an incident report, or'you can have a combination.
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I 58 1 Q What I was referring to, your statement was if ,
2 you have an ATS item that has a issue in it that would 3 potentially affect operability, would that necessarily 4 result in an incident report or a DEF7 5 A Perhaps. You can have an incident report 6 written but not a DEF. Or you can have a DEF written and 7 not an incident report. And both items may impact 8 operability of the plant. ,
9 Q Both those systems would be appropriate means 10 of notifying other individuals of an operability concern?
11 A Correct.
12 Q Okay. Now, the time frame associated with 13 resolution of ATS items, ball park, is it 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />? Is it 14 six months? Is it --
15 A It depends upon the issue. Historically, I 16 would say we look at three months, six months. If the 17 work isn't done at the end of three months or six months, 18 then we will request an extension, what we feel is an 19 appropriate length of time to get the final answers.
20 Q How about an incident report?
21 A Well, an incident report will require a root 22 cause evaluation and that is determined in accordance with 23 the NAP as far as the depth of the root csuse that's 24 needed, and there are a number of -- I believe there are 25 six different processes that you can use to determine the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. D C 20005 (202) 2344 433
+
59 4
- 1. root cause.
2 And how that relates-is depending upon which 3 of the six that you follow that dete.rmines how long the 4 ATS item-is assigned or, you know --
5 .
Q .How long would an incident report sit before 6 initial operability determination is made?
. 1 7 A Well, the initial operability, determination is 1 i
3 made by the Operations Department, and in conjunction with 9 the initiator of the incident report.
10 0 And how long would that take for them to do 11 the initial operability determination?
12 A I don't know. I assume that occurs very 13 rapidly. When someone brings it up to their attention.
14 Q Rapidly would be five hours? twelve hours?
15 ten days?
16' A I would say within the shift that the incident 17 report is presented to.
18 Q Okay. And how about a DEF that raises an
, 19 operability concern? Would that receive basically the 20 same. type of attention?
21 A I think so, yes.
22 MR. McDERMOTT: .Okay, thank you.
23 BY MR. LOGAN:
24 Q One le- ceries of questions. I appreciate 25 your staying. I realize we're getting into your lunch NEAL R. GROSS COURf REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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i 60 !
I hour. l 2 I have a draft incident report, a cover sheet 3 for one, and three drafts on it, dated April 20 draft, 4 April 20 meeting and subsequent to April 20 meeting.
5 Would you look at those three documents with 6 the cover sheet and tell me if you recogni::e those 7 documents?
8 A This is the cover sheet?
9 Q That's correct.
10 A These appear to be the Licensing Group's 11 response to the POPS issue that Westinghouse had raised.
12 Q Let me ask you again.
13 A Do I recognize them? No.
14 Q Do you recognize them? No. Okay. I'm really 15 looking to see whether or not you've had any contact with 16 any version of that report. Obviously you have three of 17 them there.
18 A My contact would be at some point where 19 Licensing has completed their work and they're ready to 20 submit it to the station, either via the SORC Committee or 21 I guess the SORC Committee.
22 Q What is the SORC Committee?
23 A It's the Operational Review Committee where 24 the --
25 Q Station Operational Review Committee?
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61 1 A Yes.
2- Q Okay.
3 A Now, if the Licensing Department has 4 determined that an_ incident report has impacted the
]
l 5 licensing arena, then they can submit what is known as an 6 LER to the SORC Committee for approval. The licensing l 7 event report would document how the plant was challenged 8 and it's approved by SORC as far as the various 9 departments represented at SORC reviewing the LER.-
10 So this Ken O'Gara is in the Licensing Group so they 11 -
then reviewed the POPS set point non-conservative issue.
12 That's how they've titled it here.
13 Q Yes, we've spoken with Ken, but you're telling 14 me that you haven't seen these?
15 A I don't recall seeing them. I may have been 16 involved in the final document that was presented. As far 17 as my review au the NSSS Group head or as a System 4
18 Engineering representative, before it's presented at SORC.
19 Q You used one term, SOER. What doer, that stand 20, for?
21 A Significant Operating Eventa Report. It's an 22
&Y Inpo)( term, I believe. It's just one type of document 23 that would enter into the ATS system.
24 BY MR. McDERMOTT:
25 Q Some time in the last year or say since the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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62 1 January time frame, have you -- ,
2 A Keith did:say that was.the last question.
3 MR._ LOGAN: _? bum me.
4 MR. WETTERHAHN:- Okay, we can leave now.-
5 BY MR. McDERMOTT:
6 Q Did you receive training on operability and 7 operability determinations and --
8_ A Yes, on the NRC --
9- Q -- 89107 Or, I'm sorry, 91187 10 A Yes, I did.
11 Q Okay. When did you have that training?
, 12 A I'm going to say the summer of last year.
13 Q So after the December / January time frame we've
-14 been discussing here, January _'94 time frame?
15 A That is correct, as far as 9118 goes.
16 Q Given the training that you received during 17 that summer, would you view this any differently?
- 18 A We have lowered the threshold for incident l- .
19 reports and I would say in the 1995 time, frame, maybe as a 20 conservative gesture, we would have written.the incident 21 report'when the Westinghouse bulletin came in, and_chen we 22 always have the option of retracting the incident report 23 if it's not applicable.-
24 '
- 93 '94 time frame, we may have looked to 25 determine whether-it's applicable before we stbmit the NEAL R. GROSS COURT REPORTERS AND TRAN4CiteERS 1323 RHODE ISLAND AVENUE, N W.
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63 1 incident report. So that's what I can point to as a shift- ,
i 2 of what we would have done differently in this.
3 Q Okay. How about the decision that was made on
)
4 Mr. Lashkari's draft incident report? He's raising a 5 potential design basis concern with the POPS system.
6 Would that be done eny differently now?
7 A Well, based on the discussions that we had, I 8 would have handled it pretty much the sama way, that we 9 hadn't completed our evaluation. It wasn't clear to me, 10 and I thought Charlie had the same understanding, as to 11 4W4 @@
whether we were outside of the N96 curves or not, and let 12 Licensing take a look at it.
13 Q I don't recall Mr. Lashkari, in our 14 interaction, ever raising a question of whether or not you
- 15 actually violated that limit. The discussion was more 16 based on calculations for the design basis for that.
17 A Well, the incident report that he wrote said 18 we violated the heat up and cool down cut ves. That's tne ,
19 Appendix G limit that I'm referring to.
, 20 So if he had presented that we had violated 21 the heat up and coc1 down curves today, I would say, well, 22 I think we need to do our homework a little more before we 23 can-make that determination.
24 So I can't really say that we would have 25 handled'it differently.
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64 1 MR. McDERMOTT: Thank yeu.
2 MR. LOGAN: Thank you.
3 .MR. WETTERHAHN: Hold it. Let's go off the l
4 record for a minute.
5 (Whereupon, there was a discussion held off 6 the record) 7 MR. LOGAN: Back on the record.
8 MR. WETTERHAHN: I only have one further 9 question, or one question, but let me set it up.
10 BY MR. WETTERHAHN:
11 O As I understand your testimony, at the January 12 -- December / January time frame, you ,didn't believe you 13 were outside the design basis for the POPS system with 14 regard to this particular design basis, did you?
15 A Correct.
16 Q Okay. If you had believed at that time that 17 you were outside the design basis, would an IR have been 18 the appropriate vehicle to raise that issue to operations?
19 A Correct.
20 MR. WETTERHAHN: Okay, I have nothing further.
21 MR. McDERMOTT: Mr. Wiedeman, we have --
22 THE WITNESS: Are we still on the record?
23 MR. McDERMOTT: Yes, we are.
24 MR. LO7AN: Mark has obviously raised an 25 issue.
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65
'l 'BY MR. McDERMOTT:
- 2. Q The question of design basis of the-system, 3 earlier we took_a look at the basis of the system as 4- described in the technical specifications. That indicated 5 that a single PORV would be able to mitigate the -- a 6 single PORV would.not --_a 375' pound set point would be 7 able to mitigate the effects of the design basis mass 8 addition transient for this, system.
9 After that, we reviewed a table that is 10 attached to the December 30th Berrick memorandum, and in 11 that table, it indicates that if you have reactor coolant 12 pumps opers'.ing, that the peak pressure -- calculated peak 13 pressure would exceed the limits for both Salem Unit I and 14 Unit II.
15 Do you recall that?
16 A I recall that discussion as well as the 17 discussion that the scenario that's postulated --
18 Q I just want to know if you recall that.
19 A -- is not the same scenario that the design-20 basis has, as explicitly written in the SAR. That the 21 design basis scenario in the.SA~ and the Westinghouse 22 postulated scenario are different.
23 MR. LOGAN: Let's -- go ahead.
24 BY MR. McDERMOTT:
25 Q In this discussion, we talked about the POPS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. O C 20005 (202) 234 4 433
66 1 system, its design basis, that single PORV was adequate.
2 We talked about the fact that you have to consider this i
3 event, it's part of the design sasis that you have to l I
4 assume this event's going to happen. Okay? , ;
5 A Hmm-hmm.
6 Q We also discussed the fact that the 7 Westinghouse letter describes a non-conservatism because 8 something that will cause a difference in when the system 9 will begin to relieve was' missed during the original 10 calculations. Okay? That's the hundred pound delta that 11 they described in their letter.
12 A Hmm-hmm.
13 Q And what's in the back of that December 30th 14 Berrick memorandum, that table indicates what would happen ya L n\ talu/4f 15 to the ppei pressure when you add that delta that was 16 specifically calculated for Westing -- for Salem by 17 Westinghouse. Is that correct?
l 18 A Correct in the sequence of events that the l
l 19 Westinghouse bulletin is identifying, i
20 Q Okay, that's fine.
21 A What differs here, though, is it's not a 22 subtle point. It's the basis for our position. My 23 position is that the Westinghouse sequence of events and 24 the scenario as postulated in tie letter,-differs from the 25 design basis description, that the design basis and the NEAL R. GROSS COURT REPOATERS AND TRANSCHIBERS 1323 RHODE ISLAND AVENUE, N W.
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67 1 SAR description is wi?.h the PT405.and 403 pressure '
2_ transmittersL. iso 3ating the RHR system.
3 0 Can you show me where the basis for the POPS 4 system technical specifications indicates that? l 1
l 5 A That was the original design of the plant. So !
6 the basis is based on the initial design of the plant.
7 The POPS system relieves the pressure when the RHR system 8 is isolated. The same pressure transmitters that are ;
9 sensing the POPS set point are the same pressure i
10 transmitters that isolate the RH1 and-RH2 from the reactor 11 . coolant system.
12 So the original design of the plant and the 13 original installation, you would not have the RH3 14 available, and at the POPS design basis, as stated before 15 we did our design change, would relieve the pressure at 16 375 and we were -- if we hadn't done that PT405 and 403 17 pressure transmitter DCP, then the Westinghouse bulletin 18 would have applied to Salem. That's the point I'm trying 19 to make. I hope that was clear.
20 0 No, your point is not clear. What I'm 21 understanding from you is that you're explaining why you 22 felt the plant was physically pro ~tected from this issue.
23 A Correct.
24 Q And what I'm trying to diccuss with you is the 25 design-basis of the POPS system. I'm talking about a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. H W.
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1 licensing basis. -
2 What we were discussing is whether or not this 3 system, as described in the technical specifications, 4 would have performed the function of mitigating that 5 pressure spike? And is it your understanding that that 6 system, as described in there, which didn't include RH3 --
7 A Correct, the RH3 would be isolated. In the 8 initial design of the plant, the RH3 is isolated, so the 9 description of the POPS system in the SAR is based on a 10 description of relieving the pressure that would occur in 11 the RCS with the RH1 and 2 closed, the RH3 valve isolated.
12 So the scenario that's postulated in the 13 Westinghouse bulletin would not occur at Salem, so 14 therefore the POPS system was not challenged.
15 Q Excuse me.
36 MR. WETTERHAUN: Let him finish and then ask 17 him the next question.
18 MR. LOGAN: All right, I think he's trying to 19 make a point here that by letting him finish, we're never 20 going to get to.
21 MR. WETTERHAHN: Okay. Maybe he can answer 22 the question.
23 BY MR. McDERMOTT:
24 O The scenario that's described, that's 4 25 postulated by the Westinghouse document, the scenario is NEAL R. GROSS COURT REPORTERS AND TRANSCRISERS 1323 RHODE ISLAKO AVENUE. N W (202) 234 4433 WASHINGTON, D.C. 20006 (202) 234-4413
69 I postulated as having reactor coolant pumps running at the 2 time your design basis mass addition transient occurs.
3 A Correct.
4 Q Okay. So when I asked,you whether or not 5 there were procedural requirements to prohibit reactor 6 coolant pumps running at a tinne when a low pressure -- low 7 temperature transient could occur, you did not recall any.
8 A That's correct. I'm not the Ops procedure 9 expert.
10 Q Okay, so --
11 A But what -- I'm sorry, Go ahead.
12 Q Given the information that during my 13 inspection, we found out that prior to December ' 3 time 14 frame, there were no procedural requiren:ents to eliminate 15 the number of running reactor PORV pumps below 312 degrees 16 or below '. 00 degrees, for that matter.
17 Given that fact, how could this not be 18 applicable to Salem?
19 A The number of things that are occurring 20 simultaneously to result in this Westinghouse issue, one 21 of the things that is required to occur simultaneously 22 with the pump starting, the mass addition and the other 23 events that are described, is the isolation of the RH1 anc.
24 2. That is the initial Westinghouse design. .
25 If your plant'was designed by that original NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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1 Westinghouse design, these sequence of events will occur 2 and you will challenge the POPS system. However,Sqlem 3 Station does not have that same scenario occurring because 4 we never isolate the RH1 and 2 because we S ?d performed 5 that pressure interlock approval.
6 That's the point I'm trying to make and that 7 was --
8 0 You've made that point well. I absolutely 9 understand that in the late '70s, 1980 time frame, the 10 autoclosure interlock for RH1 and RH2 was removed. I've 11 reviewed the documents for that design change. I've 12 reviewed the NRC safety evaluation for that design change.
13 Okay?
14 But what I'm asking you is, we got to the 15 point of discussing when Mr. Lashkari raised this concern 16 with the incident report, at that time, was it your 17 understanding that the POPS system, as descrjbeu in your 18 license, would have worked the way it was expected to?
19 A Yes.
20 Q If you feel that the system would have 21 performed as designed, how can you justify that against 22 Mr. Berrick's December 30th memorandum, which indicates t
23 that if you had two reactor coolant pumps running, the 24 pressure spike would have exceeded the limits?
25 A Okay, I guess I'm unable to communicate my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER $
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71 1 position here, that Mr. Berrick's letter does not mention 2 the RH3 valve in there.
3 Q That's right.
4 A Correct.
5 0 Because he was evaluating the system as 6 originally designed, as described, two PORV's only.
7 A And from my perspective on the plant side, we 8 did not challenge our ability to mitigate a pressure spike 9 in the RCS system, because of the way the plant is 10 configured.
11 0 okay.
12 A So therefore I did not challenge my mid-plane 13 reactor vessel stress limits.
14 Q Do you agree that the calculation summarized 15 in the table of Mr. Berrick's memo indicate that the 16 pressure would have exceeded the limits?
17 A No, because his table also indicates that we 18 were within the allowable stress levels for the vessel 19 material.
20 Q Can you show me where it indicates that?
21 A I believe it's the last table where we're 22 using 495 e.nd he's saying the maximum calculated is 485.
23 Q Okay, that 495 that you referred to, is that 24 not the column t. hat includes the 10 percent af forded by 25 use of the ASME code case relief?
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1 A Again, this is m) ;.uint, entirely for the last
- 2. hour and a half.- Is that this memo takes credit for the !
3 code case, and does not take credit for the RH3. So the 4 question is, the RH3 or the code case insures that we are ,
5 within our pressure over-protection system requirements. ,
6 Q And given that those two options were known to 1
7 you at the time and the fact that both those options would 8 require some type of NRC approval, did you not view that !
9 as a problem?
10 MR. WETTERHANN: Did you know that they both 11 needed NRC approval?
12 THE WITNESS: I knew that we did not have an 13 immediate issue with the plant and this should be 14 something that's sent over to Licensing and Regulation to 15 determine the course of action. It's my understanding i 16 that's what had happened.
17 BY MR. LOGAN:
18 Q But did you know that you needed NRC approval?
19 A I knew that we needed NRC approval for the 20 RH3. Charlie and I had discuesed that we had to apply for 21 the code case.
22 Q To the NRC7 .
23 A Correct, to the NRC.
I 24 So it was very clear that the final resolution 25 of this was with Licensing and Regulation to determine NEAL R. GROSS COUR1 e& PORTERS AND TRANSCRIBERS l 132J RHODE ISLAND AVENUE N W.
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73 I what we wanted to take credit for.
i 2 BY MR. McDERMOTT !
3 0 was there any formal mechanism which passed 4 the ball to Licensing? !
5 A I bellete that's the ATS system. -
6 BY MP,. LOGAN:
7 Q What you're saying is you believe they had the i 8 ball?
9 A Correct. And that was my direction to Charlie 10 Lashkari, Let Licensing pick this up and determine which 11 .
avenue we needed to take Public Service. Short term, long 12 term, what was the credit that we needed to take in the 13 documentation space. But at no time was the plant 14 challenged. At no time was there a safety issue with 15 Salem I or Salem II, and that's what Howard Berrick's 16 memorandum also indicates.
17 MR. LOGAN: All right, thank you. '
18 MR. McDERMOTT: Thank you.
19 MR. LOGAN: We're off the record.
20 (Whereupon, the proceedings concluded at 21 12:31 p.m.)
( 22 g ggiRd)fM D M F M Td M N 23 IHAMM '
24 l 4/u/95 25 NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1323 RHODE ISLAND AVENUE, N W (202) 2MM33 WASHINGTON, D C. 20005 -(202) 2344433
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l CERTZF1CATE l This is to certify chat the attached l
proceedings before the United States Nucl'n- Ran;3 %<.oy f l Commission in the anatter of: i Name of Proceeding: Interview of OM Sjedemann '
Docket Number Not assigned '
Place of Proceeding Hancocks Bridge, New Jersey !
were held as herein appears, and that this is the original '
transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the dircction of the court reporting company, and that the transcript is a true ,
and accurate record of the foregoing proceedings.
- w. k Barbara Burke ,
official Reporter Neal R. Gross & Co., Inc.
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EXHIBIT 9 4
9 Case No. 1 95 013 Exhibit 9
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