ML20054M377
| ML20054M377 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/09/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8207130043 | |
| Download: ML20054M377 (329) | |
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l 5 In the Matter of a l
6 LONG ISLAND LIGHTING COMPANY s Docket No. 50-322-OL 7 (Shoreham Nuclear Power Station) :
i 8 ------ -----------x 10 Riverhead County Complex 11 Legislative Hearing Room 12 Riverhead, New York 11901 l
13 Friday, July 9, 1982 i
L/ 14 The hearing in the above-entitled matter 15 convened, pursuant to notice, a t 8:30 a.m.
l 16 BEFORE:
17 LAWRENCE BRENNER, Chairman 18 Administrative Judge l
19 JAMES CARPENTER, Member 20 Administrative Judge 21 PETER A. MORRIS, Member 22 Administrative Judge 23 WALTER H. JORDAN, Assistant to the Board C
h 24 Administrative Judge 25 I) v ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
f 6239 O i >>>saniacss.
2 On behalf of Applicants 3 ANTHONI F. EARLEY, Esq.
4 T. S. ELLIS III, Esq.
5 Hunton E Williams 6 707 East Main Street 7 Richmond, Va. 23212 8 On behalf of the Regulacory Staffa e EDWIF REIS, Esq.
10 RICHARD RAWSON, Esq.
11 Washington, D.C.
12 On behalf of' Suffolk County:
13 LAWRENCE COE LANPHER, Esq.
14 KARLA J. LEISCHE, Esq.
15 Kirkpatrick, Lockhart, Hill, 16 Christopher E Phillips 17 1900 M Street, N .W .
18 Washing ton , D.C. 20036 19 20 21 22 23 24 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6239-A
' c O ""'S 2 WITNESSES DIRECT CROSS REDIRECT RECROSS BOARD O 4 Vogin Joksimovich, Edward T.
Robert M.
Burns, Kascsak, 5 By Ms. Letsche (further) 6266 By Mr. Rawson 6328 6 By Mr. Ellis (Further) 6329 7
By Judge Carpenter 6336 8 (AFTERNOON SESSION P. 6340) gThemis P. Speis, Walter P. Haass, 10 James H. Conran, Sr.,
C. E. Rossi (Called) 11 Marvin W. Hodges and Robert Kirkwood (Recalled)
By Mr. Rawson 6347 13 By Mr. Lanpher 6378 l
14 E,X H,I B I T S BOUND IN j 15 NUMBER IDENTIFIED RECEIVED REJECTED TRANSCRIPT, l
16 Suffolk County No. 28 6265 6325 6326 17 18 Mo on y os e esu mony, da M July 8, H82 62H 19 Staff Testimony on contention 7.B and SOC contention 6357 19.b with attachments, corrections and the statements 20 of professional qualifications of supporting witnesses.
21 NRC Staff Stestimony of James H. Conran, Sr. in rebuttal 6368 to Applicant's Testimony on Salety Classification and 22 Analysis of Structures, Systems and Components 23 RECESSES:
24 Morning - 6309 25 Noon - 6339 i O
6240 O i aaacata1xas 2 JUDGE BRENNER Good morning.
3 One housekeeping matter. The infamous U.S.
4 Air Islip to Washington airplane was cancelled last 5 evening. Aside from the fact that I don't know how Mr.
6 Brown got home, the other result of that is that the 7 inserts for the transcript could not be flown back to be 8 placed into the transcripts today.
9 What the reporter is going to do, which I
! 10 found perfectly acceptable, is issue a separately bound 11 volume which you will probably receive on Monday of just 12 the inserts, with the index as to what page those 13 inserts follow. The inserts were only three and they 14 were not testimony. If it had been testimony we might 15 have asked that new transcripts be issued, but I think 16 we can get by with this method.
17 It also reinforces our view that we were wise 18 in altering the schedule so that we could take other l 19 planes out on Friday.
20 Ms. Letsche, we had the one matter or one or I 21 two matters remaining with respect to the documents that i
22 we directed be made available to the County. The 23 GE-prepared tables regarding the comparison between
() 24 Limerick and Shoreham PRA's were made availabe and you 25 were going to tell is if you had any questions about i
l l
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
y 6241 them. '
(} 1 2 MS. LETSCHE Yes, Judge Brenner, I do ha ve a 3 few questions related to this document.
O 4 MR. ELLIS: Judge Brenner, in connection with 5 that document, I don't have it here, but we made an-6 effort to go back and get another copy of it, and 7 indeed, in our efforts to comply as quickly as we could 8 with the Board 's order, it does have a title and it had 9 a sheet that was not telecopied to us, which we are i 10 having copied now.
11 So it will be complete, so we don't have to 12 rely on this typed version. And in addition, there 13 appears to be one error, there may have been others, in 14 the transcription, attributable in part to the 15 difficulties that I anticipate anybody would have in 16 reading the telecopied version.
17 that should have been here at 8:30. It was 18 being copied, and I will ask that people check on it.
19 It was almost done at 8:30 when I came down here, so it 20 should be here righ t a way.
21 JUDGE BRENNER : So as I understand, we are 22 waiting for a completely new version , new in forma t, to 23 be retelecopied?
1
() 24 MR. ELLIS4 Oh, no. It is essentially the 25 same document. It is just that, rather than our retyped ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
1 6242
+
(),- 1 version, it is the document itself.
2 JUDGE BRENNER: That is what I'm saying. Tha-3 is what I was trying to say. I guess I would like to 4 wait for that, in case there are some minor 5 4 typographical errors and in case we end up putting it 6 into the racord. I would wait f or it, because we 7 believe its arrival is imminent. Otherwise we might 8 have proceeded without it.
9 MR. ELLIS: It is imminent.
10 JUDGE BRENNEF What about the other 11 documents? Do you have any time frame of when they 12 might be put together? That is, the documentation of
'13 the changas being contemplated by LILCD as a result of O
\_/ 14 the PRA work to date?
15 MR. ELLIS: Well, Mr. Kas:sak has got to go 16 back to Hicksville and look for those documents. And 17 some I think are readily available, and others, if they 18 exist, he will have to look to see what exists. And 1
19 then we want to consider the Board's suggestion to us 20 that we put a comment or something of that sort along 21 with them.
f 22 JUDGE BRENNER: Yes. I didn't expect it all 23 here this morning, but it would be very helpful, I think, if we could get it while we are still on this
) 24 25 contention, as early as possible this week, while the f
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l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6243
() 1 Staff witnesses are still on the stand, in case it 2 becomes pertinent for the examination of them. And then 3 maybe we could go back into it with LILCO witnesses if
, O 4 there is sny necessity to do that.
5 It is not a req ui re me nt , but I just point out 6 tha t it migh t be helpf ul.
7 MR. ELLIS: We will do our best. I think the 8 estimate was that the Staff witnesses would be 9 cross-examined by the County for three or four days at a 10 minimum, as I recall, so that at some time during that 11 period -- Wednesday or Thursday or Friday of next week 12 -- we hope to be able to do it.
13 JUDGE BRENNERa I would like to change minimum 14 to maximum.
15 Let's hear the argument on the motion to 16 strike by LILCO, and then we can come back to the other 17 matter when we get copies. I guess what I'm referring 18 to is a motion filed by LILCO d ated July 8th, which was 19 in fact received yesterday af ternoon, I believe. It's a 20 motion to strike a portion of Mr. Conran's rebuttal 21 testimony on contention 7.B.
22 And maybe the simplest thing would be to bind 23 the motion into the record at this point, and we will do
, () 24 that.
25 (The document referred to, a July 8, 1982,
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6244 ro11o ==>
O i otioa er trtco to strike testi oar 2
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ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54 2345
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O, July 8, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,- Before the Atomic Safety and Licensing Board
'x_, '
In the Matter of )
)
LONG ISLAND LIG!! TING COMPANY ) Docket No. 50-322 (OL)
) l (Shoreham Nuclear Power Station, )
Unit 1) )
MOTION TO STRIKE A PORTION OF J AMES II. CONRAN'S REBUTTAL TESTIMONY ON SC/ SOC 7B AND SOC 19(b)
I.
On July 1, 1982, the NRC Staff filed testimony sponsored by James 11. Conran, Sr. in rebuttal to LILCO's testimony on SC/ SOC Contention 7B and SOC Contention 19 (b) -- Systems Inter-action and Safety Classification. As indicated below, a por-tion of that testimo'y n is beyond the scope of the contentions and LILCO's testimony. Thus, the Staff raises for the first time an issue that is not before the Board, irrelevant both to the contention and testimony and, thus, appropriately struck.
II.
Mr. Conran's rebuttal testimony discusses the Staff's view of the "Denton Memorandum" which sets out definitions for
(~b
'~ the classification of systems. The testimony points out that there are certain differences in terminology between that used
c by LILCO and the NRC Staff for classification of systems.
Testimony of LILCO and Staff witnesses demonstrates that the difference in terminology does not lead to any difference'in (v"]
result. In the rebuttal testimony, however, on pages 6-7, Mr. Conran discusses three implications of the different usage of the terminology. The third such implication, listed on page 7, states that "Under Applicant's construction of
'important to safety,' the obligations imposed by 10 CFR Part 21 might be more narrowly construed than would be the case under the Staff's broader definition of that term." This statement raises a new issue that is not within the scope of the contentions nor was it the subject of LILCO's testimony on these contentions.
O N/ SC/ SOC Contention 7B raises the issue of whether LILCO and the Staff have applied an appropriate methodology for the classification of structures, systems and components. SOC Contention 19(b) involves the related issue of whether LILCO has complied with the classification scheme set out in Regulatory Guides 1.26 and 1.29. Neither contention raises any issue about the adequacy of LILCO's reporting procedures l under 10 CFR Part 21. Thus, the staff's testimony is not w.ithin the scope of the contentions as admitted by the Board.
In LILCO's pre-filed written testimony and the cross-() examination on it, the methodology used for classifying struc-tures, systems and components at Shoreham, including how LILCO used the term "important to safety" in such classification, was l
l i
A
discussed at length. The testimony was clearly limited to the use of "important to safety" in the context of systems classi-r~s fication. There was absolutely no evidence presented that (v !
suggested any link between the definitions discussed and the reporting requirements in 10 CPR Part'21. Thus, the Staff's testimony is not responsive to any issue raised in LILCO's testimony.
Moreover, LILCO does not believe that LILCO's testimony on its interpretation of "important to safety" indirectly raises an issue related to 10 CFR Part 21. The critical definition in Part 21 with respect to classification of systems is thm definition of a " basic component." 10 CPR 8 21. 3 (a) (
That definition does not use the term "important to safety."
_) In fact, "important to safety" is only used in 10 CFR @ 21. 3 (a) ( 3 )
in relation to the elements (i.e., design, inspection, testing or consulting services important to safety) of a " basic component." Thus, the term is used in a very different context from that discussed in LILCO's testimony.
III.
For all of the foregoing reasons, the first paragraph on page [o the NRC Staff's rebuttal testimony on SC/ SOC 7B and SOC 19(b) should be struck.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY T
/ ,
, , s W. Taylor Reveley, III T. S. Ellis, III ,/
Anthony F. Earley, Jr.
k
_4 Ilunton & Williams Post Of fice Box 1535 Richmond, Virginia 23212 h DATED: July 8, 1982 1
l l
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I
In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL) r\
I certify that copies of the " Motion to Strike a Portion of James H. Conran's Rebuttal Testimony on SC/ SOC 7B and SOC 19(b)" were served upon the following by first-class mail, postage prepaid, on July 8, 1982, or by hand on July 8, 1982, as indicated by an asterisk:
Lawrence Brenner, Esq.* Bernard M. Bordenick, Esq.*
Administrative Judge David A. Repka, Esq.
Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory 1717 H Street, N.W.
Commission Washington, D.C. 20555 Washington, D.C. 20555 Herbert H. Brown, Esq.*
Dr. Peter A. Morris
- Lawrence Coe Lanpher, Esq.
(~N NJ Administrative Judge Karla J. Letsche, Esq.
Atomic Safety and Licensing Kirkpatrick, Lockhart,' Hill, Board Panel Christopher & Phillips U.S. Nuclear Regulatory 1900 M Street, N.W.
Commission Washington, D.C. 20036 Washington, D.C. 20555 Secretary of the Commission Dr. James H. Carpenter
- U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing 1717 H Street, N.W.
Board Panel Washington, D.C. 20555
- U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Walter H. Jordan
- Commission 1717 H Street, N.W.
Administrative Judge Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Mr. Mark W. Goldsmith Commission Energy Research Group
['#l Washington, D.C. 20555 400-1 Totten Pond Road Waltham, Massachusetts 02154
e 5
David J. Gilmartin, Esq. Ralph Shapiro, Esq.
Attn: Patricia A. Dempsey, Esq. Cammer and Shapiro, P.C.
County Attorney 9 East 40th Street
( Suffolk County Department of Law New York, N.Y. 10016 I Veterans Memorial Highway L llauppauge, New York 11787 Matthew J. Kelly, Esq.
State of New York MilB Technical Associates Department of Public Service 1723 ilamiIton Avenue 3 Empire State Plaza Suite k Albany, New York 12223 San Jos<, California 95125 Mr. Jay Dunkleberger l Stephen B. Latham, Esq. New York State Energy Office Twomey, Lathan & Shea Agency Building 2 33 West Second Street Empire State Plaza P. O. Box 398 Albany, New York 12223 Riverhead, New York 11901 floward L. Blau, Esq.
217 Newbridge Road 11i ck s vi 1 le , New York 11801
, N i Xnthony F. Ca r le y', Jr. -
IIunton & Williams Post Office Box 1535 Richmond, Virginia 23212 DATED: July 8, 1982 O
6245 JUDGE BRENNER: Now we will hear the Staff's
(]) 1 2 response.
3 MR. RAWSON: Thank you, Judge.
4 The LILCO motion to strike really makes two 5 principal arguments. The first is that the reference to 6 Part 21 is beyond the scope of 7.B and LILCO's testimony 7 relating to it. The second issue, raised I think in the 8 final paragraph, part two, is that no issue-involving 9 Part 21 is even indirectly raised by LILCO's narrower 10 construction of the term "important to safety."
11 Ihe Staff disagrees and opposes the motion, 12 for the following reasons. Contention 7.B deals in a 13 very broad way with safety classification and system 14 interactions issues. It raises points, and we've 15 discussed at length, points concerning th e terminology, 16 the analytical methodologies, and the application of the 17 results of those methodologies in the context of this 18 contention.
19 The Staff's rebuttal testimony attempts to 20 clarify and correct the record on the important point of l 21 the appropriate construction of the regulatory term 22 "important to safety." I want to emphasize, however, 23 that that clarifica tion and correction is not an
() 24 academic exercise.
, 25 It was for that reason that we thought it O
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
6246
() 1 necessary to clarify the point, and we thought it 2 necessary to lay out for the Board the reason that this r~ 3 is not an academic exercise. Part 21 is an important k.-
4 part of that reason.
5 It is clear that Part 21 obligations do go 6 well beyond this contention. But to be specific, the 7 P,RA that we have been discussing here for several days 8 provides a very good example of th e relation of Part 21 9 to this contention. The Staff was not involved in the 10 decision by LILCO to do the PRA. It was not involved in 11 the performance of the PRA.
12 Assume for a moment that the PRA did identify 13 a new systems interaction calling f o r classifica tion
\/ ) 14 upgrading and that the sequence involved there raised a 15 substantial safety hazard within the meaning of Part 16 21. If that sequence related to a "desgn, inspection, 17 testing or consulting service important to safety" --
18 and my reference there is to 10 CFR Section 21.3.A.3 --
l 19 LILCO, General Electric and Stone & Webster could take a 20 more narrow view of their reporting obligations under 21 Part 21 than the Staff would be believe appropriate 22 under the regulations.
23 And I hasten to add tha t we are not suggesting
() 24 that there would be any impropriety of conduct involved 25 in such an interpretation. A good faith construction of ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 the regulations might create that very problem.
2 The same is true of the more deterministic 3 methodologies. Something could turn up which the 4 Applicant would not feel bound to report because of its 5 more narrow construction of th a t term.
6 The Staff raised its concern for these 7 reasons. We think the Board needed to be aware of this 8 prospective problem, and tha t it ought to have the 9 opportunity to explore this issue. Staff witnesses are 10 fully prepared to explore this issue, and we think it is 11 best raised and resolved in the context of this 12 contention.
13 Wi th respect to the second point, that no 14 issue involving Part 21 is even indirectly raised, I 15 would point the Board within the regulations to the
~
1s definition of basic component at Section 23.3.A.3, which 17 includes the language that I quoted earlier using the 18 term "important to safety."
19 The term " construction" in the definition 20 section under Section 21.3.C uses the same term. The 21 term " operation" within that section, specifically at 22 subsection 21.3.H, also includes the term "important to 23 safety."
( 24 JUDGE BRENNER: What was your reference 25 before, the opera tion term? I missed that.
ALDERSON REPORTING CoMPANf,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 MB. PAWSON: " Construction," Judge. It 2 appea rs at 21.C.3.
3 I would further note that the term 4 " substantial saf ety hazard," which is defined at Section S 21.3.K, has been interpreted by the Staff to include 6 exposures above Part 20 limits and not simply Part 100 7 lim its . Again, this relates to the broader definition 8 that the Staff applies to the term "important to 9 safety." And it demonstrates an additional area in 10 which this difference in terminology could create 11 problems in the future.
12 For those r e a son s , we think that the motion to i 13 strike should be denied and the Board ought to explore 14 these issues with witnesses.
15 JUDGE BRENNER: Give us one moment and then I 16 will allow any further comment by the County, if it 17 wishes, and a response by LILCO.
18 (Board conferring.)
l 19 JUDGE MORRIS: M r. Ra wson, could you give a l
l 20 citation to the interpretation of Pa rt 23.K that says l
21 that -- 21.3.K, that implies that exposures greater than l
22 Part 20 limits meet that definition of substantial 23 safety hazard?
l () 24 1R. R AWSON : Yes, Judge Morris, I would be 25 happy to. My specific reference came from a document I
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
l 6249
() 1 entitled NUREG-0302, Revision 1. The document's title 2 is " Remarks Presented (Questions, Answers Discussed at
- - 3 Public Regional Maetings to Discuss Regulations)," 10 4 CFR Part 21, for reporting of defects and 5 noncompliance. And the date relates to the meetings 6 from July 12 through July 26th of 1977.
7 The specific reference is from page 8 21.3(k)-1. And as I stated, Mr. Conran and Staff 9 witnesses are prepared to address this at great length 10 before the Board.
11 JUDGE MORRIS : Thank you very much.
12 (Pause.)
13 JUDGE BRENNER: M r. Dawson , when I read the 14 rebuttal testimony I could understand why in the Staff's 15 view they would be worried about the term for Part 21 16 reasons, in addition to the other reasons. But it is an 17 additional reason, and I submit that I would not lik,e to 18 get into litigation over whether or not your i i
19 interpretations of Part 21 are correct or not in this f 20 hearing.
I 21 That is, you've got enough reasons that are i 22 more central, arguably, to the safety analyses to find 23 out if systems are properly classified. If we leave the -
l,
() 24 paragraph in so that you would be free to rely on it for 25 findings as an additional reason, wouldn't it be i
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 relevant for another party if it wishes to cross-examine t
2 extensively as to whether or not your interpretation of 3 Part 21 is correct?
4 MR. RAWSON. Judge Brenner, I think that that 5 would be a possibility. The Staff's primary concern was 6 to bring this before the attention of the Board, so that 7 the Board could explore it in the context of this 8 contention, because it has arisen in the context of this 9 contention.
10 I agree, it holds the potential f or more 11 extended litigation, and the decision as to whether that 12 more extended litigation should be conducted in the 13 context of this contention is of course the Board's 14 decision. We think it can be handled in the context of 15 this contention and that it can be handled expeditiously 16 within the context of this contention.
17 Other parties and the Board may disagree with 18 our judgment.
19 JUDGE BRENNER: Does the County wish to 20 comment one way or the other on the motion to strike?
21 3R. LANPHER: We do not support the motion to 22 strike. I think the Staff has set forth sufficient 23 reasons, and I would just note one additional point,
() 24 tha t I think it is useful for the Staff to give its 25 perspertive on the implications of these terms, O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON O.C. 20024 (202) 554-2345
6251
() 1 "important to saf ety" and other classification terms 2 which we have been litigating here, and the 3 sethodologies, and in bringing to everyone's attention 4 its concerns about the use of the me thodology.
5 I don't think it is necessarily opening the 6 whole area for extensive litigation. It is their 7 interpretation of the regulations and the fact that Mr.
8 Rawson, however, said the Staff witnesses are prepared 9 to answer questions. I think this is a convenient means 10 to explore that if anybody wants to.
11 (Pause.)
12 JUDGE BRENNER: I will submit, Mr. Rawson, 13 that if the term "important to safety" is undefined or 14 ill-defined, anyway, you've got problems regardless from 15 an enforcement point of view. But that would be not 16 necessarily pertinent to whether it should be struck or 17 not.
18 And it would also go to the point about 19 whether it suffices for the Staff to say, did you commit 20 to include things important to safety under different 21 definitions, and the utility says yes and the Staff 22 says, okay, we have a commitment, and then later on you 23 find out that there was no meeting of the minds on what
() 24 "important to safety" meant; th a t th at is also more a 25 subject to be explored on the examination of this O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6252 contention, for a lot of reasons.
(]) 1 2 1R. RAWSON: Those are the reasons, Judge, 3 that we th o ugh t it important to bring this to the 4 Board's attention.
5 JUDGE'BRENNER: Does LILCO have a response?
6 MR. ELLI3s Thank you, Judge Brenner.
7 Nothing that I have heard changes what I have 8 heard changes what I think is an inescapable and obvious 9 fact, and that is that Part 21 is not within this 10 contention. It is not relevant, it has not been raised, 11 it was not raised in our direct testimony, their direct 12 testimony. It was not raised in their questions in 13 cross-examination, Mr. Rawson's questions in 14 cross-examination of our panel when it was up there.
15 It was not raised by the County in cross-examination of 16 our panel when it was up there.
17 The notion of what we contend or the 18 definitions that we use is not news. These were l
19 explored in depositions prior to the filing of l
20 testimony, at whi:h both the County and the Staff were 21 there. And I think it is quite clearly something that l 22 is outside the scope of systems interactions an
- l l 23 classification.
Mr. Rawson mentions the changes that were
) 24 i
25 explored or the two changes that are being implemented, l
O f ALDERSON REPORTING COMPANY,INC.
l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6253 the two that are being reviewed or studied by LILCO in
(]) 1 2 connection with the PRA. We have heard ample testimony fg 3 that they are well beyond the design basis of the plant, V 4 and it is by no stretch of anybody 's imagination 5 anything involving a substantial safety hazard as 6 defined in 21(k).
7 So really, I want to say that. I don't think 8 it is necessary to my argument, but I don't want anybody 9 to be left with a misimpression that any of those things 10 have anything whatever to do with Part 21. And the more 11
-- well, enough said about that. They are well beyond 12 the design basis and have nothing whatever to do with 13 substantial safety hazards, which under the regulations O means a loss of safety function to the extent that there
(_/ 14 15 is a major reduction in the degree of protection 16 provided to public health and safety for any facility or 17 activity licensed and so forth.
18 And that is not what was involved in those l
l 19 four changes, and I think we will hear testimony from l
20 the Staff involving some of those changes.
l 21 JUDGE BRENNER: Well, you've got two basic 22 points, as I understand them, Mr. Ellis, and then some 23 subpoints. One point is it's not proper rebuttal, even
() 24 if it is otherwise relevant, because it didn't come up 25 . earlier. It could have been in the original testimony, ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6254
() 1 it wasn't set up in cross-examination, and so on.
2 The other point is it is not relevant to the 3 contention anyway. Am I interpreting your arguments 4 correctly?
5 MR. ELLIS: As usual, you have done it more 8 concisely and more lucidly than I. Yes , th a t 's righ t.
7 JUDGE BRENNER: As to the examples, I think 8 Mr. Rawson's argument was not that those examples raised 9 a reporting requirement, but his reason as to why he 10 believes it is relevant to the contention is that the 11 reporting requirement could be important so that the 12 Staff is apprised of matters that come up which could 13- involve systems interactions and in turn classification D
\ 'l
' 14 of systems, structures and components, not that those --
15 not that he was saying those four examples would have 16 given rise to that.
17 HR. ELLIS: I wanted to eliminate that l 18 implication. And in addition, we have no quarrel with l
19 the abstract notion that Part 21 is important. If it 20 weren't important, it wouldn't be a regulation. But it 21 is not part of this contention.
22 And all I wanted to do was erase any possible 23 implication tha t any testimony heard in connection with
() 24 the PRA lent any weight to the notion of this concern.
I 25 I think the basic thing is that the Staff is saying that O
l l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 they have this concern and they are advising the Board. f 2 Fine, but it is not part of this contention and should 3 not be a part of this contention.
4 And I think, Judge Brenner, you stated 5 concisely the two points that are supportive of our 2
6 motion to strike.
7 MR. RAWSON: Judge, if I may, I would just 8 like to join Mr. Ellis' comments in trying to remove any 9 implication that anything that was said in relation to 10 the PRA related to those four changes that have been 11 discussed. It was not my intention. I did not refer 12 specifically to those changes and it was not my l 13 intention to.
i 14 I was merely presenting a hypothetical to 15 demonstrata very specifically how the Part 21 16 requirement is important and how it relates to the 17 terminology which is an issue in this contention.
k 18 JUDGE BRENNER: Isn't that what I said about I
19 what I thought your argumen t was?
l I
20 MR. RAWSON: Yes, sir. I was just agreeing.
I 21 I just wanted to agree that I was not casting any 22 implications in relation to those examples.
l 23 (Board conferring.)
() 24 JUDGE BRENNER. We are going to deny the 25 motion to strike on a close call. It is close for a
(
1 ALDERSON REPORTING COMF ANY,INC, WO VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 couple of reasons. Number one, if this had been a 2 private lawsuit between parties it would not be proper 3 rebuttal, because it was never set up in the 4 cross-examination or the prior testimony, and in effect 5 it is coming in for the first time late.
6 However, we will leave it in for the .
7 relatively limited purpose of showing that the Staff's 8 view of the importance of assuring that what LIlCO is 9 doing is consistent with what the Staff understands the 10 terms to be is not ,an acader'.c exercise. As I said, 11 there were other reasons much more central to the 12 contention, and this is an additional reason.
13 We don't intend to make any findings as to h
14 what the term means in the context of Part 21, though.
15 And I say that because it may alleviate the 16 cross-examination burden on this late matter. And it is 17 in there as a kind of a make -- I guess it is to prevent 18 us from cutting off any examination or testimony by the 19 Staff, although the order is strange.
20 Normally, it would have come up in 21 cross-examination if it was important to the Staff for J
. 22 prior testimony, and there has been total silence on it. In addition, it cuts both ways, and I alluded to l 23 24 this earlier.
25 It shows that a business as usual " audit-type l
O f
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
- .= , . . . .
6257 O ' 9toceaure" rn e to de v riea ia vertico1er 2 circumstances where there a re indica tions that there are 3 ambiguities in the way things a re being used, and to 4 have a simple so-called " commitment" that will do the 5 right thing with respect to what's importan t to safety 6 and the Staff says okay may be, I guess, what is called 7 in the law a latent ambiguity where there is no meeting 8 of the minds.
9 And we expect the Staff to consider whether or 10 not it's going to do anything different with respect to 11 this application, given all of the indications to date 12 thst there might be -- and I emphasize "might be" ---
l 13 some substantive effect of that latent' ambiguity and all 14 of these fine statements of counsel.the last few weeks, including the'sontence in the mo' tion to strike that what
~
15 counsel likes to ca11 a seman' tic problem does not lead
^
16 17 to any difference in result, may not'be supported by 18 what we have heard so far. _
19 'That isi we may not know. ;And I expect maybe 20 the Staff witnesses can assist us in explaining what 21 they intend to,do with regard to-the matter or what has .
22 been done with' regard to that. And it~goes back, Mr.
23 Rawson, to my problems with the series of que'stions you 24 asked some weeks ago. That is, the questions were 25 useful to highlight the ref erence poin t, that is, there O
^
ALDERSON REPORTING COMPANY, INC, 400 VIRGit"A AVE., S.N., NASH'NGTON, D.C. 20024 (202) 554 2345
6258
() 1 was this commitment and now you're testing what it might 2 mean.
'g 3 But bacause of what I saw as a certain (v#
4 inherent tautology in the questions and answers, it 5 helped highlight the problem and it was useful for that 6 reason, but it didn't lead to any findings that -- well, 7 it was just semantics. We can't conclude that from that i .
8 questioning. Maybe that'is not where you were headed.
9 MR. RAWSON: Judge, I understood the point 10 when you made it at the time. I understand it now.
~
11 Part of the reason, as I stated at the time, part of the i
12 reason for that series of questions was an exploration 13 of certain of these issues for the benefit of the Staff 14 as well as for the benefit of the Board.
l 15 JUDGE BRENNER: The other reason for our 16 ruling on the motion to strike is we can see the 17 relevance, albeit somewhat peripheral, to 18 classification, that is as to whether the reporting 19 requirements through the life of the plant would ensure 20 that work that could affect systems classification in 21 the sense that the Staff is interested in under their 22 definition of "important to safety," whatever that is, 23 and I quess we will find ou t, could be reported.
() 24 There were more direct routes to it throughout 25 the contention. There has been a lot of emphasis that
)
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() 1 ongoing work was important, such as monitoring LER's, 2 and LILC0 has testified as to the methodology that it 3 intends to employ to monitor ongoing eccurrences in the 4 future and so on.
5 The definitions in Appendix B in Part 100, I 6 guess in Appendix B to Part 50, and also Appendix A in 7 the GDC are undoubtedly more direct than the Part 21 8 reference. But we will leave it in, but we are not 9 going to make any findings as to whether or not wha te ve r 10 we do in the context of direct safety classification 11 would also be the same definition of the term for Part 12 21 purposes.
13 MR. RAWSON: Judge, we have no problem with 14 that. We understand it and accept it.
15 JUDGE BRENNEPs So it is in there for your 16 motivation, more than the substance of Part 21, and it 17 is useful for that purpose.
18 MR. RAWSON4 We thought it very important to 19 bring that to the attention of the Board, yes, sir.
20 MR. ELLIS: Am I to understand, then, Judge 21 Brenner, that it is in the rebuttal testimony and there 22 aren 't going to be any questions to anybody about Part 23 21, and it was just there to show that, as they stated, that they thought the definition was more than an
( 24 25 academic exercise?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6260 If that is so, then I understand it and I
(]) 1 2 think that may take care of the unfairness in the sense 3 that we have not had a chance to respond to that.
J 4 JUDGE BRENNER4 I didn't say there would be no 5 questions. For example, it occurs to me that, since it 6 is in there as part of their motivation, if somebody has 7 difficulty with the Staff's definition or lack of 8 definition of "important to safety" it might be 9 appropriate to show whether or not there is consistency 10 in the Staff's view of what the term means, since the 11 Staff believes it should mean something for Part 21, and 12 that is one area in which it could be useful.
13 We are not going to make any findings as to, 14 yes, this is what it means in Part 21. But it may be l
l 15 appropriate to help us explore the Staff's definition, 16 and it might be helpful for the Staff to explain their i 17 definition by reference to the terms. It is similar to 18 wha t has already been done, that is the reference to the 19 term in the Denton memo, the reference to the term in 20 Appendix B, and then again the reference to the term in 21 the GDC and so on.
22 So it might be pertinent to that in terms of a 23 consistency or an inconsistency. I'm not saying that's l () 24 the only area, but that is one thing that I wouldn't 25 preclude by a ruling.
l l
ALDERSON REPORTING COMPANY,INC, j
400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6261 MR. ELLISs I take it that your ruling also
(]) 1 2 would not preclude if we deemed it appropriate to file a 3 motion to supplement or to add testimony of our own on O~ 4 that subject, if it turned out that we deemed it 5 appropriate, since, as I indicated, it was not in our 6 direct and not in our cross or recross or re-recross and 7 was not in the deposition.
8 JUDGE BRENNER I will agree, it wouldn't 9 preclude tha t. That is one problem with getting things to what I would consider late for the first time. And I 11 agree, Mr. Ellis, that you have been apprised of this 12 late, very late.
13 i:as the document arrived?
14 MR. ELLIS: Yes, Judge. May I have just a 15 moment to check it?
16 (Counsel for LILCO conferring.)
17 JUDGE BRENNER: Back on the record.
l 18 Let's have the witnesses and proceed with the 19 questioning.
20 (Pause.)
21 JUDGE BRENNER: Ms. Letsche, could you 22 concisely tell us what point your cross-exa mina tion 23 would go to, that is what point in the testimony so far
() 24 will be further illuminated by cross-examination of this 25 in the context of the contention?
O ALDERSON REPORTING COMPANY,INC.
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() 1 MS. LETSCHE4 Judge Brenner, I want to obtain 2 a response to the questions I directed to M r. Kascsak 3 yesterday concerning this document that he referred to 4 and, having reviewed this document in light of what Mr.
5 Kascsak indicated, that LILCO's use of this document or 6 the contents of it was to a ttempt to clarify the record, 7 which I think there is some confusion in light of what 8 is in this document in terms of the comparison between a 9 the differences in how these plants respond to given 10 accident sequences and the assumptions that went into 11 the analysas. ,
12 JUD"E BRENNER: Well, I have in mind the j
l 13 testimony of Dr. Burns and Joksimovich as to wha t they
)
(/
\-
14 meant by saying there was some confirmation in the 15 results of other work, including the Limerick PRA, and l
l 16 that to my mind was different than a detailed comparison 17 of all of the sub-conclusions between the two PRA's.
18 And therefore I would hope that your questioning would 19 go to that point, that is that they felt that there were 20 no strange outliers showing up in the comparison in one 21 and not the other, as opposed to -- you know, we could 22 be here a long time exploring differences between two 23 PRA's, and I don't want to get into the Limerick PBA to 24 that extent.
25 MS. LETSCHE: No, Judge Brenner, I don't O i 9
l s i ?
l ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345 s ,
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() 1 intend to. My concern about the confusion in the record 2 I believe is related to the point that you mentioned, 3 and it goes to what comparison was being made in taking 4 the comfort -- a term that nobody likes to use -- with 5 respect to the comparison, and the relationship of this 6 document to the testimony on that point that has already 7 been presented by these witnesses.
8 JUDGE BRENNER: All right. I guess what I 9 just did is reiterate what was said when we granted you 10 access to the docaments yesterday.
11 Do you have a time estimate?
12 MS. LETSCHE4 I think my questions are 13 straightforward and I think if I can get answers to them I
i 14 it should not be particularly lengthy.
l 15 JUDGE BRENNER: You have to try to respond 16 with an estimate when I ask for one, even though you l
l 17 don't like to. It doesn't mean that you are locked into 18 thst estimate by any means. But I don't know if that 19 means 15 minutes or an hour or two hours, for example, 20 in the particular context of my question and your answer 21 just now.
22 (Pause.)
23 MS. LETSCHE4 It's difficult for me to put a
() 24 time limit on it, and frankly I am concerned about being 25 locked in, because that did happen to me the last time I O
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() 1 did that. So I have trouble giving you a time estimate, 2 to be frank.
3 JUDGE BRENNER: Let me tell you that what 4 happened last time was not solely a function of 5 exceeding sn estimated time limit and you cannot in the 6 future refuse to give me a time limit for that reason.
7 It was a function of our perception of the efficiency of 8 the examination at certain points also.
9 When exciting things were happening nobody 10 pressured you. When things seemed to start to drif t out 11 a little bit, that is when we started talking about the 12 time. I have a perception of how long it might take to 13 ask questions limited to the purpose we just discussed, 14 and it will help me to know if we are on the same wavelength when I hear your time estimate. That is why 15 13 I a sked .
17 MS. LETSCHEs I would hope that I could get 18 through my questions in less than an hour.
19 JUDGE BRENNER: We're not going to drop the 20 ceiling down on you necessarily when the hour expires, 21 and if you have that fear you should not.
22 Mr. Ellis, you wanted to say something?
23 MR. ELLIS4 Yes, Judge Brenner, if I may.
() 24 While I don' t have the transcript, my notes indicate 25 that the requirement for examination on these things was O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
4 6265 either to refute evidence or that it had to be material
(]) 1 2 in order to offer new evidence, rather than just 3 clarification, as Ms. Letsche has indicated.
4 JUDGE BRENNER: Well, she told me enough where 5 it fits. If the questions are true to what she 6 indicated her purpose would be, that it would be an 7 attempt to -- depending upon the answers she gets, of 8 course. She can't know that in advance. It might well 9 refute the fact that these witnesses can be comfortable 10 in the thought that there were no outliers in the 11 results.
12 She can't guarantee that she's going to refute 13 something. It's the attempt to see if she can refute 14 something that is sufficient.
15 All right, let's proceed.
i 16 3S. LETSCHE: Judge Brenner, in order to 17 facilitate this examination it would be helpf ul to have 18 the document marked as an exhibit for identification, 19 for ease of dealing with the record. I don 't have the 20 copies here since I just obtained a copy from Mr.
21 Ellis. But I will provide them if we need any l 22 additional ones.
23 JUDGE MORRIS: That will be Suffolk County l () 24 28.
25 (The document referred to l
()
l
! ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 was marked Suffolk County 2 Exhibit No. 28 for ,
3 identification.)
4 MS. LETSCHE I will state for the record that 5 Suffolk County Exhibit 2e that I am having marked or 6 requesting to be marked for identification at this time 7 is a seven page document, the title page of which states 8 " Comparison of PBA Results, Shoreham and Limerick," and 9 in the right-hand corner it states "L.G. Frederick, 10 General Electric Company, 4/29/82." And it is followed 11 by six pages.
12 Whereupon, 13 VOGIN JOKSIMOVICH, 14 EDWARD T. BURNS 15 ROBERT M. KASCSAK 16 the witnesses on the stand at the time of recet7, 17 resumed the stand and were further examined and 18 testified as follows:
19 FURTHER RECROSS EXAMINATION 20 BY MS. LETSCHE:
21 0 Mr. Kas:sak, do you have before you a copy of 22 what has been marked as Suffolk County Ex hibit 28 for 23 identification?
() 24 A (WITNESS KASCSAK) Yes, I do.
25 0 Is that the document that you referenced in ALDERSON REPORTING COMPAf!Y,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554-2345
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() 1 YoJr testinony on July 7, 1982, in the discussion that 2 is included on pages 5879 through 5883 of the 3 transcript?
{
4 MR. ELLIS: Can we supply the witness with the 5 transcript? The witnesses don ' t have the transcript and 6 I think they should.
7 JUDGE BRENNER: Let's go off the record.
8 (Discussion off the record.)
9 JUDGE BRENNER: Back on the record.
10 BY MS. LETSCHE: (Resuming) 11 0 That's 5879 over to 5883.
12 A (WITNESS KASCSAK) Yes, this is the document 13 we were discussing at the time.
14 0 Is this one of the documents that LILCO is 15 using in its PRA review to evaluate differences in how 16 the Limerick and the Shoreham plants respond to given 17 accident sequences and differences in assumptions that 18 went into the analyses, as you stated in your testimony 19 on page 5879, lines 21 th ro ug h 24?
20 (Pause.)
21 A (WITNESS KASCSAK) I believe I had previously 22 stated and I will reiterate, we are not performing a 23 formal comparison between Limerick and Shoreham. These
() 24 particular differences were identified by Mr. Frederick 25 and we are pursuing these differences, and we will reach ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 a conclusion as to whether or not there is any substance 2 to these particular differences. I think that is what 3 we were talking about at the time.
4 0 I was just trying to get clear for the record 5 that this is the document, in terms of GE's 6 identification of those differences, that you were 7 referencing in your testimony; is that right?
8 A (WITNESS KASCSAK) I think I did state that 9 just a minute ago, that this is the document we were 10 discussing at the time.
11 JUDGE BRENNEBs Ms. Letsche, with the thought 12 that this migh t assist efficiency, are you going to find 13 out early shat the other witnesses' familiarity is, if 14 any, with this document? And one reason I asked that 15 is, although I know you asked Mr. Kssesak the particular 16 questions you just referenced, in my mind the other 17 witnesses' testimony was equal, if not greater, than Mr.
l 18 Kascsak's, as the people who performed and reviewed the 19 PRA work, as to what comfort they drew.
20 MS. LETSCHE: I agree wi th you, Judge Brenner, 21 and I intend to ask them that. But I also want to find 22 out about LILCO's own use of this document that Mr.
23 Kascsak referenced.
() 24 JUDGE BRENNER: Some of that use might be 25 through the other witnesses, I don't know. But I want O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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() I to get at all of the witnesses together rather than go 2 through the questions seriatim, unless you have a 3 particular reason for any one point.
4 Well, are the other witnesses f amiliar with 5 this document?
6 WITNESS BURNS: Yes, sir, I am.
7 WITNESS J0KSIMOVICH: This document, as I 8 indicated I believe yesterday, was presented to the peer 9 review group meeting on April 29th, and that is the 10 first time I saw it. And it made zero impact on me as 11 far as the statements I made with regard to comfort.
12 JUDGE CARPENTER: The peer review group for 13 what?
14 WITNESS J0KSIMOVICH: I am a member of the 15 peer review group on Shoreham PRA. Mr. Frederick, who 16 made this comparison, is General Electric's 17 representative.
18 JUDGE CARPENTER: Are you a reviewer for 19 Limerick?
20 WITNESS J0KSIMOVICH: No, I'm not.
21 JUDGE CARPENTER: Thank you.
22 BY MS. LETSCHE: (Resuming) 23 0 Dr. Burns, I'm not sure I understood what you 24 just mentioned about Mr. Frederick. Is he a member of 25 the Shoreham peer review group of the Shoreham PRA?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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() 1 A (WITNESS KASCSAK) Let me clarify that, 2 because Dr. Joksimovich is not familiar totally with all 3 the management structure here. Mr. Frederick is a
{}
4 representa tive f rom the General Electric Corporation.
5 He is the individual who is focusing the technical 6 assistance that GE is providing us for the processing of 7 the PRA analysis.
8 Mr. Frederick does attend the peer review 9 group meetings. He is not a formal member of the peer 10 review group, though. He, as all people who are free to 11 attend, is free to participate in the meetings and free 12 to exchange thoughts on their f amiliarity with the 13 process and what's going on.
14 It might also be important to point out at 15 this time that Mr. Frederick was also the project 16 manager for the Limerick PRA, and he brought that 17 expertise in to the program by his participation in this 18 review process.
19 Q I take it, Dr. Joksimovich, that this was the 20 entire document presented by Mr. Frederick to the peer 21 review group, what has been marked as Suffolk County 22 Exhibit 28?
A (WITNESS JOKSIMOVICH) At that meeting.
23 24 0 Have there been supplements or addenda to this 25 document provided to the peer review group subsequent to O
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() I that April 29th meeting?
2 A (WITNESS J0KSIMOVICH) We didn't have peer 3 review group meetings subsequent to this.
4 (Counsel for Suffolk County conferring.)
5 0 Have you received or are you aware of any 6 supplements or additions to this document over and above 7 what has been marked as Suf folk County Exhibit 28?
8 A (WITNESS J0KSIMOVICH) With regard to 9 comparisons between Shoreham and Limerick?
10 0 I'm just talking about this document.
11 A (WIINESS J0KSIMOVICH) No, this is the only 12 one I've seen.
13 0 Mr. Kas:sak, where in Suffolk County Exhibit f
\
s 14 28 does GE identify differences in how the two plants 15 respond to accident sequences?
16 (Panel of witnesses conferring.)
17 A (WITNESS KASCSAK) This report does really not 18 discuss in any detail the differences in accident 19 sequences between the two plants. The pie charts 20 presented on page 6 do in a sense reflect the cumulative 21 differences in dominant sequences and how those 22 cumulative differences do result in some differences in 23 frequencies for those types of sequences.
() 24 But there is no discussion of those sequences 25 in this document.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 JUDGE CARPENTER: If I may, Ms. Letsche, once 2 again, is it true that the legend for this figure that 3 you are just referring to is inaccurate, that all three 4 of the diagrams on that page are not for core melt, but 5 some of them are for something other than core melt?
6 WITNESS KASCSAKs Yes. As we stated 7 previously, the Shoreham numbers refer to core 8 vulnerable frequencies, and the legend is misleading in 9 that respect.
10 JUDGE CARPENTER: Was this made clear to Mr.
11 Frederick at the meeting? Is he aware that he was 12 comparing things that were in some way inaccurately 13 presented to him?
14 WITNESS KASCSAKa Yes. And some of the copies 15 that may have been floating around here -- some of his 16 comments, handwritten comments that were made, were made 17 during the meeting, where there were oral discussions 18 about some of the information on these tables. And we 19 pointed out many of these distinctions that he possibly 20 may have not been totally aware of at the time he l 21 presented the initial report.
22 JUDGE CARPENTER: So that if we had the 23 minutes of that meeting as a supplement to this D
(,) 24 document, our review of this document might be different 25 in the sense of resolving that apparent error?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
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() 1 WITNESS KASCSAK: I'm not sure that that --
2 I'm not sure the minutes would reflect that. If we had
^3 3 Mr. Frederick here, I'm sure he could concur with the (J 4 fact that many of these differences and distinctions 5 were pointed out to him at the meeting, and he did make 6 some personal corrections at the time.
7 JUDGE CARPENTER: Well, am I raising something 8 that you consider to be important or not, or am I simply 9 being fussy?
10 WITNESS KASCSAK No, I think it is a 11 distinction that certainly needs to be made, and we 12 recognize the fact that these differences needed to be 13 looked at, and we assigned this particular, the review O' 14 of this document and an evaluation of the differences 15 and the fact that we will address these and report back, 16 ve assigned that task back to SAI to do that. And they 17 do owe LILCO and they will report back to the peer 18 review group an explanation of these differences, and we 19 will discuss that at one of the meetings.
20 (Board conferring.)
21 JUDGE CARPENTER: Thank you.
22 BY MS. LETSCHE: (Resuming) 23 0 Dr. Burns, I'm confused and I hope you can
() 24 help me here. When we were talking earlier about 25 Suffolk County Exhibit 24, which was the pie charts of O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., ,,4HINGTON, D.C. 20024 (202) 554 2345
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() 1 WASH-1400 and Shoreham, and you explained there the 2 basis for comparing those two pies, am I correct that 3 you felt that that was a valid comparison because the 4 assumptions used to reach the mean values were 5 com pa rable?
6, A (WITNESS BURNS) Yes, I believe that's true.
7 And as we discussed at the time in the text, that it 8 clarifies a little bit the reasoning that went behind 9 that comparison. And as Judge Carpenter pointed out, to the figure itself does not lead one to tha t conclusion.
11 So the figure itself is misleading.
12 The text clarifies a little bit. The 13 subsequent discussion that we had in this hearino I 14 think attempted to further illuminate the fact that, 15 while it is a valid comparison for a specific purpose, 16 and that is to orient people to what would be the 17 comparison if assumptions were similar, that on the 18 actual fact of core melt what people did perceive to be 19 core melt frequency and may perceive today to be core 20 melt frequancy, this particular comparison may be, to 21 use the phrase that we have used, apples and oranges.
22 But I do feel it is a valid comparison for 23 similar assumptions.
I
() 24 0 Were similar assumptions also used in the 25 comparison of the Limerick contributing accident ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
62'75
() 1 sequence pie and the WASH-1400 pie that were on Suffolk 2 County Exhibit 26?
3 MR. ELLISs May I have the question read back, 4 please?
5 MS. LETSCHE: I can restate it, I think.
6 BY MS. LETSCHE: (Resuming) 7 0 Were similar assumptions also used in the 8 comparison of the contributing accident sequence pies 9 for Limerick and WASH-1400 that are contained on Suffolk 10 County Exhibit 26? I think that is at list the gist of 11 my question, if not word for word.
12 JUDGE BRENNERa In any event, that is the 13 question you want to a sk now.
14 MB. ELLIS: Again, because the record -- let 15 me object to the question insofar as it fails to include 16 in it the predicate that we have already been through in 17 previous testimony and just went through again, the 18 difference between core melt and core vulnerable, which 19 is obviously a different assumption and it leads to l
20 different sized pies.
21 MS. LETSCHE: Judge Brenner, if I might t
l 22 respond, I think the most efficient way to clear up the 23 record is to let Dr. Burns explain what his assumptions were in constructing these figures, rather than Mr.
( 24 25 Ellis attempting to do so.
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() 1 JUDGE BRENNER: All right, there is a little 2 equity on each side here. I agree with your last 3 sta temen t. However, we are getting a little redundant.
4 Also, even though Mr. Ellis didn't state it that way, 5 but I understand you have got a renewed hook to hang it 6 on, so to speak, and now that we have -- we want to 7 focus on the comparison again, now that we have had the 8 benefit of this additional document.
9 But we don't have to completely continue to 10 plow over other ground. And as of now you haven't done 11 that yet.
12 BY MS. LEISCHE: (Resuming) 13 0 I am only attempting to get thing s clear. I'm T
14 not attempting to go over ground I have already 15 covered.
16 JUDGE MORRIS: Ms. Letsche, the way you 17 phrased the question I think it implied that Dr. Burns 18 drew these diagrams. I don't think that is correct. Is 19 it, Dr. Burns?
20 WITNESS EURNS: I'm sorry. Which diagrams?
21 JUDGE MORRIS: Page 6 of Exhibit 28.
22 WITNESS BURNS: These are actually copies of 23 wha t appeared in the Shoreham PRA, and I believe the
() 24 WASH-1400 one was a copy of what appeared in the 25 Limerick PRA. And both of those I was involved in O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6277 O 1 producino.
2 Ihe Limerick pie that appears here is 3 different than any pie we have talked about thus far, in 4 that it is a reflection of the most recent revision to 5 the Limerick PRA, which I was not directly involved in 6 producing.
7 (Counsel for Suffolk County conferring.)
8 (Board conferring.)
9 JUDGE BRENNER: At some point soon I hope 10 somebody asks Dr. Joksimovich what he meant by his 11 comment that this had nothing to do with the statement 12 in his testimony, and that we ask Dr. Burns a similar 13 thing, regardless of his answer. That d'oesn't prevent b
14 an exploration, but it might give us a direction.
15 (Pause.)
16 MS. LETSCHE: There is a pending question, 17 isn 't there?
18 MR. ELLIS: If there is, I'm not aware of it.
19 JUDGE 'BRENNER: It is the question that Ms.
20 Letscheirdstated, and then we had a dialogue about it.
21 Could you testate it again?
22 3Y MS. LETSCHE: (Resuming) 23 0 Dr. Burns, are the assumptions upon which the
() 24 contributing accident sequence pies for Limerick and 25 W ASH-14 00 a re ba sed as contained in Suffolk County O
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() 1 Exhibit 26 also th'e same?
2 A (WITNESS BURNS) I don't want to be remiss in r^ 3 not pointing out tha t these particular -- this i
4 particular graph is different than the one that is 5 presented by Mr. Frederick in his presentation to 6 LILCO. But I can go back and answer your question, I 7 believe.
8 Q Let me, just to clarify the point you just 9 sade -- the mean number in Mr. Frederick's presentation 10 for the calculated f requency for Limerick is the same 11 tha t is on Suffolk County Exhibit 26, isn't it?
12 A (WIfNESS BURNS) Yes, it is.
13 0 So the difference you are referring to is in 8 14 the makeup of the pies ; is that correct?
15 A (WITNESS BURNS) Yes, the contributing events 16 and their contribution is different, yes.
~
17 0 Let's come back to that. But can you answer 18 my earlier question about the assumptions used with 19 respect to Suffolk County Exhibit 26?
20 A (WITNESS BURNS) If we return back to Exhibit 21 26, which is related to Mr. Frederick's presentation but 22 is not the same, okay, the comparison --
23 JUDGE BRENNER: Wait a minute, Dr. Burns. Let 24 me make sure I'm not confused. A little ea rlier you f,L,)
25 said this document is not the same as that presented by (3
(_)
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( 1 Mr. Frederick to LILCO. When you said "this document,"
2 did you mean Suffolk County Exhibit 267 That is, the excerpt from Limerick
('LJ 3 4 WITNESS BURNS 4 Yes, sir.
5 JUDGE BRENNER: You didn't mean to imply that 6 anything in Suffolk County Exhibit 28 for identification 7 is different than that presented?
8 WITNESS BURNS: No, sir.
9 JUDGE BRENNER: Okay.
10 WITNESS BURNS: With regard to Exhibit 26, as 11 we have discussed earlier, the purpose of the Limerick 12 PRA was to provide to the NRC Staff a comparison between 13 WASH-1400 and Limerick and this, these charts here, 14 defining dominant sequences were genera ted on a 15 consistant basis.
16 17 18 19 20 21 22 23 i
qj 24 25 gs U
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() 1 BY MS. LETSCHE (Resuming) 2 0 So am I correct then in saying that 3 considering the assumptions upon which the means were 4 arrived at, as stated for Shoreham in Suffolk County 5 Exhibit 24 and for Limerick in Suffolk County Exhibit 6 26, are the same?
7 ER. ELLIS: I think f or clarification of the 8 record, 11 Ms. Letsche could tell us what she means by 9 "the assumptions," maybe we would be better off. -
to JUDGE BRENNER: Well, it is the same 11 assumption we have been taliking about. Let us make 12 sure the witnesses are not confused. But I do not see 13 how they could be.
14 Dr. Burns, did you understand tha t question to 15 be talking about the difference between whether you were 16 talking about the mean of core-vulnerable condition as 17 distinguished from core melt?
i l 18 WITNESS BURNS: Thank you for that i
19 clarification. Yes , if- tha t is -- that is one of the 20 principal assumptions that makes a possible large 21 differences. There are a number of assumptions other 22 than that that possibly could be different.
23 JUDGE BRENNER: Okay. Mr. Ellis' point is
() 24 better taken than I first thought. And what did you 25 mean, 's. Letsche?
l i
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() 1 MS. LETSCHE: Judge Brenner, I was going back 2 to wht Dr. Burns had confirmed was my correct 3 understanding of his original testimony about the 4 cor.parison between Shoreham and WASH-1400 on Suffolk 5 County Exhibit 24. And tha t is that you made that 6 comparison because the numbers that are reflected in 7 that document are based upon the same assumptions in 8 terms of what frequencies lead to core melt, even though 9 he has explained tha t for several reasons the pie to relating to Shorehsa on that exhibit includes not only 11 events that, in his opinion, would lead to core melt but 12 also includes events that would lead to core 13 vulnerability becsuse there was a possibility of 14 recovery.
15 A s I understood his testimony --
and this is 16 what I am trying to get at -- the WASH-1400 assumption 17 was that all of these sequences would lead to core melt 18 and did not take into account the possibility of 19 recovery. And I understood him to say that therefore 20 the assumptions were the same and this was a valid 21 comparison.
22 I as trying to establish if the assumptions 23 were also the same with respect to the comparison of l
() 24 Limerick and WASH-1400 and find out what that therefore 25 does to the relationship between the means for Shoreham C:)
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() 1 and for Limerick.
2 JUDGE BRENNERs I must confess I did not 3 f ollow everything you said. There has got to be a more 4 efficient way of doing this. Let me give it a shot, 5 with some trepidation, as Mr. Ellis says from time to 6 time.
1 7 The exploration here is some comparison has 8 been made between these other studies and Shoreham as to 9 the results. M s. Letsche is exploring the validity of 10 the comparison for the purposes the comparison was used, t
11 and there may be some lack of clarity as to that last 12 point also. Given differences in assumptions, including 13 -- maybe " assumption" is not quite the right word for 14 this -- but differences in what was looked at, as well
^15 as assumptions, including the difference that has been 16 discussed now between whether the numbers reflect core 17 melt or core-vulnerable conditions, in addition, there 18 were some other dif f erences in assumptions di scussed 19 yes te rd a y , including plant differences or differences 20 assumed in the analysis of the plants, to be more i
21 accurate.
l 22 Given all of that, can you discuss the 23 validity or invalidity of the comparison made in the
() 24 context for which your witnesses are using the 25 comparison? And maybe you could clarify that last ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 point, too, as part of your answer?
2 JUDGE CARPENTERS If I may, Judge Brenner, 3 suggest you conpare the validity and invalidity. Would
{
4 you start with the validity? In what ways do you think 5 this is a valid comparison? In the comparison, what, in 6 your opinion, is valid?
7 JUDGE BRENNER And maybe start with what 8 comparison is being mad e, a nd then give us th e re st .
9 WITNESS BURNSs I think the validity of the 10 comparison lies in the fact that these are potential 11 sequences of concern, potential concern, in a safe 12 operation of nuclear power plants and that they are for 13 different designs. These are three different plants.
14 And at least two of them are different.
15 People who have evaluated them -- and in the 16 third case there is some commonality, but in general 17 they are different, and therefore the validity of the 18 comparison is that it identifies important sequences.
19 And then the next step, if you are interested i
20 in what contributes to the sequence, you can continue 21 further on to identify what is contributing to each of 22 these segments of the graph.
23 They are valid from the important point that
) 24 very similar assumptions were made in deriving them.
25 There have been some changes in methodology from one to i (2) l ALDERSON REPORTING COMPANY,INC, l
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6284 the other, some changes in data input, and there.is some
-( ) 1 2 changes in plant systems and hardware.
3 But the fact remains that the basic assumption 4 that failures of multiple systems placing the core or 5 the containment, challenging the~ core or the 6 containment, can be compared within the same sort of 7 basic assump tions on this basis that is presented here 8 to the same point.
9 In other words, I think we could crudely to characterize -- and I think we did state this in the 11 testimony previously -- tha t one could characterize 12 WASH-1400, Limerick, and Shoreham as all these charts 13 being the frequency of events that could lead to 14 core-vulnerable conditions.
15 So if one viewed it in that context, I believe 16 that they are all proper comparisons.
17 JUDGE BRENNER: I infer from document --
18 WITNESS BURNS: May I add just one thing?
19 JUDGE BRENNER: Yes. And I should let the 20 other witnesses add, too.
21 WITNESS BURNS: I just want to add one
. 22 important point so that I don't again confuse the 23 issue. What I have been referring to is a comparison of l () 24 Exhibit 26 and Exhibit 24 25 The comparison that Mr. Frederick made is a O
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() 1 little bit more difficult because there have been some 2 changes in the Genera 1' Electric approach that make the
~ 3 issue a little bit more cloudy in that some recovery
. 4 actions are directly, included in the subsequent 5 evaluations that they have'done to bring their approach 6 closer to Shoreham in that they are both core-vulnerable 7 type events -- I 13 sorry, it brings it further apart in 8 that he takes ~some credit for recovering from 9 core-vulnerable conditions in that chart.
10 JUDGE BRENNER: For which? For all of the 11 plants in the chart?
12 WITNESS BLANS: No, sir, just for the revised 13 Limerick chart. The~ comparisons, though, in Exhibit 26
(/ 14 and 24, I believe, are consistent on the b ' sis that I l
15 have stated.
- s 16 JUDGE BRENNER: Dr. Joksimovich, did you want 17 to add anything?
18 JUDGE CARPENTER: Just one little question 19 before you start. That did not c ange the Limerick mean 20 value? I,am just surprised. ~
21 WITNESS BURNS: Well, sir, unfortunately, I am' 22 not sure all of the assumptions that have gone into 23 these'different exhibits and in jumping Sack from 26 to 24 to'now, the new one, presented by Mr. Frederick in
( 24 25 the spring, there have been many-changes.
~
(2) :
ALDERSON PEPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 s
6286 And even though the mean has not changed, what
(]) 1 2 has happened ~is that Limerick has eliminated in the new gw 3 revision the entainment overpressure relief design
(" 4 function which was previously incorporated in Exhibit 26 5 when they eliminated that design function, they also did 6 some additional analyses and modeling and made some 7 assumptions that b ro ug h t their calculation closer to 8 what I would now call Shoreham's core-melt frequency.
9 And combining all of those things resulted in not 10 changing the mean.
11 I am not sure I stated tha t clearly. But 12 there is a really potential for large confusion by 13 considering each of these without the text and l
l 14 assumptions tha t go along with identifying the 15 assumptions that went into them.
16 JUDGE BRENNER: That is part of where the 17 County's questions are coming from, and I am not sure we 18 have gotten at that yet, given all of these 19 differences.
20 What usefulness is the statement that because 21 no great dif ferences in outlyers were perceived, that 22 provides some support for the thought that the Shoreham 23 PRA is a good one for its purposes, including
() 24 identification of systems interactions?
25 WITNESS BURNS: Well, I reviewed the results O
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() 1 of both the previous analyses and the updated General 2 Electric analyses and all of the information presented 3 to LILCO at the meeting. All of those things together 4 were intended to identify whether there were any 5 significant potential contributors to public safety that 6 were much significantly dif ferent between the two 7 plants.
8 And in my judgment, there was no significant 9 difference between the evaluations that were performed 10 previously on Limerick as updated by General Electic and 11 presented by Mr. Frederick.
12 And now I guess I am not sure I personally 13 have ever stated I consider htha t to be a valuable piece 14 of information, not necessarly something that I would 15 rely on, though, as a baisis for any conclusion.
16 JUDGE BRENNER: I think we got this a few days 17 ago. Let me make sure I undestand it. And I am f 18 thinking of some of your previous answers, Dr. Burns.
19 It is valuable in the sense that if you hadd seen 20 something different, you would have felt compelled to 21 pursue the difference to understand why the differences 22 were there?
23 WITNESS BURNS: Yes, sir.
() 24 JUDGE BRENNER: And that is the context of 25 your reference? That is the absence of a negative O
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() 1 problem as distinguished from the very affirmative 2 positive' conclusion tha t because the comparison is the 3 same, that because the result is the same, that 2
4 necessarily means that the Shoreham PRA is good for 5 identifying the problems?
6 WITNESS BURNS: Yes, sir.
7 JUDGE BRENNER: Dr. Joksimovich, did you want 8 to add to what has been kind of-a broad umb rella ? I was 9 trying to avoid the detailed series of questions and i
10 that is why I asked something very broad.
11 WITNESS J0KSIMOVICH: I hope I am not going to 12 confuse the issue any further. So I will offeer several 13 co.m en t s .
14 JUDGE CARPENTER: It would help my thinking if
(
15 you could start with the ways in which you think a valid 16 comparison is being drawn. That would be helpful.
17 WITNESS J0KSIMOVICH Limerick versus Shoreham 18 versus WASH-1400?
19 JUDGE CARPENTER In the Suffolk County 28, 20 page 6, the three graphs tht we are trying to develop 21 some recor$ on.
22 WITNESS J0KSIMOVICHs As far as I am 23 concerned, this page is a comparison of apples, oranges,
() 24 and pears.
Page 6 of Suffolk County 28?
25 JUDGE BRENNER:
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() 1 WITNESS J3KSIM3VICH: Right. And I did not 2 and would not draw any comfort from such a comparison.
3 However, Judge Brenner earlier on asked what I 4 thought was a relevant question, and I would be glad to l
5 respond to that because I think Judge Stenner's question I
6 was what led me to draw the comfort with regard to both 7 Limerick and Shoreham related to risk outlyers. And I 8 think I can respond to that.
9 In responding to Judge Carpenter's question, I 10 stated that I was not a member of the peer review group 11 on Limerick. However, I have been contracted by the l
12 Elactric Power Research Institute to review five PRA 13 studies, Limerick being one of them. In that process, I l 14 think I can claim that I have sufficient knowledge of
! 15 Limerick.
16 The kind of comparison that we are still 17 conducting f or the Electric Power Research Institute, we 18 are taking a very comprehensive approach in how does one 19 compa re one study versus another study.
20 The Electric Power Research Institute is very 21 c once rn ed that there is a lot of misinterpretation to be 22 made in these compa risons, and they felt that they 23 should invest some of their money to come up with a way 24 to do that. And tha t is the project that we are 25 Currently working on.
- d O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6290 So I just want to point out that I as familiar
(]) 1 2 with Limerick. Now, how did I draw the comfort from 3 both Limerick and Shoreham? I tried to explain -- and I 4 have lost now the prospective time this week, anyway, 5 that I have my own technique in how I draw comforts.
6 ind I plot the results in what I called "F/C 7 diagram." "F" stands for " frequency," and "C" stands 8 for " consequence." And in many cases, I take C to a 9 curie release available, so that the release available 10 to the environment in terms of curies of a number of 11 po ten tially ha rmf ul nuclides. And I plot a number of 12 points on that. And if I see that some point is 13 sticking out, then that is a clear indication that there 14 is a potential for some outlyers.
15 I draw the line which I call a " limit line."
16 And I have presented my approach in a paper showing how 17 that can be done. And I therefore don't intend to go 18 into that.
19 Upon that type of examination, an examination 20 of all of the sequences which are close to that line and i
21 what went into the assumptions in arriving at these 22 sequences, I draw my conclusions.
23 JUDGE BRENNER: A t the beginning you said this
() 24 document, Suffolk County Exhibit 28 for identification, 25 had nothing to do with your comparison. Was that a bit O
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() 1 of an overstatement, given the comparison you just 2 explained, some of this comparison would be pertinent to 3 your comparison even in the F/C diagrams, would it not, 4 to account for differences?
5 WITNESS J0KSIMOVICH: Well, I have taken the -
6 points, but I have not taken into account Mr 7 Frederick's interpretation. I have taken my own 8 interpretation of the results of WASH-1400, Limerick, 9 and Shoreham in drawing the conclusions, not Mr.
10 Fre d e rick 's . I found Mr. Frederick's compilation -- and 11 this is nothing more than a compilation, as far as I am 12 concerned; there is nothing crea tive in this -- this is 13 a compilation. I found it useful as a compilation, but i
Is 14 I don't draw my conclusuions based upon the 15 compilations.
16 JUDGE BRENNER: Well, it is not just a 17 compilation, is it? It is a compilation, in part, and l
18 then comments of suggested explanations for differences 19 as to some of the points. I lo not know how to define 20 " creative," but that pa rt may be more creative than just 21 a mere compila tion.
22 WITNESS J0KSIMOVICH: Yes, I think you are 23 right. The only part which could in any way be creative 24 are the comments because they presumably reflect Mr.
25 Frederick's characterizations.
(
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() 1 JUDGE BRENNER: Would it not be usef ul for you 2 to know if his comments are correct? For example, if he 3 thinks that maybe it was a design difference, that would 4 be useful for you to knc= in understanding your 5 comparison on a particular F/C diagram approach; 6 correct?
7 WITNESS J0KSIMOVICH: I hope that I would have 8 picked that up myself. But if he says the same thing, 9 tha t makes me feel more comfortable, because Mr.
10 Frederick has been with General Electric for many years 11 and he is an experienced General Electric BWR engineer.
12 And so if he feels the same way as I do, that makes me 13 feel much more comfortable.
- k. 14 JUDGE BRENNER: Did you look at this document, l
15 and more than just the document, as part of your i
16 discussion at the meeting or of any other discussions?
17 Did you take a look to see if his attributions of the 18 differences were consistent with yours or whether he had 19 anything that you did not have, or vice versa, in terms 20 not of every detail but in terms of ascribing a basic 21 censon for apparent differences in results?
22 g WITNESS J0KSIMOVICH: During the time of 23 writing the testinony I made my own comparisons where I
() 24 described it. And in the process of doing that, I have 25 to admit th a t I have not taken this into account.
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I (The Board conferred.)
(]) 1 2 JUDGE BRENNER: Judge Morris reminds me that 3 we do have testimony on the record as to what is going 4 to be done next in terms of the process. And although 5 it is a little redundant, just to get it focused at this 6 point, am I correct ~ that that includes an examination of r 7 this document and Mr. Frederick 's views, among other 8 things, to account for the differences in results to 9 better understand whether the diff ernces are explainable 10 by real differences?
4 11 WITNESS BURNS: Yes, sir. Mr. Frederick 12 presented this information as an independent review 13 comparison for this peer review group and for LILCO's 14 inf orma tion at the meeting. I orally responded to what i
15 I believe to be the reasons for the dif ferences in the 16 two studies.
17 While LILCO was in the peer review group, was 18 sa.tisfied at the time with the responses and with the i
19 comparison that had been made, we were directed to 20 provide detailed documentation to both LILCO and to the l 21 peer review group to identify why there were differences 22 and what were the reacons for those differences.
23 JUDGE JORDAN May I ask just one quick
() 24 question concerning page 6 of Suffolk County Exhibit 28 They refer to TE events. Is 25 on the Limerick pie ch, art?
O ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554-2345
6294 that the same as loss-of-off-site-power events?
(]) 1 2 WITNESS BURNS: Yes, sir.
3 JUDGE JORDANS All right.
O 4 BY MS. LETSCHE: (Resuming) 5 0 Dr. Jaksimovich, on page 6 of Suffolk County 6 Exhibit 28, directing your attention to the pies for 7 Limerick and for Shoreham, in your opinion, is the 8 difference in frequency of the ATWS and the TW events in 9 those two charts a significant difference?
10 A (WITNESS J0KSIMOVICH) I am sorry, would you 11 repeat the question?
12 0 Yes. I am talking about the difference in 13 frequency for the ATWS and TW events on the Limerick pie
( 14 chart and the ATWS and TW events on the Shoreham pie 15 chart.
16 MR. ELLIS: I object to the question. The 17 witness has already stated that these are apples, pears, 18 oranges, wha t have you, and were not comparable.
19 JUDGE BRENNERs No. The objection is 20 overruled. That is the very kind of thing she is 21 getting at with that example. He explained why it is 22 not comparable just to look at the pie chart, but the 23 question did not restrict him to that, it just used tha t
() 24 as a frame of reference.
25 WITNESS J0KSIMOVICH4 What this means to me is i
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() 1 that the composition of dominant sequences in the three 2 pisnts refarenced is different, and this gives the 3 breakdown.
4 BY MS. LETSCHEs (Resuming) 5 0 Well, I understand that. This shows the 6 frequency of those events. My question wasa Is the 7 difference in those frequencies between the Limerick and 8 the Shoreham plants significant, in your opinion?
9 A (WITNESS J0KSIMOVICH) It is a matter of how 10 one distributes the pie. In one particular case you 11 have a number of events which are dominant contributors, i
12 in another case you have another, and in a third case 13 you have a third. And it is dependent upon many 14 features which ara,'by and large, site- and 15 design-dependent.
16 In addition to that, they depend upon the time 17 frame in which the analysis has been done. Numerous 18 other assumptions go into that. So it is a very complex 19 type of comparison. There is no way you can simplify 20 this. We are just looking at this type of diagram to 21 draw any conclusions, which I believe I explained in my 22 response to Judge Brenner's question.
23 0 Dr . Jok simovich , these pies do show the
() 24 frequency of the occurrence of the accident sequences 25 identified as ATWS and TW for those two plants. Is that O
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6296 O ' ot riaat?
2 MR. ELLIS: Again I object. There is
< 3 extensive testimony on what wen t into the accident b 4 sequences on ATWS and so forth in previous testimony.
5 MS. LETSCHE4 Judge Brenner --
6 JUDGE BRENNER: Dr. Joksimovich explained that 7 he made his own comparisons and that it was based upon 8 that that he was able te draw comfort. These questions 9 are pertinent to exploring the validity of that 10 comparison. And although the answers keep coming back 11 to the pie chart, partially because of counsel's 12 comments, the questions are not restricting the 13 witnesses to the pie charts, and I say again it is just 14 a frame of reference.
15 And maybe you should consider wording the 16 questions a little differently, if I correctly 17 characterized where you are going, because the witness 18 keeps looking only at the pie chart, and that is 19 partially because of some of the words in your 20 questions.
21 MS. LETSCHE Judge Brenner, I would like to 22 get an answer to the questions I an asking. The witness 23 is obviously capable of adding whatever he wants to his
() 24 answers, but I would like answers to my questions.
25 JUDGE BRENFER: But if the witness continues
) ,
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(') 1 to think -- and maybe thinking correctly that you are 2 restricting him to the pie charts -- you have already 3 got the answer to that. So you have got to move away i
4 from that chart if you want to get to where I suggested 5 you might want to go.
6 (Counsel for Suffolk County conferred.)
7 BY MS. LETSCHE: (Resuming )
8 0 Dr. Joksimovich, you stated that you make a 9 comparison -- or that in making a comparison, you draw a 10 chart which includes frequency and consequences in 11 determining the values on your chart for frequency of 12 occurrence of an accident sequence.
13 Are the values that you determined f or 14 frequency basically reflected in a relative manner in 15 these pie charts?
16 A (WITNESS J0KSIMOVICH) I didn't do anything 17 new. All I did is I plotted the results of the two 18 studies in my own format.
19 0 In your opinion, is the difference in the 20 frequency of the occurrence of the ATWS and the TW 21 accident sequences for Limerick and for Shoreham a 22 significant difference?
23 JUDGE CARPENTER: I just want to clarify, do
() 24 you mean significant in a mathematical sense or in some other sensa, a statistical sense or some other sense?
25 O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $$4-2345
6298 MS. LETSCHE: I guess I as trying to relate it
{]) 1 2 to what Dr. Joksimovich has explained to us in terms of 3 his evaluation of differences and his comparison. And I O 4 am not quite sure I know exactly what his definition 5 is.
6 WITNESS J0KSIMOVICH: I think we are going 7 round and round. For every plant that I have seen, 8 there is a dif ferent composition of dominant sequences.
9 And in some plants ATWS contributes, I don't know, 43 10 percent, in some 57 or whatever. And that has to be 11 taken into account in the relationship to how the study 12 has been performed.
I 13 For example, Zion, in the Zion study, a 90 14 percent contribution for risk comes from seismic. For 15 instance, I don't believe in that conclusion. And in 16 lookinq a t Zion, I have arrived at that is an 17 overstatement on behalf of the study sponsors because of 18 some assumptions they have made, and I have made my own 19 assumptions and arrived at a number much smaller.
20 Hence, your attempt to simplif y this is simply 21 insppropriate and doesn't lead anywhere and it doesn't 22 add any more information to what has been already 23 stated.
() 24 JUDGE BRENNER: When you looked at Zion and 25 found that 90 percent, you thought that was unusual and O
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() 1 pursued your inquiry as to attempt to identify why they 2 reached that conclusion and to see if it stood up in 3 your view; correct?
4 WITNESS J0KSIMOVICH: That is correct.
5 JUDGE BRENNER: In examining these two 6 conclusions as to frequency -- that is, relative 7 frequency -- of an ATWS event, and let us stay with that 8 one for a moment, between Shoreham and Limerick, was 9 there anything in that result after you looked at it ,
10 through displaying it in the format that you decided to 11 use, the F/C diagrams, th a t you would consider 12 significant, to be worthy of further pursuit to explore 13 whether sonething wrong was done somewhere in one or the O
km/ 14 other or both of the studies?
15 WITNESS JOKSIMOVICH: In neither cases I have 16 been able to identify the risk outlyers. However, in my 17 diagram they show differently. So relative to each i
18 other, they are different. But that relative l
. 19 distribution didn't excite me a great deal.
20 However, when I did the same thing for Zion, 21 despite th9 fact that the study claims that the risk is 22 small, the fact that 90 percent of that is seismic was 23 an extracrdinary conclusion to me, which led me to
() 24 examine in detail the assumptions that the contractors have used in arriving at that conclusion.
25 O
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6300
() 1 JUDGE BR ENNER: Why did the difference not 2 excite you here with respect to the different frequency 3 of the ATWS event between Limerick and Shoreham and the O 4 difference in relative contribution between those two 5 events?
6 WITNESS J0KSIMOVICH Because if you look at 7 this pie -- and for this particular case it may be 8 useful -- you will see that the events are recurring in 9 all three avaluations. And it is just a matter of the to redistribution of importance of the various sequences.
11 And hence, I don't find anything particularly 12 unique about that, simply because it is a matter of l
13 redistribtion and it is not a matter of all of a sudden
/~
( 14 something startling coming out of this.
15 Another example I can give you, for instance, 16 in the Big Rock Point study there was also a relatively 17 startling conclusion that the dominant contributor was
, 18 one which hasn't occurred before that; and that attracts i
19 automatically the attention to see whether that was 20 really because of the way the analysis was done or 21 because it is real.
22 And the attentions are automatically focused 23 on that, and we spend a lot of time looking a t it. But
() 24 when we see justothe redistribution of events, I don't 25 get excited about that.
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() 1 JUDGE BRENNER: I as asking this solely 2 because I sm trying to get a handle on how you applied 3 your judgment. And that is what these questions and 4 answers have been all about. What was that one on Big 5 Rock Point?
6 WITNESS J0KSIE0VICH: Fires. ,
7 JUDGE CARPENTER: Do you think, in trying to 8 compare the two results of analyses, 'that it is more 9 insightful to compare the absolute values rather than 10 the percntage values as expressed in these pie diagrams, 11 coming back to Ms. Letsche's question which is still on 12 the table? Do you think that the difference between the 13 two is significant? -
14 And we have talked about this particular 15 graphical representation, but in terms of looking at the 16 actual frequencies that are represented here, what do 17 you think of their significance not with respect to the 18 percentage but the absolute?
19 WITNESS J0KSIMOVICH: Well, there is no 20 question, for instance, Judge Morris the other day 21 quoted a number from t,his SAI Dak Ridge report about the 22 frequency of core melt being in the 10-3 type of class.
23 Well, I find that startling. And if Shoreham came up
( 24 with a 10-3, I would find it absolutely sta rtling , and I 25 would definitely spend a lot of time looking at what has O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
1 i
6302 1 gone into arriving at that number.
2 If, for instance, that is on one of the 3 spectrum, on the other end of the spectrum if SAI 4 reported a result that there was a core melt of 10-10 or 5 something, I would have consilared that as nonsense and 6 I would have, I think, been relatively quickly put in a 7 position to point out that the analysis had been done in 8 a very optimistic fashion.
i 9 ,
10 11
. 12
+
13 14 15 16 17 18 19 20 21 22 23 24 .
l 25 O
l l
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(} 1 (Board conferring.)
2 WITNESS BURNS 4 Could I add just one comment?
3 I think, as you correctly pointed out, there are several f-V) 4 ways to compare, both on an absolute basis and on a 5 relative basis. And myself, I am more in terms of 6 identifying important systems interactions, more 7 comfortable in looking at relative comparisons among 8 different contributors, rather than at the absolute 9 value.
10 The only reason that we are tied to an 11 absolute value in the PRA is that one of the reasons we 12 are ultimately going towarda is public risk, and we need 13 to identify some level. We need to identify an absolute 14 level to get to that point. But from a standpoint of 15 systems interactions, a relative comparison can be made 16 on a very useful basis.
17 This particular format for relative comparison 18 using the pie chart, while it is graphical and it does 19 present the information to jump out at the reader, in 20 some cases it overemphasizes the differences. In other 21 words, while there may be apparent large area i
22 differences, that the actual numbers in terms of the 23 uncertainty in which they are calculated, it makes the l
() 24 numbers comparable.
I'm still trying-to get back 25 JUDGE CARPENTER:
)
\
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() 1 to Ms. letsche's question, which I think was encumbered 2 by the fact that -- and I quite agree with you -- that a 3 percentage presentation is usef ul for certain purposes.
4 But then if you compare two things that have been 5 displayed in terms of percentages and then try to 6 compare one category with the other. ca tegory, you have 7 to be very careful the way you're doing it. It's very 8 easy to get lost.
9 In the other ona, there is a dominance of the 10 " percentage" and the " percentage" is small, so it looks 11 small in that p res e n ta tio n vis a vis -- her question was 12 relative to the significance of the ATWS frequencies for 13 the two PRA's. That is why I thought it might be 14 clearer if you got right at that, rathat than focusing 15 on these pie diagrams back on page 5. I don't know what 16 class 1, class 2, class 3, class 4 is, because there is 17 no documentation here.
18 But if there were such a thing, it is very 19 easy to compare on a bar graph specifically the two i
l 20 items that you are trying to compare, and I was just 21 trying to see maybe if we could get at the answer to her 22 question by focusing. And for the record, she is 23 nodding affirmatively.
() 24 So could you speak to that, the absolute?
you think there is a significant difference in the Do 25
()
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
6305 1 computed frequency of the ATWS event resulting or the
(]}
2 ATWS events resulting from the Limerick PBA and the 3 Shoreham PRA as presented in Suffolk County Exhibit No.
O 4 287 5 (Panel of witnesses conferring.)
6 MR. ELLIS: While the witnesses are thinking 7 about that, I did want to point out for the record that 8 that bar graph, th a t there wa s a b a r gra ph testified to 9 -- Ms. Letsche asked questions about it yesterday --
10 involving the various classes. And Dr. Burns at that 11 point indicated that the comparison of that bar graph --
12 in that bar graph, could not be made.
13 JUDGE CARPENTER: Thank you for refreshing my
/~)
(_f 14 memory.
15 MS. LETSCHE4 Judge Brenner, I should just 16 note for the record that this is a different bar chart 17 tha t Dr. Carpenter is asking about, and if what Mr.
18 Ellis suggests is true I'm sure Dr. Burns can say so.
19 JUDGE BRENNER: I know tha t, and I don't like 20 those interjections either, unless we're going to get 21 o bj ec tio ns.
22 We were going to taka a break around this 23 time. If the witnesses are ready to answer we will take the break and then the answer. But otherwise, we will r 24 take it the other way around. It is up to the 25 O
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(} 1 witnesses.
2 WITNESS J0KSIMOVICH: Maybe I got lost. What 3 was the question?
4 JUDGE J3RDAN: Let me try to tell you what the 5 question was. Dr. Carpenter was saying tha t you can 6 look at the pie charts. There are numbers so that you 7 can get absolute values from these pie charts, although 8 one is for core seit and the other is for core 9 vulnerability. Nevertheless, you can see from these pie 10 charts that the ATWS probabilitits, the absolute values, 11 are different in Limerick and in Shoreham.
12 WITNESS J0KSIMOV!CH: And in WASH-1400.
13 JUDGE JORDANS Yes, in WASH-1400, yes. And 14 his question was, do you believe that those differences 15 are significant.
16 JUDGE CARPENTER: And I would simply -- that 17 was simply a footnote on Ms. Letsche's question, which I 18 think spoke to the same question. If she would affirm 19 that, then that is all I am trying to do, is to make 1
20 clear to you what I think she was trying to get at.
21 Do you want to comment on that, Ms. Letsche?
22 I'm taking the ball way from you. I didn't mean to keep 23 it so long.
() 24 MS. LEISCHEs I think you are doing fine, I don't have any comment.
25 Judge Carpenter.
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1 6307 1 (Panel of witnesses conferring.)
2 WITNESS J0KSIMOVICH: Is the ball in my 3 court?
O 4 JUDGE JORDAN: Yes, sir, the ball is in your 5 court. There are absolute values that can be inferred 6 from those pie charts on ATWS probability. Do you find 7 those absolute values, the differences, significant?
8 WITNESS J0KSIMOVICH: If I just look at these 9 bar charts, the answer is no. However, since I have the 10 knowledge, some knowledge of these designs, I would have 11 expected that Limerick should show lower on this type of 12 comparison because of the different design. With regard 13 to Peach Bottom, I think that is an entirely different
() 14 estimate that was used in WASH-1400 that askas the 15 dominant contribution to the difference, which I believe 16 illustrates my point that you can't make these types of 17 simplistic comparisons without having the full 18 background of what goes into all of this.
19 JUDGE MORRIS: Well, that is just the point I 20 vanted to get your confirmation on, that you wouldn't 21 make such a judgment absent a full understanding of the 22 plant design and the way in which these numbers were l 23 Osicul3ted.
() 24 WITNESS J0KSIMOVICH: That is absolutely 25 correct.
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6308 1 JUDGE MORRIS: Thank you.
[}
2 JUDGE BRENNER: Just one more follow-up on
- 3 tha t last one. I take it you would find your view 4 reinforced by the fact that, despite the obvious 5 difference in even absolute amounts between the ATWS 6 amounts in the two pie charts, you can see that --
7 meaning Limerick and Shoreham -- you could see that 8 because the Limerick pie is smaller and the relative 9 piece of that pie for ATWS is smaller. Had it been the 10 other way around, it may be that the absolute 11 differences would have been the same, and nevertheless 12 the initiator frequency for ATWS is the same as 13 presented on page 1 of this Exhibit 28. So obviously 14 there is something going on between the beginning and 15 the end in these two analyses. And I take it that would 16 reinforce your view that you wouldn 't draw conclusions 17 from the comparison, absent the type of inquiry that you l
18 talked about in response to Judge Morris' previous 19 question.
20 WITNESS J0KSIMOVICH: That is absolutely 21 correct, had WASH-1400 is an excellent exam ple , because 22 the biggest pie.that you could see over here is 23 WASH-1400. But it is not because Peach Bottom is
() 24 inferior to that; it is because of how the evaluation was performed.
25 O
~
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i
' 1 ==e 1 O 3"oct 8ar" ara- ooine to hear -
2 lot about that last point some day, and that goes back 3 to an interesting letter that the Staff once sent out to O 4 Philadelphia Electric.
5 It is 10:40 now. Let's break for '15 minutes.
6 (Whereupon, a t 10:40 a.m., the hearing was 7 recessed, to reconvene at 10:55 a.m.)
8 9
10 11 l 12 13 O 14
. 15 16 17 18 19
[
20 21 1
22 23 24 i
l 25 O
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() 1 (10:55 a.m.)
2 JUDGE BRENNER: Let's go back on.
3 I don't know if it's just the Friday syndrome 4 -- and certainly I f eel I am to blame as much as anybody S' else -- but this has been the most inefficient morning I 6 have ever spent in this hearing to date. And I think 7 it's a function of just everybody taking a deep breath 8 and becoming alert and having the witnesses pay 9 attention to the questions and having the questions 10 better focused. And I think it is a hard subject for 11 some of us, including me, and that is part of the 12 pro blem .
13 But the answers haven't always been focused on
, 14 where the question was going and the question hasn't 15 always been focused so that the witnesses could answer 16 easily. And then I tried to jump in and didn't achieve 17 any efficiency by that.
18 Absent great stimulation, the Board is going 19 to hold off its questions, if any, and just try to let 20 you get through with what I hope is not very much more.
21 BY MS. LETSCHE: (Resumin g )
~
22 0 Dr. Joksimovich, right before the break you 23 were discussing with Judge Brenner the fact that the
() 24 initiater frequencies for ATWS were the same for 25 Shoreham and Limerick. In light of the fact that those ALDERSON REPORTING COMPANY. INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6311
() 1 initiating frequencies are the same and the fact that 2 the relative frequency of the accident results from ATWS gS 3 are different with respect to Shoreham and Limerick, V
4 doesn't that indicate that the causes of those 5 differences should be investigated to identify if any 6 possible improvements could be made at Shoreham?
7 A (WITNESS J0KSIMOVICH) Not per se.
8 0 Why not?
9 A (WlTNESS J0KSIMOVICH) Well, if we take every 10 plant that has been PRA'ed in the United States, and we 11 find differences between one another, in one case we 12 have a number A sad in another case we have a number B, 13 and we want to equalize tha t, I think that would be 14 totally disruptive of the regulatory activities simply 15 because we have to take a much broader view of what is 16 acceptable.
17 The Nuclear Regulatory Commission arrives at 18 their judgments of acceptance. The Nuclear Regulatory 19 Commission is in the process of prom ulg a tin g the sa f ety 20 goals that were discussed yesterday. These goals have 21 been out for public comment. The comments have been
?
22 received by numerous parties. They are being examined 23 by the Nuclear Regulatory Commission, and in some
() 24 foreseeable future we will have a set of ysrdsticks l 25 which will enable us to compare our results against.
)
(m_)
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() 1 In the meantime, we have to use our 2 professional judgments. I have used mine. In addition, 3 if I were to use an interim safety goal on core melt O 4 frequency of 10
-4
, both Limerick and Shoreham wouldn't 5 meet the goal. And with regard to the other goals of 6 individual risks and societal risks, I expect that the 7 same would be true.
8 Q Dr. Joksimovich, I'm not talking about whether 9 or not plants should be equalized. You said that you 10 compared the results of the Limerick and the Shoreham 11 PRA, and I'm asking you if in your opinion, wouldn't the
, 12 difference I referenced between the frequencies of the 13 accident results from an ATWS, in light of the fact that I( 14 the initiating frequency is the same, wouldn't, in your 15 opinion wouldn't that difference merit investigation?
16 A (WITNESS J0KSIMOVICH) I answered that not per 17 se. ,
18 0 You tied your answer to looking at the safety 19 goals. Are you referring to the consequences half of 20 your chart that you discussed?
21 Can you say yes on the record for me?
22 A (WITNESS J0KSIMOVICH) I'm sorry, I didn't 23 understand.
() 24 0 Your nodding isn 't going to come out in the 25 record in response to my question.
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6313 (WITNESS J0KSIMOVICH) I take, in my 'own
(]) 1 A 2 comparison, I stated repeatedly that'I put it in the FC 3 diagram where C stands for consequence.
Os 4 0 Are there differences in consequences of the_ _
5 ATWS sequences compared to the consequences of other 6 accident sequences between Shoreham and.Limerickf 7 A (WITNESS J0KSIMOVICH) The, consequences in 8 terms of health effecfs for Limerick are in the Limer ek 9 PRA. With regard to Shoreham, that is a phase three 10 effort that is'now in progress, and- the. results of which 11 have not been pressented to the review board.
12 0 So the answer is you don't know if there are any differences yet, is { hat right?
13 ~
r~)
k_/ 14 A (WITNESS J0KSIMOVICH) As far as health 15 effects.
16 0 Is that what you mean by consequences in your 17 analysis?
18 A (WITNESS J0KSIMOVICH) That is one of my 19 parameters.
20 0 Is another factor in your -- another element 21 in your consequences variable reflected in the classes 22 of accidents to which the accidents a're assigned ?
23 A (WITNESS J0KSIM3VICH) No, it isn't.
() 24 0 Is there any difference with respect to the 25 ATWS event in the smount of radioactive releases between m
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6314 I the Shoreham and Limerick plants?
(])
2 A (WITNESS J0KSIMOVICH) I will have to refresh 3 sy memory. We need a table from Limerick and Shoreham.
4 Q Maybe I can ask Dr. Burns this question. I 5 don't want to characterize your testimony, any prior 6 testimony, but are the effects, the consequences of an 7 ATWS event, the sa me , would they be the same, at the 8 Shoreham plant as at the Limerick plant?
9 MR. ELLIS I object to the extent the 10 question doesn't make clear what is meant by 11 " consequences."
12 BY MS. LETSCHEt (Resuming) 13 0 Dr. Burns, I mean releases or health effects.
( 14 A (WITNESS BURNS) I am not really intimately 15 f amiliar with the health ef fects calculation. I can 16 speak from seconda ry knowledge.
17 0 To sake it easier, let's just limit it to 18 releases, my question.
l- 19 A (WITNESS BURNS) Radionuclide releases ?
l 20 0 Yes.
21 A (WITNESS BURNS) The radionuclide releases due 22 to ATWS sequences at Limerick and at Shoreham are 23 approximately equivalent. There have been some recalculations ione at Shoreham using MARCH-CORRAL to
( 24 25 make the calculations more correct, more realistic. We l
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() 1 have also done soie sensitivity studies to define what 2 the potential upper and lower bounds would be at 3 Shoreham.
O 4 We have done, I believe, a much better 5 characterization of the potential releases and the range 6 of potential relesses due to ATWS at Shoreham.
7 Q You referenced recalculations. These are 8 subsequent to those that are reflected in the Shoreham 9 PRA?
10 A (WITNESS BURNS) No, we were talking about a l
11 comparison between Limerick and Shoreham. We have done 12 recalculations subsequent to the Limerick PRA using a 13 different set of codes and then benchmarking the codes
( 14 between themselves to compare the results of releases 15 that we calculate at Limerick for the same sequence and 16 those we calculate at Shoreham for the same sequence.
17 (Counsel for Suffolk County conferring.)
18 0 Dr. Burns, I would like to direct your 19 attention to page 5 of Suffolk County Exhibit 28, which 20 contains a chart labeled " Summary of the Results of the 21 Event Tree Quantification Displayed by Class of 22 Postulated Core Vulnerable Condition." In your opinion 23 does this chart represent a valid comparison?
() 24 A (WITNESS BURNS) No, it does not.
25 0 Can you explain why it doesn't?
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() 1 A (WITNESS BURNS) Because the definition of 2 classes are different between the two evaluations. In 3 some cases the dif f erence in the definition is very 0 4 slight and in some cases the dif ference in definition is 5 large.
6 (Counsel for Suffolk County conferring.)
7 Q Can you tell me for which classes the 8 differences are slight and which ones are large?
9 A (WITNESS BURNS) Classes 1 --
10 JUDGE BRENNER: Excuse me. This is, I 11 believe, redundant. You can correct me if I am wrong, 12 Ms. Letsche. And also, what is the point of it in the 13 context of this exhibit?
14 MS. LETSCHE: I think it is important to know, 15 Judge Brenner, whether or not this document which GE has 16 produced and which LILCO is reviewing contains valid 17 information in the opinion of the person who performed 18 the two PRA's.
19 JUDGE BRENNER: That is not exactly the 20 directly for which we turned this document over for 21 you. The direction was to see whether there was 22 anything here that would refute the comparison to the 23 extent relied on by these witnesses in making what was a
() 24 statement of a sentence or two in their testimony.
25 Now you have got the witness saying, no, that O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
6317 is not the comparison he would use. So I don 't see
(]) 1 2 where you can go with it from there.
3 MS. LETSCHE: He indicated, Judge Brenner, O 4 that with respect to some of these classes the 5 differences are very slight, or are slight. I don't 6 vant to characterize his testimony any further. And I 7 think it is a proper follow-up to have him identify 8 which classes he is referring to.
9 JUDGE BRENNER. What about my redundancy 10 point? Didn't we get all of the definitions of the 11 classes and the explanations of the differences?
12 MS. LETSCHE: Judge Brenner, we got an 13 explanation of the classes and what they represent for 14 Sho reh a m , and you discussed with Dr. Burns class 4 15 When I attempted to ask questions about other classes I 16 was told tha t the comparison was invalid and I did not 17 pursue it.
18 So there is not on the record any discussion l
l 19 of, with the exception of class 4 which you pursued, the 20 definitions of the classes at Limerick. And that is 21 actually not what I've been asking this witness. All l
i 22 I'm asking him is for which of these classes are the l
23 differences slight, as he indicated earlier.
() 24 MR. BEIS: M r. Chairman, can the Staff be The Staff has another objection to 25 heard for a moment?
)
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6318 this. Though this may be in some tangential way l
(]) 1 2 relevant, it certainly isn' t material. If we look at 3 the long line we get to on how this relates back to the 4 basic contantion we litigate here, and we look at, we're 5 looking at one document put in and looking at it for one 6 particular purpose, it just would not make any sense and 7 could not influence in any msterial vsy the findings in 8 here.
9 And therefore we object from the point of view 10 of materiality. We are just getting much too remote.
11 MS. LETSCHE4 Judge Brenner, if I might say 12 one thing, this document is one that Mr. Kascsak has i 13 indicated Limerick -- or LILCO is reviewing and is going 14 to be drawing conclusions from, or at least might be l
l 15 using in its drawing of conclusions with cerpect to 16 these two PRA's.
17 I think it is important to get on the record 18 if some of the informa tion that LILCO is reviewing is 19 not valid, if some of it is less valid or more valid 20 than the others, and that is all I am attempting to do.
21 MR. ELLIS: I would just point out that that 22 is not the purpose for the testimony on this document, 23 what Ms. Letsche just stated.
() 24 JUDGE BRENNER: Give me a moment.
25 (Board conferring.)
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(} 1 JUDGE BRENNER I'm going to allow it, but not 2 very far, and it is only because your last point turned 3 se around, to be candid about it. But it is, I agree O 4 with the Staff, it is getting quite remote already.
5 You 've got one document tha t isn 't even a very final 6 document, and the te stimon y is it is one of many that is 7 going to be used, and I will allow it just a little bit 8 more.
9 WIfNESS J0KSIMOVICH: It is not only a 10 document, but the vugraphs that have been used by Mr.
11 Frederick.
12 JUDGE BRENNER: But you can get at some of 13 these things without asking each of the details about 14 it, I believe, although I confess when I tried the 15 overall umbrella approach this morning it didn 't work 16 either.
17 Why don't you repeat the question.
18 BY MS. LEISCHEs (Resuming )
19 0 Dr. Burns, can you tell us for which classes 20 the differences are slight and for which ones they are 21 large?
22 A (WITNESS BURNS) I believe the one that I 23 would characterize as slight is class 1, possibly class
() 24 2, but not to the same extent and there are probably moderate differences there, and in the other classes 25 O
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6320 1 'are are significant differences in the sequences that
(}
2 are included in each of those. So that the comparison 3 based upon frequency presented is not good.
O 4 0 Dr. Burns, you indicated a while back tha t the 5 Limerick pie that is on page 6 represents some revisions 6 to the Limerick pie th a t is in Suffolk County Exhibit 7 26. Are the revisions there the result of calculations 8 that were performed by SAI?
9 MR. ELLIS: Objection. Beyond the scope of 10 what this document was intended to do.
11 BY MS. LETSCHEs (Resuming) 12 0 Or are they -- I hadn 't finished my question.
13 MR. ELLIS4 I'm sorry, I thought you had. You 14 hesitated, and I apologize to you.
15 BY MS. LETSCHEa (Resuming) 16 0 Or are they the result of calculations 17 performed by GE?
18 MR. ELLIS: My objection remains.
19 JUDGE BRENNER: What is the point of that 20 question?
21 MS. LETSCHEs Judge Brenner, I think it is 22 pertinent to find cut whether or not this panel is 23 knowledgeable to discuss how these differences were
() 24 obtained, and that was the only reason I was asking Dr.
25 Burns that question.
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(') 1 JUDOE BRENNER. I'm going to grant that 2 objection. That doesn 't get to the point of comparing, 3 of what comfort they would have drawn from the 4 com:.* r eon there. And in the context of all the 5 testimony we 've had and the ongoing reviews they say 6 they are going to perform in the future, I just keep 7 trying to tie it to those one or two lines in the 8 testimony that says they drew comfort from -- or I don't 9 even think it used the word " comfort," but that is whsL 10 ve have begun to call it.
11 And the witnesses have now explained over and s
12 over again what use they meant by that term, and I think 13 it is fair to say they have qualified the term. I too 14 had questions about it as written, and we have gotten 15 the qualification on it.
16 Also, a lot of these questions, not all of 17 them but a lot of your questions, could have been asked 18 with information already in the record. You are back in 19 the area of --
the same area. But it is not based upon 20 any n e'w information in this document.
21 MS. LETSCHE: Judge Brenner, we've had 22 testimony that this information is related to the l
! 23 Limerick revision which we have not had access to and didn 't know existed and was not referenced in the
( 24 25 earlier testimony.
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
6322 JUDGE BRENNER: It is not pertinent to the
(]) 1 2 testimony that you now would be attempting to refute.
3 So the objection is granted.
4 BY MS. LETSCHE: (Resuming) 5 Q Dr. Burns, in your opinion is the revised pie 6 that is presented on page 6 of Suffolk County Exhibit 28
~
7 an accurate representation of the contributing accident 8 sequences at Limerick?
9 (Pause.)
10 A (WITNESS BURNS) In my judgment -- and this is 11 only my judgment -- this pie represents in handy summary 12 form the dominant sequences that contribute to risk at 13 Limerick within the scope of the study -that they 14 ' performed, that was performed at Limerick. And the only 15 qualification I would have on that is that there may be 16 within this, there may be some redistribution of 17 sequences differently than are presented here. But I 18 think they are all, in the sense that these are general 19 and no specific sequences are presented, only general
! 20 categories of types of sequences -- in that context, I 21 think they are all identified here. It is only that 22 proportion of them that occupy this presentation that I l 23 might do differently if I was to do the problem.
() 24 MS . LETSCHE: Judge Brenner, I have no further However, I would like to move 25 questions at this time.
(
l I
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(} 1 this document into evidence.
2 JUDGE BRENNER: Mr. Kascsak, did you'have 3 something to add to the answer to the question? The O 4 only reason I asked that was you were reaching for the 5 microphone.
6 WITNESS KASCSAKs Not to this specific 7 question. I wanted to make a comment about the document 8 before we close out.
9 JUDGE BRENNER: Let's do it through redirect 10 if there is anything that needs to be done.
11 All right. Any responses to the motion to 12 move the document into evidence?
13 MR. ELLIS: We oppose moving the document or
( 14 putting the document into evidence. This is unlike some 15 of the other documents that we have had. Here we do not 16 have Mr. Frederick.
17 JUDGE BRENNER: Is your mike on?
18 MR. ELLIS: Yes, sir.
19 We oppose the motion. We object to the 20 introduction of this document into evidence. We don't 21 have Mr. Frederick here to exa. wine and we do not think 22 this document should be put into the record for the 23 purpose for the truth of the matters asserted in here.
MR . R AWSON : Judge Brenner, may we have a
( 24 25 statement of the purpose for which this is moved into O
ALDERSON REPORTING COM/2ANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6324 evidence? Let me shortcut. If it is being moved for
(]) 1 2 the limited purpose of cla rifica tion and/or impeachment
- 3 of these witnesses' testimony, we have no objection.
4 JUDGE BRENNER: She wouldn 't be moving it in, 5 I don 't think. She wouldn ' t ha ve to.
6 MR..RAWSON: If it's being moved in for any 7 other purpose, we join in LILCO 's opposition.
8 JUDGE BRENNER: Do you want to respond to the 9 S ta f f ?
10 MS. LEISCHE: Yes. Judge Brenner, I think in 11 light of the fact that there has been testimony tha t 12 this was a document relied upon or being reviewed by 13 LILCO and also has been provided to and reviewed by the O
(_/ 14 peer review group, and that it is based upon information l
15 tha t was produced by some of.the people on this panel, 16 that it is proper to move it into evidence at this 17 time.
18 And let me add that if there is any additional i
f 19 information that LILCO feels is pertinent to clarify the l
20 record any further on this, they certainly will have an 21 opportunity to.
22 JUDGE BRENNER: That is the camel's nose 23 theory of litigation. You know, you are given a l'\/) 24 document in the first place for a limited purpose and
! 25 now you want to -- recognizing its limitations. It is l
ALDERSON REPORTING COMPANY,INC, l
l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
6325 i
I not even a preliminary report in nature, let alone
(]) 1 2 something final.
,- 3 I think you mischaracterize its status within 4 the peer review process and LILCO's review process as of 5 this time, and it was merely a presentation by one 6 person who isn't here. It is not the type of technical 7 document that has reached the status that would be 8 relied on in the field.
9 Maybe the best way for me to summarize it is, 10 I certainly don 't have a sufficiently warm feeling as to 11 the validity of a document of this stature as to admit 12 it for the truth of the matter asserted. And then you 13 say, well, they can bring in all of their other stuff if 14 there are other problems with it.
15 So we are not going to admit it into 16 evidence. It is certainly important to mark it for 17 identification, and whatever is in the document that has 18 been asked about and answered is already in the record.
19 To that extent, I think it might be good, just for 20 convenience, to bind it into the record so we don't lose 21 it. So we will bind it in at this point, but it is not 22 admitted into evidence. It is merely an exhibit marked 23 for identification. .
() 24 (The document referred to, previously marked for 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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ACCIDENT INITIATOR FREQUENCIES (per year)
SHOREHAM LIMERICK ColetENTS TT 4.2 4.0 MSIV/W 0.73 1.8 SHOREHAM NON-CONSERVATIVE ?
LOOP 0.065 0.053 IORV 0.07 0.07 TOTAL TRANSIENTS 5.1 5.9 MANUAL SHUJDOWN 4.3 3.2 ATWS FREQ. 3x10
-5 3x10 -5 RPV RUPTURE 10~ NEGLIGIBLE SMALL LOCA 0.008 0.01 MEDIUM LOCA 0.003 0.002 LARGE LOCA 0.0007 0.0004 LOCA OUTSIDE CONT, 0.00014 NOT TREATED O -
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- 2. TOP OF DRWELL PROB. OF LEAK (NO BREAK) ? 507. AE WOULD NOT C0!DtIT CONTAi!I!!ENT OVERPRESSURE RELIEF ? MO LIMERICK DELETED
- IN REVISION DECONTAMINATION FACTORS UNSAT. POOL 100 100 SAT. POOL 10 10 CONSERVATIVE NO POOL 1 1 Q STEAM EXPLOSION IN VESSEL 0.0l? 0.001 v
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5 4 NO LOCA OUSIDE CONT.
ACCIDENT CLASSES ON LIMERICK YES NO ON LIMERICK ALL FAILURES CORE DAMAGE WITH RECOVERY WENT TO 85% CORE MELT CORE MELT, CONT. INTACT YES NO -
ON LIMERICK ALL CORE HELTS FAILED CONTAINMENT CONT. FAILS, NO CORE MELT ? NO ALL CONT. FAILURES
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Comparison of the Contributing Accident Sequence to the Calculated Frequency of Core Melt from WASH-1400 Shoreham and the Limerick Analysis (Area of " Pie Chart" is Proportional to '
Mean Frequency)
6327 JUDGE MORRISa Dr. Burns and Dr. Joksimovich,
(]) 1 2 I would like to ask one question for clarification. On 3 page 1 of this Exhibit 28, the accident initiator 4 frequencies, andet "ATWS Frequancy" the numbers are both
-5 5 3 times 10 for Shoreham and Limerick. Were these 6 numbers the result of an analysis and calculation or a 7 separate calculation for the two plants?
8 WITNESS J0KSIMOVICH: The calculation is the 9 same. 'It came from the NRC report, NUREG-0460.
10 JUDGE MORRISs Thank you.
1: WITNESS BURNSa I would just add one 12 clarification to that, that that is really a conditional 13 probability of the scram system and it is per challenge 14 to the scram-system.
15 JUDGE MORRISa Thank you.
16 (Pause.)
17 JUDGE BRENNER: Some day, perhaps in this 18 proceeding or another proceeding, in the context of an 19 ATWS contention we will find out how they got the 20 absolute risk down by taking hardware out. But that may 21 be something lost in the noise of the calculation. We 22 will see.
23 That is all of this panel -- well, I'm sorry.
() 24 Staff and redirect.
25 RECROSS EXAMINATION ON BEHALF OF THE NRC STAFF O
t ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON. D.C. 20024 (202) 554-2345
6328 1 BY MR. RAWSON:
{])
2 0 Gentlemen, could I direct your attention to 3 page 6 of Suffolk County Exhibit 28, and would you~1ook, O 4 please, at the AIWS segment of the pie for Limerick. My 5 question is, is there a bound of uncertainty associated 6 with that segment of the pie?
7 A (WITNESS BURNS) You asked is there an 8 u nc er tain ty bound?
9 0 Is there such an uncertainty bound, yes, sir.
10 A (WITNESS BURNS) In the Limerick PRA we 11 discussed the uncertainty bounds on accident sequences, 12 including ATWS, and both upon the initiators, the h
13 systems required to operate, the in-plant consequence O
(,/ 14 analysis and the ex-plant consequence analysis. In many 15 cases the discussion was qualitative, but there was an 16 uncertainty bound presented.
17 A (WITNESS J0KSIMOVICH) In answer to your 18 question, the uncertainties are not represented on these 19 pie charts.
20 0 That is precisely what I was getting to, Dr.
21 Joksimovich.
22 Dr. Burns, is the same statement true with 23 respect to the ATWS segment of the pie for the Shoreham 24 pie? Is there an uncdrtainty bound associated with that
(
25 ATWS probability?
i ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
6329 1 A (WITNESS BURNS) Yes, sir. I guess possibly I
{ 2 may have been remiss when I didn't say that these, of 3 course, are point estimate comparisons using mean _O 4 values, and tha t the uncertainties -- I tried to get at 5 it a little bit by saying that this is a useful 6 comparison in some cases, for certain limited purposes, i 7 if one keeps in mind the f act that these differences 8 must be tempered with the knowledge of the 9 uncertainties. 10 Ihank you. 11 Q Am I correct that there are uncertainty bounds 12 associated with each of the segments of each of these 13 pies that are not expressed on this page, on this pie ( 14 chart page? 15 A (WITNESS B UR N S) Not expressed on this chart, i~ 16 yes, sir. 17 MR. RAWSON: That's all I have, Judge. Thank 18 You. 19 JUDGE BRENNER: M r. Ellis. l l 20 FURTHER REDIRECT EXAMINATION ON BEHALF OF LICENSEE l 21 BY MR. ELLIS. 22 0 So that we can clarify the record, you were 1 23 asked a number of questions, Dr. Burns and Dr. () 24 Joksimovich, I think chiefly Dr. Burns, concerning 1ssumptions and so forth. I am correct, am I not, that 25 O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
.-=_ _ __
6330 the Limerick pie and the WASH-1400 pie are core melt and (]) I 2 the Shorehsm pie is core vulnerable; is that correct? 3 A (WITNESS BURNS) As reported in each of those 4 documents, yes, sir. 5 Q And when you testified in response to Judge 6 Carpenter's question about the fact the -- well, in 7 connection with Judge Carpenter's questions, you 8 indicated that the Shoreham pie would shrink if it were 9 reduced to core melt. Is that the same gra ph that you 10 were talking about there as at page 6 of Suffolk County 11 Exhibit 28? 12 MS. LETSCHE: Judge Brenner. 13 JUDGE BRENNER Let him answer that question 14 first, unless you're going to object to that particular 15 question. 16 MS. LETSCHE: Well, I was going to object to 17 this line of questioning, because I think it certainly 18 is very reiundant. I was attempting to clear things up 19 and I thought we had finally all understood it. 20 JUDGE BRENNER4 I never make that statement 21 about anything in this hearing. 22 Let him answer that one question. I think 23 there is an element of confusion in the previous question and answer. ( 24 25 WITNESS BURNS: On page 6 of Exhibit 28 and O ALDERSON REPORTING COMPANY,INC, l
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400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6331 () 1 Exhibit 24 for Shoreham, those do represent core 2 vulnerable conditions for which calculation of core melt 3 frequency would show a decrease in size of that pie. 4 BY MR. ELLIS: (Resuming) 5 Q So that we put matters in perspective, the 6 size, that is the circumference of the pie or the 7 diameter of the pie, is related to the figures that say 8 4.4, 4.4 for Shoreham, and 1.5 for Limerick, isn't that 9 right? I mean, the sizes of the pies don't have 10 anything to do with the powers of 10; they have to do 11 with the difference between 4.4 and 1.57 12 A (WITNESS BURNS) Yes, sir. The area is 13 directly proportional to those numbers, yes, sir. 14 Q So in terms of the overall number, they are
-5 15 both the same order of magnitude at 10 ?
16 A (WITNESS BURNS) Yes, sir. 17 JUDGE BRENNER: Mr. Ellis, could I jump in for 18 one moment, because I'm a little confused again. I 19 don 't know how important it is. Give us a moment. 20 (Board conferring.) 21 JUDGE BRENNER4 Dr. Burns, Er. Ellis asked you 22 if the Limerick pie -- if the Limerick pie was core 23 melt, and you said yes. Is that too simplistic, in view 24 of your previous inswer, the previous one Ms. Letsche ( 25 was asking you. O ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6332
' ao=* *ae O 3=ase "=rris te riant- r
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2 Limerick pie on page 6 of Suffolk County 28 for 3 identification, which is the revised Limerick pie. 4 WITNESS BURNS: This graph for Limerick is 5 characterized as core melt frequency in the Limerick 6 PRA. The graph for Shoreham is characterized as core 7 vulnerable frequency. We could in f act drav a similar 8 plot for Shoreham of core melt f requency and then I 9 believe that a comparison of that chart for Shoreham and 10 the Limerick chart that is presented would be a 11 meaningful comparison of core melt frequency. t 12 13 14 15 16 17 18 19 20 21 22 23 24 2 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6333 WITNESS BURNS: This graph for Limerick is (]) 1 2 characterized as core-melt frequency in the Limerick 3 PRA. The Graph for Shoreham is characterized as 4 core-vulnerable frequency. We could, in fact, draw a 5 similar plot for Shoreham of core-melt frequency, and 6 then I believe that a comparison of that chart for 7 Shoreham and the Limerick chart as presented would be a 8 meaningful comparison of core-melt frequency. 9 JUDGE BRENNER Did you not testif y at some to point that the Limerick pie chart in Suffolk County 11 Exhibit 26 was really closer to core vulnerable even 12 though the caption was " Core Melt," and tha t now in the 13 revised Limerick one there is some recovery assumed, and 14 to that extent it would bring it f urther away f rom the 15 Shoreham core-vulnerable? 16 But I did not take that to mean that you would 17 then attribute the correct label " Core Melt" to that 18 revised pie. In fact, wha t I inferred from all of that l 19 is just the whole use of these overall labels are I 20 misipading because you have got to h4e a look at what i 21 was assumed in the particular sequences What say you
! 22 to all of that?
- 23 WITNESS BURNS: THere is no question in my
() 24 mind that I agree that this presentation is confusing. I 25 And the prasentation on page 6 of Exhibit 28 is l k f ALDERSON REPORTING COMPANY,INC, I 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6334 () 1 additionally conf used because it is a mixture of -- it 2 is a hybrid , almost, of core-vulnerable and -core-melt. 3 So in that sense, it is very difficult to make that \ / 4 comparison on this basis. 5 JUDGE BRENNERs So when you answered Mr. Ellis 6 saying yes, tha t pie was core-melt, that was not~ fully 7 correct, or at least it could be misleading unless 8 explained as you just explained it? l 9 WITNESS BURNSs No, sir. I thought I ' 10 qualified his question by saying that as reported in the 11 Limerick PRA this is what they call " core-melt 12 frequency." And certainly, again I can't emphasize too 13 auch that to refer to only this chart to draw too many 14 conclusions is dangerous. I find it useful for some i 15 purposes, but I think it is;out of proportion with its 16 Worth. 17 JUDGE BRENNER: Out of proportion with its 18 confusion, you mean? 19 (Laughter.)
~
20 WITNESS BURNSs- Yes, sir. 21 JUDGE BRENNER: Mr. Ellis, do you have more 22 questions? 23 BY MR. ELLIS: (Resuming) () 24 0 Dr. Burns, Dr. Joksimovich -- well, let me try You indicated that when you did 25 Dr. Joksimovich first. O ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE S.W.; WASHINGTON, D.C. 20024 (202) 554 2345
6335 {} 1 your analysis for your testimony, that you did not go 2 back and review the documen t that has been marked as Suffolk County 28. Now that you have seen it, and given p 3 V 4 your knowledge of the Limerick and Shoreham PRA and your 5 knowledge of the plants and the analysis conducted, 6 including the information in Suffolk County 28, do you 7 still believe that the Limerick PRA gives you an 8 indication that the BWR-IV MARK 2 design at Shoreham 9 does not have any adverse systems interactions? 10 A (WITNESS J0KSIMOVICH) That is correct. 11 0 May I have your answer to the question, too, 12 Dr. Burns? Shall I restate the question for you? 13 A (WITNESS BURNS) I find it useful information, A ( / )1 14 but the only important issue in my mind is whether the 15 analysis at Shoreham finds anything different in whether 16 other information, including the Limerick PRA, 17 identified something that was not considered in the 18 site-specific evaluation of Shoreham. 19 0 Then looking just at the Shoreham PRA, does 20 your analysis disclose any unacceptable systems 21 interactions? 22 A (WITNFSS BUEF9) No, sir, not within the 23 criteria that we have suggested and reviewed it 24 against. 25 MR. ELLIS: T.a t co11pletes our redirect. O 'd ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (2C2) 554-2345
6336 () 1 EXAMINATION BY THE BOARD 2 BY JUDGE CARPENTER: 3 Q Dr. Joksimovich, I cannot resist the 4 temptation to ask you to look a t Staff Exhibit Number 3 5 once mere. I would like to draw your attention to page 6 11 of that document, and specifically to the third 7' paragraph, the second-from-the-last line. Would you 8 confirm for me that it reads: "PRA is not yet mature 9 enough to be debated in licensing hearings or in the 10 courts"? 11 JUDGE BRENNER: Now they tell me. 12 (Laughter.) 13 Q A yes or no will suffice. 14 A (WIINESS J0KSIM3VICH) I have observed that 15 these are comments made by Professor Lewis. I happen to 16 know him personally very well. And neither he nor I are 17 legal experts. However, both of us -- 18 0 If I may interrupt, I simply wanted to get you 19 to affirm that what I just quoted from that is as you 20 reads it. 21 A (WITNESS J0KSIMOVICH) I am sorry? 22 Q Do you affirm that I read the statement 23 accurately? 24 A (WITNESS JOKSIMOVICH) Yes, you did. 25 0 Is it your opinion that the maturity that is O v ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
1 l 6337 l l needed probably will come in the direction of the (J)
~.
1 2 standa rdized review so that one can compare a review for fx 3 a plant with a review for another plant in a ('^') 4 straightfoCward way without having to be so perplexed as 5 we have been the last few weeks? 6 A (WITNESS J0KSIMOVICH) Well, I sincerely hope 7 that we are not going to get to the point of the 8 standard reviews. I think that we have an extremely 9 useful document called "PRA Procedures Guide" that you 10 have observed in my testimony. 11 The document was deliberately structured not 12 to be overly prescriptive. I think that we have 13 suffered a great deal in this country from trying to 14 come up with an overly prescriptive regulatory process. 15 In other countries where I have lived and heard some 16 things, the licensing process is structured along 17 guidelines. 18 And in Great Britain, in particular, they only 19 have one document, which is es11ed " Safety Principles," 20 and it is not meant to be prescriptive at all. And 21 hence the designers and the regulators are given all of 22 the freedom they need to come up with optimum designs as 23 opposed to be severely restricted by come regulations. 24 0 Do You not agree that it makes it very 25 dif ficult f or an independent reviewer to come along and Iv ') ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6338 () I try to evaluate the quality? I see many of the virtues 2 to that, but I am trying to get a f eel f or wh e the r -- 3 the sta temen t " mature," I am not sure 5 years er 10 4 years is going to change it. I am curious to see 1 5 whether 5 years or 10 years is going to change whether 6 it is really age or whether inherently PRA is a very 7 difficult thing to litigate and to evaluate in terms of 8 quality. 9 A (WITNESS J0KSIMOVICH) Well, in my opinion, 10 no. But there again I am not a legal expert. I have 11 been, however, in the last few years exposed to legal 12 processes, and I have observed that in one case in Great 13 Britain they have used the probabilistic approach to 14 determine whether a murder has taken place or not. And l 15 since the defense attorneys established the probability 16 was less than 10-6, the case was dismissed. 17 0 Thank you very much for wherever you took me. 18 (laughter.) 19 A (WITNESS J0KSIMOVICH) And if I may add, I do 20 not believe in the black-and-white type of situations 21 which typically are present in the legal proceedings. 22 There is always a shade of gray, and the probabilistic 23 approach provides new insights into how gray that gray 24 is. 25 (The Board conferred.) () i ALDERSON REPORTING COMPANY,INC,
6339 s JUDGE BRENNER: Well, we are not going to ask (u~) 1 2 you about how you make sure safety goals are 3 well-scrubbed. Safety goals are the context of this 'f s\ i
'~) 4 particular paragraph by Dr. Lewis and, in fact, the 5 whole letter, as de discussed yesterday. So we will let 6 that opportunity go by. Maybe somebody will ask you 7 about the murder off the record also.
8 Are there any other questions based just upon 9 the last question? I hope not. 10 (No response.) 11 JUDGE BRENNER: The time has finally come, 12 almost, subject to the document that still has not been 13 -- or the documents that Mr. Kascsak has to compile as ['N (_) 14 soon as we give him an opportunity to do that. 15 Well, I thanked you yesterday, and I reiterate 16 those thanks today, subject only to the document or 17 those documents the panel is completed on 18 cross-examination. 19 (Witnesses excused.) 20 JUDGE BRENNER: It is 11:45. Let us take a 21 1-hour break and then come back. And remember, we are 22 going to adjourn at 2:30. 23 (Whereupon, at 11:45 a.m., the hearing in the 24 above-entitled matter was recessed, to reconvene at f 25 12:45 p.m., this same day.) O. LJ ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6340 1 AFT ER NOON EESSION (~s] s 2 ( 12:50 p.m.) 3 JUDGE BRENNER: Back on the record. I.s) 4 The Staff is going to call its witness panel 5 on this Contention. 6 MR. REIS: Mr. Chairman, before we get to 7 that, there is one other matter I hesitate to bring up, 8 but it does have to be brought up. 9 I was in contact with the office during 10 lunchtime today concerning the memorandum you asked for 11 on conflict of interest and the situation which might 12 create the impression of impropriety from a conflict 13 between review and preparation of application. (_,/ 14 The Operations and Administrative Division of 15 the Office of Executive Legal Director of the NBC is 16 looking into this matter and finds that it is 17 considerably more complex than we were led to believe in 18 the beginning and finds that a proper analysis of the 19 law, the regulations, the contracts that do exist -- and 20 ve ha ve to face them in a factual situation that does 21 exist -- a n d just what is involved in each of those 22 contracts will require substantially more time than we 23 indicated to the Board before. 24 Mr. Began, who is division chairman or 25 division chief of that division, and Mr. Murray, deputy [ l ('_N) r ALDERSON REPORTING COMPANY, INC, I
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400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 i
. 6341 m
() 1 executive legal director, estimate that they would -- 2 that that ma tter could not be complete before July 23.
"N 3 And we are prepared to submit it to the Board at th a t (U 4 time. Prior to tha t time, we cannot have a complete 5 product.
6 (The Board conferred.) 7 JUDGE BRENNER: Well, we certainly want the 8 job done right, and that is the thrust of your comment. 9 Depending on what we do, this could put the schedule for 10 the proceeding in a terrible bind, however. 11 MR. REIS: I realize that, Your Honor. I 12 think we ought to go ahead and accept things and 13 recognize that that might have substantial effect, and 14 it might require the calling of witnesses or what have 15 you. That is what I have been informed, and I can see 16 where looking at this sort of thing could take that 17 time. I do not think that the request is unreasonable, 18 considering what is involved in those regulations. 19 JUDGE BRENNER. All right. It occurs to me 20 that in suggesting that date you had in mind some of our 21 comments. I do not remember if it was at the meeting of 22 counsel or on the record or both that we have that break 23 coming up and we wa n ted to be able to begin focusing on 24 it before that break. And you have probably picked the i 25 last date. And it is still getting tight. O
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l ( ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
6342 i MR. REIS: Your inference is wrong. The date (/)
~
1 2 was applied by the home office to me. fx 3 JUDGE BRENNEP By the way, I did not mean () 4 that there would be an unf avorable inf erence even if it 5 had gone the other way. It would have been a reasonable 6 trade-off perhaps. 7 All right, we will have to live with that, and 8 the schedule for the proceeding will have to live with 9 that. If there is a way to get some advance indica tion 10 -- not right now but in advance of the 23rde -- as to 11 the thrust of what the Staff view will be, particularly 12 if it could upset the applecart, so to speak, that is 13 going to be, obviously, very helpful. b'l (,/ 14 MR. REIS: Rig'ht now I have no indication tha t 15 it upsets the applecart. There are conclusions given in 16 memorandum or as i preliminary matter that would be 17 changed. It is just the Board raised this matter, and 18 ve felt we should put it to rest one way or the other. 19 And we feel it will take that length of time to do it. 20 We will also -- we could undertake to give the 21 Board a progress report around the 15th of July -- well, 22 let's see, today is the 9th. The 15th is a little too 23 close. Let us say towards the end, at the end of next 24 week, which is the 15th. Let us make it the following 25 Monda y or Iuesday. We will give a progress report. O b ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
i 6343 ; JUDGE BRENNER: That would be helpful. Since (]) 1 2 you are taking additional time, I ce rtainly hope that -- 3 we attempted to make some comments the other day that 4 would help focus our interest, and I assume that is 5 going to be taken into account in addition. 6 One thing we were considering is that 7 regardless of what the Board for itself decided in the 8 context of this particular case, and that is the only 9 thing we were going to focus on, we were thinking of 10 some way of apprising whatever cognizant offices there 11 would be, whether it would be the Commission itself or 12 the Office of General Counsel or some other body, that 13 from an administrative point of view we would be 14 interested in focusing on this for its possible 15 implication in other proceedings. 16 MR. REIS: I agree, Your Honor, that would be 17 very appropriate. But let us sue what the effect of 18 this examination is. We certainly have already brought 19 in and are consulting with the trial attorneys at least 20 in other proceedings which have been mentioned in the 21 past and are looking at this from a larger scope than 22 just this proceeding. We are looking at it in a hearing 23 p ro ceeding , and certainly it does af f ect our () 24 contracting. 25 As we indicated in the memorandum we already O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
1 6344 {) 1 filed, there is processes by which we screen these Now, to the extent that this 2 matters and look at them. 3 turns out not to be sufficient, we will certainly go O 4 beyond that, and we think all levels of the Commission. 5 should be involved in that if that is so, if there is a 6 blot on the independence of the review of the. Staff. 7 JUDGE BRENNER: Well, all I was going to - 8 suggest is that since additional time is being taken and 9 we do not get caught short at the end after we make our 10 preliminary determination, it would be good, I think, if 11 some mechanism on an informal basis for now could be 12 found for the Staff people working on it to keep an 13 appropriate contact in the Office of General Counsel or 14 wha tever appropriate Commission of fice would be 15 appropriate. I do not know if it is the OGC. 16 MR. REIS I am not sure myself, Your Honor. 17 But we will look in to tha t. 18 JUDGE BRENNER Either Mr. Remick 's of fice -- 19 I forget the name of it now. 20 MR. REISa Policy Evaluation. j 21 JUDGE BRENNERa Or OGC or both, in the' sense 22 that they know of the inquiry and perhaps could be l 23 supplied copies of wha t we have been given so f ar and l the contemporaneous copy of what the Staff is going to ( 24 l 25 supply when it supplies it to the parties, just so if we 1 () l l ! ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554 2345
6345 O 1 do refer something to them -- and I do not know that we 2 will -- it will not be the first time they have heard 3 sbout it. 4 The reason I suggested it now is I thought we 5 would be focusing on this a lot sooner. Now that we are 6 going to be delsyed, maybe we could save some time later 7 perhaps. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 O ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6346 4 () 1 MB. REISs Well, as you probably recognize, 2 Your Honor, this is s continuing problem within the 3 Commission, with the limited amount of specialized 4 contractors in certain areas, and this has -- is and has 5 been looked at by the Commission, and of course in the 6 past contractors have reviewed applications and 7 testified on comple tely dif f erent applications. 8 It is nothing new from that point of view, but 9 we will look at it further and see what the story is and 10 make sure that there is nothing that could leave any 11 doubt to the Staff's independence in this regard. 12 JUDGE BRENNER All right. We will look 13 forward to the progress report, and also a very thorough s' 14 analysis of the question. 15 HR. RAWSON: Judge Brenner, at this time the 16 Staff calls as its witnesses on contention 7.B and SOC 17 contention 19.B Demos P. Speis, Walter P. Haas, Marvin 18 W . Hodges, C .E. Rossi, Jame s H. Conran, Senior, and 19 Robert Kirkwood. 20 JUDGE BRENNER: .I guess other than Mr. Hodges 21 and Mr. Kirkwood, the witnesses have not been sworn. 22 .5 R . RAWSON: That's right, Your Honor. 23 JUDGE BRENNER: If the rest of you would 24 rise. 25 Whereupon, ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6347 O ' rat"1s P- ser1s
.2 WALIER P. HAASS p 3 C. E. ROSSI U 4 JAMES H. CONRAN, SR.,
5 called as witnesses by counsel for the Regulatory Staff, 8 and 7 MARVIN W. HODGES and 8 ROBERT KIRKWOOD, 9 recalled as witnesses by counsel for the Regulatory 10 S taff, having first been duly sworn by the Chairman, - 11 were examined and testified as follows: 12 DIRECT EXAMINATION 13 BY MR. RAWSON: v 14 0 Gentlemen, you each have before you a 15 nameplate for the benefit of the reporter. Would you 18 also each state your name for the record, beginning with 17 Mr. Hodges on the righ t. 18 A (WITNESS HODGES) My name is Marvin W., Wayne, 19 Hodges. 20 A (WITNESS ROSSI) My name is Charles E. Rossi. 21 A (WITNESS SPEIS) My name is Themis P. Spels. 22 A (WITNESS CONRAN) My name is James H. Conran. 23 A (WITNESS HAASS) My name is Walter P. Haass. 24 A (WITNESS KIRKWOOD) My name is Robert 25 Kirkwood.
- O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6348 () 1 Q Sentlemen, do you each have a copy of the
. 2 prefiled testimony which was filed in this contention, 3 and would you each have tha t in f ront of you, please?
4 A (WIINESS SPEIS) Yes, sir. 5 0 Dr. Speis, was a copy of your qualifications 6 attached to that prefiled testimony? 7 A (WITNESS SPEIS) Yes, sir. 8 Q Are there any changes or corrections that you 9 would like to make to your professional qualifications 10 at this time? - 11 A (WITNESS SPEIS) Yes, there is a minor 12 change. Somewhere between being the branch chief of the 13 LHFBR Branch and the branch chief of the Reactor Systems (
~
14 Branch, I was the branch chief of the Advanced Reactors - - 15 Branch in the Office of Nuclear Reactor Regulation for 16 about a year. 17 0 Is that the only change you wish to make to 18 your professional qualifications? 19 A (WITNESS SPEIS) Yes, sir. . 20 0 As corrected, are your professional 21 qualifications true and correct? 22 A (WITNESS SPEIS) Yes, to the best of my 23 memory. 24 MR. RAWSON: Judge, that one additional change l 25 has not been made for the reporter and we will see to () ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
6349 ( 1 that at a break. 2 JUDGE BRENNEPs Well, you don't have to make 3 that one. In other words, that is different than just a 4 strikeout and it is in the record. Thank you. 5 BY MR. RAWSON: (Resuming) 6 0 Mr. Haass, do you have a copy of your 7 professional qualifications that was attached to your 8 prefiled testimony? 9 A (WITNESS HAASS) Yes, I do. 10 0 Are there any changes or corrections that you 11 vish to make to that? 12 A (WITNESS HAASS) No, there are not. 13 0 Are those professional qualifications true and s/ '- 14 correct? -- 15 A (WITNESS HAASS) To the best of my knowledge, 16 yes. 17 Q Mr. Hodges, do you have a copy of your 18 professional qualifica tions? 19 A (WITNESS HODGES) Yes, I do. 20 0 Are there any changes that you wish to make to 21 those? 22 A (WITNESS HODGES) No, there are not. 23 0 Are they true and correct? O (/ 24 A (WITNESS HOD,GES) Yes. 25 0 Dr. Rossi, do you have a copy of your O ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTCN D.C. 20024 (202) 554 2345
6350 () 1 professional qualifications ? 2 A (WITNESS ROSSI) Yes, I do.
. 3 Q Are there any changes or corrections you wish 4 to make?
5 A (WITNESS BOSSI) No, there are no t. 6 Q Are those professional qualifications true and 7 correct? . 8 A (WIThESS ROSSI) Yes, they are. 9 0 Mr. Conran, do you have a copy of your 10 technical qualifications, professional qualifications? 11 A (WITNESS CONRAN) Yes, I do. 12 Q Are there any changes that you wish to make to 13 those? .
~~
14 A~ (WITNESS CONRAN) No changes.- - 15 0 Are they true and correct? 16 A (WITNESS CONRAN) They are. 17 0 M r. Kirkwood, do you have a copy of your 18 professional qualifications that were attached to the 19 prefiled testimony?
. 20 A (WITNESS KIRKWOOD) Yes, I do.
21 Q Are there any changes or corrections that you 22 wish to make to those? 23 A (WITNESS KIRKWOOD) There are no changes. ( 24 0 Are they true and correct? 25 A (WITNESS KIRKWOOD) Yes. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6351 () 1 Q. Dr. Speis, do you have before you a copy of 2 the prefiled testimony with the attachment of the Dircks 3 memorandum, the memorandum and its enclosures, including 4 the Conran to Thadani memo? 5 A (WITNESS SPEIS) Yes, I do. 6 Q Do you also have a copy of an errata sheet for 7 NRC Staff testimony on contention 7.B and SOC contention 8 19.B? 9 A (WITNESS SPEIS) Yes, I do. 10 0 Are those all of the changes or corrections 11 that the panel wishes to make to its prefiled 12 testimony? ; 13 A (WITNESS SPEIS) There is an additional . ( 14 correction on page 9, which will--be addressed by Mr. t 15 Haass. 16 A (WITNESS HAASS) On page 9, some additional i 17 words should be added on line 10. The sentence 18 beginning with the word "nevertheless," the following 19 words should then be added prior to "all," and the words 20 are " design criteria and quality standards for." 21 MR. RAWSON: Judge Brenner, does the Board 1 22 vish to have the substantive changes on that errata 23 sheet done orally or is it sufficient to simply attach ( 24 the errata sheet? 25 JUDGE BRENNER: It is sufficient to attach the i () ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
- I 6352 l
() 1 sheet. And as you mentioned, you had also made the 2 changes by hand on the copy being bound in. 3 MR. RAWSON: All of the changes have been made 4 on the copy to be bound in. 5 JUDGE BR.ENNER: Thank you. 6 BY MR. RAWSON: (Resuming) 7 Q Gentlemen, I would like an answer from each of i 8 you on this. Is the prefiled testimony as corrected 9 true and correct and do you adopt it as your testimony 10 in this proceeding? Can we begin with Mr. Hodges again, 11 please. 12 A (WITNESS HODGES) Yes, it is correct as 13 corrected, and I adopt it as my testimony.. ( 14 A (WITNESS ROSSI)- Yes, it is correct as . 15 corrected, and I sdopt it as my testimony. 16 A (WITNESS SPEIS) Yes, it is correct as 17 corrected and I sdopt it as my testimony. 18 A (WITNESS CONRAN) Yes, it is correct as 19 corrected and I adopt it as my testimony. 20 A (WITNESS HAASS) Yes, it is correct as 21 corrected and I adopt it as my testimony. 22 A (WITNESS KIRKWO3D) Yes, it is correct as 23 corrected and I adopt it as my testimony. ( 24 MR. RAWSON: Judge Brenner, at this point I 25 would like to ask that the prefiled testimony with its O I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6353 () 1 attachments be bound into the record. 2 JUDGE BPENNER: This is arguably premature in 3 the way we usually conduct things on this proceeding, (~} V 4 although it wouldn't be premature in court. But I would 5 like to inquire as to the involvement of any or all of 6 these witnesses in the memorandum from Mr. Dircks to Mr. 7 Shevmon. 8 MR. RAWSON: Judge, I would be happy to do 9 tha t on the record. 10 JUDGE BRENNER Yes, maybe now, before we 11 admit things into evidence, is what I was thinking. And 12 the reason I ask i.s, as I look through the concurrences, 13 I don't see any of these witnessgs listed, unlike the 14 obvious connection,'for example, of Mr. Con ran to his 15 memorandum. And I don't want to go too far into it now, 16 but we had - questions have been raised about the 17 substance of that memorandum already, and if we are 18 admitting it into evidence for the truth of the matter 19 asserted , I want to make sure that there is a witness 20 here who is knowledgeable as to the matters asserted. 21 That would be the thrust. 22 MR. RAWSON: Very well, si r. 23 BY 3R. RAWSDN (Resuming) ( 24 C Mr. Conran, are you f amiliar with a document 25 which is a memorandum from Mr. Dircks to Dr. Shewmon O l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6354 () 1 dated February 12, 1982, which has been attached to the 2 prefiled testimony here? 3 A (WITNESS CONRAN) Yes, I am. 4 C Can you briefly describe your familiarity with 5 that document? 6 A (WITNESS CONRAN) I know the context in which 7 it was written. I assisted in the preparation and the 8 review of the document and in transmitting it through 9 Mr. Dircks to Paul Shewmon. 10 0 Are you also familiar with the memorandum 11 which is enclosure 1 to that document, the memorandum to 12 Mr. Thadani from James H. Conran?
, 13 A ( WITNESS CONRAN) Yes, I am.
f'/ j 14 "--- Q - Did you author that document? 15 A (RITNESS CONRAN) Yes. 16 JUDGE BRENNER: Let me see if I understand, 17 Mr. Conran. You wrote, even though you're not on the 18 concurrence here, you were one of the drafters of the 19 memorandum from Mr. Dircks? 20 UITNESS CONRAN4 That is correct, sir. Mr. 21 Coffman is my section chief and he was the principal 22 d ra f ter, but I assisted in the preparation and reviewed i 23 and commented on the memorandum. 24 BY MR. RAWSON: (Resuming) 25 Q Mr. Conran, does the Dircks memorandum, O . ALDERSON REPORTING COMPANY,INC, l
6355 () I together with the Conran memorandum we have just 2 discussed, reflect the Staff's position on the relation (s 3 between probabilistic risk assessment and systems 4 interactions? 5 A (WIINESS CONRAN) I think " Staff position" may 6 be a little strong. 7 JUDGE BRENNER: I am sorry, I didn't hear your l 8 last rhrase. A WITNESS CONRAN: I said I think the phrase 10 " Staff position" may be a little strong. The fact of 11 the matter is that the Staff's position on those 12 subjects is still f orming. Another key document in that 13 formulation process I understand went from Mr. Dircks to
- 14 the Commission this week.
15 The substantive content of these menos is 16 certainly consistent with the Staff's thinking as 17 reflected in the process of forming positions. I 18 Specifically the points tha t have been discussed, the 19 substantive points that have been discussed so far in 20 this meeting, from my personal knowledge and involvement 21 in the process, had been reflected and are being taken 22 into account in the formulation of the Staf f 's policy on 23 these matters. 24 JUDGE BRENNER: Well, I had enough, even 25 before that last question, for what was for now my O D ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6356 () 1 limited purpose. And presumably we will explore the 2 relationship of the substantive content of the 3 memorandum further. 4 And I believe Staff counsel were previously 5 apprised that there might be some further pertinent 6 documents in the drafting stage or just being prepared. 7 I don 't know if tha t is the same thing as what Mr. 8 Conran just referred to or not. But presumably, if 9 there is something else pertinent, given the f act that 10 the Staff is offering this one memo from Mr. Dircks, we 11 will hear about it promptly, in view of the schedule. 12 MR. RAWSONa Yes, sir. That was the document 13 that I referred to either yesterday or the day before. 7,] [N-/-- 14 if it exists and has been forwarded to the Commission, 15 ve will be forwarding it to the Board. If it is i 16 publicly available, we will make it available 17 immediately. 18 (Pause.) 19 MR. RAWSON: Judge, my only point there was 20 that it may at this point be a confidential Commission 21 paper. We are inve s tiga tin g that and if it is the case 22 we would have to analyze furthat the propriety of l 23 p ro viding it at this time without special permission. 24 JUDGE BRENNER: If that is the case, I want to
./
25 be apprised of that, too. In other words, if the reason I (1) l ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6357 () 1 ve are not getting it is other than the fact it doesn't 2 exist, I want to hear about it. 3 MR. RAWSON: I understand that, Judge. 4 Judge, at this point would the Board prefer to 5 move on to the rebuttal testi. tony or have 1 brief 6 summary of the prefiled testimony that we have just 7 discussed? 8 JUDGE BRENNER: All right. There are'no 9 objections, I take it, to moving the basic testimony and 10 the attachments and qualifications into evidence? 11 (No response.) 12 JUDGE BRENNER: All right, that will be
'13 admitted into evidence and bound into the record as if O
O 14 read. 15 (The document referred to, Staff testimony on 16 contention 7.B and SOC contention 19.B, with 17 attachments, corrections, and the statements of 18 professional qualifications of supporting witnesses, 19 follows ) 20 21 22 i l 23 24 25 A V
- ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
F {43 -in UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
. BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of LONG ISLAND LIGHTING COMPANY ) Docket Nos. 50-322
) (0L)
(Shoreham Nuclear Power Station, ) Unit 1) ) NRC STAFF TESTIMONY OF THEMIS P. SPEIS, WALTER P. HAASS, MARVIN W. H0DGES, C. E. ROSSI, JAMES H. CONRAN, SR. S AND ROBERT KIRKWOOD ON SAFETY CLASSIFICATION AND
/ ANALYSIS OF STRUCTURES, SYSTEMS AND COMP 0NENTS SC/ SOC CONTENTION 7B)
S0C CONTENTION 19(b)) r I !O - 1
T' OUTLINE OF TESTIMONY O Suffolk County and Shoreham Opponents Coalition contend that Long Island Lighting Company (LILCO) has not adequately classified or analyzed Shoreham structures, systems and components which are important to safety and thus is unable to demonstrate compliance with the Nuclear Regulatory Commission's General Design Criteria. Shoreham Opponents Coalition further contends that the NRC Staff has not required LILC0 to incorporate measures to assure that Shoreham conforms with the standards or goals of safety criteria contained in specified regulatory guides. This testimony addresses the matters raised in SC/ SOC 7B and SOC 19(b). The following principal points are made:
- 1. The principal terms used in the safety classification of structures, systems and components are "important to safety" and " safety-related."
- 2. Structures, systems and components which are important to safety are addressed in Applicant's Safety Analysis Report and in the Staff's review.
- 3. Structures, systems and components which are safety-related receive special attention through the application of stringent design criteria and quality assurance standards and a more extensive regulatory review and are listed explicitly in Section 3.2.1 of Applicant's Safety Analysis Report.
- 4. A systematic methodology has been utilized in addressing structures, systems and components important to safety.
- 5. The water level indication system and the standby liquid control system specifically have been properly analyzed and classified to ensure compliance with NRC regulations.
- 6. The turbine bypass system, level 8 trip, rod block monitor and -
i RCIC are also discussed and the appropriateness of the analysis and classification applied to them is demonstrated. I 1
r
- 7. The alternative methodologies proposed by Intervenors and their witnesses are not required by either the regulations or staff practice in the safety classification of structures, systems and components. Good reasons exist why this is so.
O- 8. The Staff believes it is acceptable to permit operation of Shoreham despite the issues being studied as unresolved safety issue A-17.
- 9. The Staff believes it is acceptable to permit operation of Shoreham despite the issues being studied as unresolved safety issue A-47.
- 10. The safety classification of structures, systems and components at the Shoreham plant and the measures taken to assure the reliability of structures, systems and components important to safety are in compliance with NRC regulations and with staff practice implementing those regulations.
O o O . i
O TABLE OF CONTENTS I. INTRODUCTION OF W ITNESSES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. STATEMENT OF CONTENTION.................................. 3 III. PREMISE FOR SAFELY CLASSIFICATION OF STRUCTURES, SYSTEMS AND COMP 0NENTS........................................... 4 IV. CLASSIFICATION Of STPitCTURES, SYSTEMS, AND COMP 0NENTS AT SH0REHAM.............................................. 9 V. DEFENSE OF METH0IOLOGY USED IN CLASSIFICATION OF STRUCTURES, SYSTEMS AND COMPONENTS AT SHOREHAM........... 15 VI. DEMONSTRATION OF THE ADEQUACY OF THE CLASSIFICATION OF STRUCTURES, SYSTEMS, AND COMPONENTS AT SH0REHAM.......... 23 VII. DEMONSTRATION OF THE ADEQUACY OF THE CLASSIFICATION AND ( ]) ANALYSIS OF THE REACTOR VESSEL WATER LEVEL MEASUREMENT SYSTEM AT SH0REHAM....................................... 28 VIII. DISCUSSION OF ALTERNATIVE METHODOLOGIES PROPOSED BY SUFFOLK COUNTY AND THE SHOREHAM OPPONENTS C0ALITION CO N T E NT I O N 7 8. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 l IX. MANAGEMENT OF UNRESOLVED SAFETY ISSUES A-17 AND A-47 FOR l SH0REHAM................................................. 34 X. CONCLUSION............................................... 46 l l (::) . f .
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m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
) BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of LONG ISLAND LIGHTING COMPANY Docket No. 50-322 (OL)
(ShorehamNuclearPowerStation, Unit 1) NRC STAFF TESTIMONY OF THEMIS P. SPEIS, WALTER P. HAASS, MARVIN W. H0DGES, C.E. ROSSI, JAMES H. CONRAN, SR. AND ROBERT KIRKWOOD ON SC/ SOC CONTENTION 78 AND S0C CONTENTION 19(b) I. INTRODUCTION OF WITNESSES Q.1 Would each of the panelists please state his name and position with + the NRC. A.1 My name is Themis P. Speis. I am Assistant Director for Reactor Safety, Division of Systems Integration. A copy of my professional l qualifications is attached. l l My name is Walter P. Haass. I am Branch Chief, Quality Assurance Branch. A copy of my professional qualifications is attached. My name is Marvin W. Hodges. l I am a Section Leader in the Reactor 1 Systems Branch. A copy of my professional qualifications is attached. My name is C. E. Rossi. I am a Section Leader in the Instrumentation and Control Systems Branch. A copy of my professional qualifications is attached. l.
^
My name is James H. Conran, Sr. I am a Principal Systems Engineer in the System Interaction Section, Reliability and Risk Assessment - im Q Branch. A copy of my professional qualifications is attached. My name is Robert Kirkwood. I an a Principal Mechanical Engineer in the Mechanical Engineering Branch. A copy of my professional qualifications is attached. Q.2 Dr. Speis, would you please describe the responsibility of each of the panelists for the various portions of the prefiled testimony. A.2 Dr. Rossi was jointly responsible for Sections III, V, VI and VII g and was responsible for Section IX (questions 40 and 41); he also comented on and participated in preparation of all of the testimony. Mr. Conran was jointly responsible for Section III and was responsible for Section VIII and Section IX (question 39); he also comented on and participated in preparation of all of the testimony. Mr. Hodges was jointly responsible for Section V and VI and was responsible for Section VII; he also comented on and participated in preparation of all of the testimony. Mr. Haass was jointly responsible for Section III and was responsible for the answer to question Q-12; he also comented on and participated in preparation of Sections IV, V and VI. Mr. Kirkwood was responsible O ror the e#swers to nuestio#s a-7. a-8. a-9. a-to eaa a-11. i aeve participated in preparation and review of all of the testimony; I was not the primary author of any specific portion of t','e testimony.
Q,3 What is the purpose of your testimony? O A.3 The purpose of this testimony is to respond to Suffolk County and the Shoreham Opponents Coalition Contention 78 that Long Island Lighting Company has not adequately classified or analyzed Shoreham structures, systems and components (SS&C) which are important to safety, and is therefore unable to demonstrate compliance with the Nuclear Regulatory Commission's General Design Criteria. It is also the purpose of this testimony to respond to the Shoreham Opponents Coalition Contention 19(b) that the Staff has not required LILCO to incorporate measures to assure that Shoreham conforms with the standards or goals of safety criteria contained in specific regulatory guides. II. STATEMENT OF CONTENTION Contention 78 as restated by the Board in ASLB Memorandum and Order March 15, 1982, p. 12 is as follows:
"LILC0 and the Staff have not applied an adequate methodology to Shoreham to analyze the reliability of systems, taking into account systems interactions and the classification and qualification of systems important to safety, to determine which sequences of accidents should be considered within the design basis of the plant, and if so, whether the design basis of the plant in fact adequately protects against every such sequence. In particular, proper systematic methodology such as the fault tree and event tree logic approach of the IREP program or a systematic failure modes and effect analysis has not been applied to Shoreham. Absent such a methodological approach to defining the importance to safety of each pd piece of equipment, it is not possible to identify the items to which General Design Criteria 1, 2, 3, 4, 10, 13, 21, 22, 23, 24, .
29, 35, 37 apply, and thus it is not possible to demonstrate compliance with these criteria." Contention 19(b) as admitted by the Board in ASLB Order February 8, 1982, p.1 reads in part as follows:
" SOC contends that the NRC Staff has not required LILC0 to incorporate measures to assure that Shoreham conforms with the standards or goals of safety criteria contained in recent regulatory guides. As a result, the Staff has not required that Shoreham O str#ct#res. srste s e#d co Po#e#ts be beckrit es reauired by 10 C.F.R. 9 50.55a, 6 50.57, and 6 50.109 with regard to:
(b) Regulatory Guides 1.26 and 1.29. -- LILC0's general list of quality group and seismic design classifications listed in FSAR Table 3.2.1-1 is not in compliance with 10 C.F.R. Part 50, Appendix A, Criteria 1 and 2,10 C.F.R. 9 50.55a, and 10 C.F.R. Part 100, Appendix A in that: (1) the quality group classifications contained in FSAR Table 3.2.1-1 do not comply with the regulatory position of Revision 3, of Regulatory Guide 1.26 for safety-related components containing water, steam or radioactive materials; (2) the seismic design classifications contained in FSAR Table 3.2.1-1 do not comply with the regulatory position of Revision 3 of Regulatory Guide 1.29 with regard to control room habitability and radioactive waste systems; (3) LILC0 has not revised the FSAR Table 3.2.1-1 to expand the list of safety-related equipment as reflected in O' NUREG-0737 and as a result of the NRC Staff review of the Q-List as set forth in Supplement 1 of the SER on page 17-1; and (4) LILC0's list of safety related equipment contained in FSAR Table 3.2.1-1 does not include equipment upon which the plant operators will rely in response to accidents outlined in the Shoreham emergency operating procedures." III. PREMISE FOR SAFETY CLASSIFICATION OF STRUCTURES, SYSTEMS AND COMPONENTS Q.4 What is the purpose of the safety classification of nuclear power plant structures, systems, and components? O . l
r A.4 A nuclear power plant is comprised of many structures, systems, and Q components which have varying degrees of importance with respect to public health and safety. These structures, systems and components are designated as items "important to safety" in the General Design Criteria of Appendix A to 10 CFR Part 50. Appendix A to 10 CFR Part 100 identifies a specific subset of "important to safety" items required to assure certain critical safety functions in the event of accidents or emergency conditions. Items in this subset are referred to as " safety-related." Clarification of the definition of these terms as used in licensing reviews was provided in a letter dated November 20, 1981, to all Office of Nuclear Reactor Regulation Personnel from Harold R. Denton, Director of the Office of Nuclear Reactor Regulation. In this letter the terms "Important to Safety" and " Safety Related" are defined as follows:
"Important to Safety Definition - From 10 CFR 50, Appendix A (General Design Criteria)- see first paragraph of " Introduction".
a. Encompasses the broad class of plant features, covered (not necessarily explicitly) in the General Design Criteria, that contribute in important way to safe operation and protection of the public in all phases and aspects of facility operation (i.e., norma Toperation and transient control as well as accident mitigation). O w. ,i , ,a- ~ ,,a, ,1,,- - ~., ~n ,s a,c - .
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Includes Safety-Grade (or Safety-Related) as a subset. Safety-Related Definition - From 10 CFR 100, Appendix A - see sections III.(c), VI.a.(1), and VI.b.(3), Those structure, systems, or components designed to remain functional for the SSE (also termed ' safety features') necessary to assure required safety functions, i.e.: (1) the integrity of the reactor coolant pressure boundary; (2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the guideline exposures of this part. Subset of "Important to Safety"" A third term often used in classifying nuclear power plant Q structures, systems and components is " safety-grade." The Director's letter states that the terms " safety-related" and
" safety-grade" are equivalent. In this testimony, we will be following these definitions of terms.
A basic premise in the licensing of nuclear power plants is that the plant structures, systems and components which are safety-related (or safety-grade) are distinguishable from those which are non-safety-related (or non-safety-grade) by the stringency of the design criteria and quality assurance standards imposed on each O and by the extensiveness of the review by the NRC staff each . receives.
Practically speaking, a nuclear power plant must satisfy utility requirements for the production of power. Plant systems to O accomplish the desired operational characteristics are designed with the objective of allowing the plant to perform normal operations while at the same time providing sufficient margin for plant safety. In some cases, safety-related (or safety-grade) structures, systems, and components are used during nomal plant operation. This is the case, for example, with the reactor coolant system. In other cases, safety-related (or safety-grade) structures, systems, and components are provided for the sole ourpose of accomplishing safety functions. For example, this is the case for systems that automatically initiate reactor trip or automatically initiate systems to remove decay heat following an abnormal plant event. In any case having a specific, well-defined group of safety-related (or safety grade) structures, systems, and components to accomplish required safety functions allows both the applicant and the NRC staff to concentrate their efforts on structures, systems, and components most important i in achieving critical safety functions in case of an accident or emergency. It should be noted, however, that a substantial l fraction of the regulatory staff's review effort is applied to the review of systems whose proper operation can help prevent accident or emergency conditions, and, in fact, whose operation is important in assuring public health and safety even if there is never an accident (e.g., effluent control systems and reactor control rooms).
Q.5 Please describe the classification systems for plant items relative to quality assurance presently utilized by the staff. O A.5 Appendix B to 10 CFR Part 50 requires that a QA program which complies with criteria contained in that Appendix be applied to safety-relatedstructhres,systemsandcomponents. In implementing this requirement, safety-re'ated structures, systems and components are placed on what we call the QA-list which is generally presented in Section 3.2.1 of the Safety Analysis Report submitted by the applicant. This listing is reviewed by the various technical review branches within NRR to determine its correctness and completeness in the area of review responsibility for each branch. The listing must include all plant items designed O to seismic category I requirements (see Position C.1 of Regulatory Guide 1.29). It also includes other items not classified safety-related (e.g. PORV) identified after the TMI-2 accident as deserving increased QA attention by the applicant and staff. Further, some applicants on their own initiative have included yet other additional items not classified safety-related (e.g. fire protection system, l radwaste system) to which they intend to give higher emphasis with regard to QA. l l The remaining items in the total set of "important to safety" (i.e., l O those items which ere 1 Porteat to serety not aot serety-reletea) are subjected to quality assurance requirements in accordance with l
i GDC 1. The staff's present review process does not require that this subset be specifically identified in a listing, nor has the staff developed quality assurance requirements, analogous to Appendix B, for these items. The staff simply requires an applicant to comit to meeting the provisions of GDC 1 and has permitted applicants to determine the appropriate quality assurance requirements for these items consistent with their importance to safety. ppropriate quality assurance for some of these plant items may be no more than normal commercial practice. 4 tfier) g;vA Nevertheless,Lall structures, systems and components important to
# it/ safety are required to be addressed, sone in considerably A r'? Ap pq g g rr7>5 more detail than others, in the Safety Analysis Report submitted by the applicant.
O IV. CLASSIFICATION OF STRUCTURES, SYSTEMS, AND COMPONENTS AT SHOREHAM Q.6 Based on the staff's review of the Shoreham plant design, has a systematic methodology been used to determine which structures, systems and components are safety-related or important to safety? A.6 Yes. The structures, systems, and components which are "necessary to assure (i) the integrity of the reactor coolant pressure boundary, (ii) the capability to shut down the reactor and maintain it in a safe condition or (iii) the capability to prevent or
~
mitigate the consequences of accidents which could result in potential offsite exposures comparable to the guideline exposures of
this part" (10 C.F.R. Part 100, Appendix A) have been explicitly identified as safety-related (or safety-grade) by the applicant in plant design documents. These structures, systems and components include the containment building and that equipment such as piping and valves used to isolate the containment from the outside environment to the extent necessary to maintain radiological releases to within the limits of 10 CFR Part 100 following an accident. Also included as safety-related (or safety-grade) are those instruments and controls used for reactor trip, engineered safeguards actuation, or containment isolation. With regard to those structures, systems and components important to safety but not classified as safety-related, compliance with the O criterie eed reguirements of approved reguietory guidence documents (M., Standard Review Plan, Regulatory Guide, etc.) assures that such structures, systems and components are properly classified and addressed in the Applicant's submittal although they are not explicitly identified in a listing equivalent to the QA-list for safety-related items. I i Q.7 What seismic design classification system was used by LILC0 for l identifying those structures, systems, and components of the Shoreham plant that should be designed to withstand the effects of the Safe Shutdown Earthquake (SSE) and remain functional? , A.7 LILC0 used Regulatory Guide 1.29, Revision 1, for identifying those l
- structures, systems, and components that should be designed to I
withstand the effects of the SSE and remain functional. Revision I was used by LILC0 since this was the revision in effect at the time O the FSAR was docketed. The current revision of Regulatory Guide 1,29 is Revision 3 which is not substantially different from Revision 1. As there are no changes in Revision 3 which would cause a change in the seismic classification of the structures, systems, and components at Shoreham, the use of Revision 1 is acceptable. The plant features that should be designed to withstand the effects of the SSE and remain functional are identified in Regulatory Guide 1.29 as seismic Category I. To determine the extent to which the seismic Category I design classification is applied to each fluid system, Table 3.2.1-1 must be used concurrently with the O appropriate Piping and Instrumentation Diagram in order to perform a satisfactory review. The NRC staff performed the seismic classification review of the Shoreham systems identified in Table 3.2.1-1 in this manner. Our review of the seismic classification of the structures, systems, and components of the Shoreham plant l indicates that these plant features are in conformance with the l guidance in Regulatory Guide 1.29. The content and fonnat of Table 3.2.1-1 for Shoreham is consistent with other licensing applications such as LaSalle and Susquehanna and, in general, is at least as detailed as that provided for currently licensed plants. Q.8 How has LILC0 applied 10 CFR 50, Appendix B, to the structures, j systems, and components of Shoreham?
A.8 The LILC0 Quality Assurance Program that is in conformance with 10 CFR 50, Appendix B, is applied to those structures, systems, and components of the Shoreham plant that are designated safety-related. LILC0 has committed to apply quality assurance requirements to other structures, systems, and components that are not within the scope of Regulatory Guide 1.29 in accordance with the requirements of GDC 1. This practice is and has been acceptable to the staff on licensing applications since the promulgation of the regulation. Q.9 What quality group classification system was used by LILC0 for water, steam, and radioactive waste containing components of the Shoreham plant? A.9 LILC0 used Regulatory guide 1.26, Revision 1, as the basis for classifying water, steam and radioactive waste containing components of the Shoreham plant. Radioactive waste management systems are classified in accordance with Regulatory Guide 1.143. This guidance in Regulatory Guide 1.143 supercedes that found previously in Regulatory Guide 1.26 for these systems. Revision 1 of Regulatory Guide 1.26 was used by LILC0 since this was the revision in effect at the time the FSAR was docketed. The current revision of Regulatory Guide 1.26 is Revision 3 which is not substantially different from Revision 1. As there are no changes in Revision 3 which would cause a change in the system quality group classifications of the water, steam and radioactive waste containing components at Shoreham, the use of Revision 1 is acceptable.
The classification system identified in Regulatory Guide 1.26 consists of four Quality groups A, B, C, and D. The Guide O identifies the fluid systems applicable to each Quality group and the construction code applicable to each pressure-retaining component. To determine the classification boundaries of each fluid system, Table 3.2.1-1 must be used concurrently with the appropriate Piping and Instrumentation Diagram in order to perform a satisfactory review as it is the intent to only identify major components in the table. The NRC staff performed the quality group classification review of the Shoreham systems identified in Table 3.2.1-1 in this manner. Our review of the quality group classifications of the water, steam and radioactive waste containing components of the Shoreham systems indicates that these components are in conformance with the guidance in Regulatory Guide 1.26. The content and format of Table 3.2.1-1 for Shoreham is consistent with other licensing applications such as LaSalle and Susquehanna and is at least as detailed as that provided for currently licensed plants. Q.10 Is the LILCO Quality Assurance Program that is in conformance with 10 CFR 50, Appendix B, also applied to all components that are s classified Quality Groups A, B, C or D? A.10 No. For Shoreham all itens that are classified Quality Groups A or O B are within the scope of the LILC0 Appendix B Quality Assurance Program. Iteas classified Quality Group C are also within the scope of the Appendix B Quality Assurance Program except for certain items
that are upgraded from Quality Group D to Quality Group C. An example of items that are upgraded at Shoreham are components of the O reector weter cie euP system besond the reactor cooieat Pressure boundary isolation valves. Items upgraded to Quality Group C standards need not be subjected to an Appendix B Quality Assurance Program. 1 I Quality Group D items are not within the scope of the LILC0 Appendix B Quality Assurance Program. The description of Quality Group D in Regulatory Guide 1.26 does include the term " safety-related." flevertheless, the staff does not require that Quality Group D items be subjected to the Appendix B Quality Assurance Program. Even the most recent revision of Regulatory Guide 1.26 (Revision 3) was
- issued in 1976, well before Mr. Denton's letter clarified staff usage of safety classification tenns.
Q.11 What seismic design classification was used by LILC0 for the control room air conditioning system. A.11 As noted in FSAR Table 3.2.1-1, LILC0 has classified the control room air conditioning system as seismic Category I. The system is also within the scope of the LILC0 Quality Assurance Program that is l O in conformance with 10 CFR Part 50, Appendix B. In addition, as noted in FSAR Section 9.4.1, the chilled water cooling coils in the , air conditioning units are classified Quality Group C and l constructed to the requirements of ASME Section III, Class 3. l
l The system is therefore in conformance with the current applicable regulatory requirements. Q.12 Has the QA Listing of equipment shown in FSAR Table 3.2.1-1 been expanded to include items as reflected in NUREG-0737 ("Classifica-tion of TMI Action Plan Requirements")? A.12 In response to staff questions, the Applicant has documented its committment to apply the pertinent requirements of the Appendix B QA program to equipment listed in NUREG-0737. The documentation is presently provided by letters from LILC0 dated May 27, 1981 and July 15, 1981. The Applicant has been requested to include this documentation in the FSAR although use of Table 3.2.1-1 for this O purpose may not be appropriate nor is it necessary. V. DEFENSE OF THE METHODOLOGY USED IN CLASSIFICATION OF STRUCTURES, SYSTEMS AND COMPONENTS AT SHOREHAM Q.13 What analyses are used to verify that the proper structures, systems, and components have been identified as safety-related (or safety-grade)? A.13 Analyses of " anticipated operational occurrences" and " accidents" i are used to verify that the proper structures, systems, and components have been identified as safety-related (or safety-grade). O These analyses are contained in Chapter 15 of the Final Safety -
Analysis Report (FSAR) and the Staff review procedures for these analyses are delineated in Chapter 15 of the Standard Review Plan. O Q.14 How are the analyses in chapter 15 of the Final Safety Analysis Report (FSAR) used in verifying that the proper structures, systems and components have been required to be safety-related (or safety-grade)? A.14 A specific set of " anticipated operational occurrences" and
" accidents" are analyzed and documented in Chapter 15 of the FSAR to demonstrate that plant trip and/or safety system equipment actuation occurs with sufficient capability and on a time scale such that the consequences are within specified, acceptable limits. In these V analyses, conservative initial plant conditions, core physics parameters, equipment availability, and instrumentation setpoints have been assumed. Conservative core parameters (for example, heat fluxes, temperatures, pressures. and flows) are also assumed. Among the specific set of " anticipated operational occurrences" and
" accidents" analyzed are the limiting events resulting from both mechanistic and non-mechanistic equipment and system failures. The conservative bounding analyses performed are used to demonstrate that the potential consequences to the health and safety of the public are within acceptable limits for a wide range of postulated
] events even though specific actual events might not follow the same assumptions made in the analyses. In addition, the analyses performed are used to demonstrate that the potential consequences te
the health and safety of the public are within acceptable limits (i.e., offsite exposures are less than the guideline exposures of 10 Q CFR Part 100) when only safety-related (or safety-grade) equipmen: and systems are used to mitigate the consequences of the postulated events. Sufficient safety-related (or safety-grade) equipment is provided to assure that essential safety functions will be performed even with the most limiting single tailure. Q.15 What is the definition of a single failure? A.15 The definition of a single failure is given in the " Definitions and Explanations" included in 10 CFR Part 50, Appendix A:
"A single failure means an occurrence which results in the loss of capability of a component to perform its intended safety functions. Multiple failures resulting from a single occurrence are considered to be a single failure."
Q.16 Are all possible accident sequences analyzed in Chapter 15 of the Shoreham FSAR? A.16 No, it would not be possible to anciyze or even define all possible accident sequences for any nuclear power plant. However, the transient and accidents analyzed are representative of classes of events that have been judged to be of significant severity and j sufficient likelihood to require consideration. Similarly, the associated analysis methods and acceptance criteria are also not .
realistic, but are conservative, or bounding representations of actual or expected conditions. O Q.17 How can the staff conclude that Shoreham can be safely operated if all possible accident sequences have not been analyzed? A.17 As was discussed in the answer to the proceeding question, the plant design has been reviewed for a spectrum of transients and accidents that are representative of classes of events that have been judged to be of significant severity and sufficient likelihood to require consideration. But assuring an acceptable level of reactor safety is not limited to the analyses of a number of transients and accidents and ascertaining that the plant is rh O designed to control and/or accomodate the consequences of these events. Adequate safety also depends on a " defense in depth" approach which recognizes the availability of a large number of plant design features as well as the availability of well trained operators using carefully prepared procedures. The cornerstone of the " defense in depth" philosophy is the use of multiple, successive barriers to the escape of radioactivity and assuring that these barriers are not compromised as the result of transients and accidents. ] The first level of protection deals with design for safety in normal operation and tolerance for system malfunctions. It emphasizesq%11ty, redundancy,andinspectability. Criteria and
requirements applied to the structures, systems and components needed for normal operatio (e.g., primary pressure boundary, main O feedweter sistem. mein steem sistem. turbine redietioe monitorins system, effluent control system, the control room and control systems) are found in regulatory guidance documents and in the Standard Review Plan, Regulatory Guides, General Design Criteria (10 CFR Part 50, App. A). The second level of protection assumes that incidents will occur in spite of care in design, construction and operation. It requires the provision of systems to detect incipient failure and to shutdown the plant so as to prevent or minimiza damage when such incidents occur. The third level of protection assumes the occurrence of Os damaging accidents. It requires the provision of safety systems to limit or control the consequences of hypothetical accidents (e.g., loss of coolant accidents). In designing these safety systems, we require the assumption of a large fission product release per 10 CFR Part 100, where some protective systems are assumed to degrade or fail simultaneously with the accident they are intended to control. The reactor fuel cladding, the reactor coolant system pressure boundary, and the reactor containment building constitute the key parts of the third level of defense in depth. The fuel clad and the reactor coolant system boundary are designed to contain the O redioective fission products produced in the core iikewise the reactor containment building and ass ciated isolation equipment, which are safety-related (safety-grade), are designed to limit radioactivity releases and serve as the final boundary to the
outside environment. The analyses in Chapter 15 of the FSAR, which are reviewed by the NRC staff, are used to verify that the integrity O of the cladding, reactor coolant system boundary, or both, are maintained within specified limits following the postulated limiting events (i.e., both transients and accidents) discussed earlier. Another level of protection is provided by the trained operator and the emergency operating procedures. The operator, utilizing the procedures, is trained to take actions to maintain the plant in a safe condition independent of the type or number of equipment or system failures which might occur. In performing the key safety functions, the operator is instructed to use any and all equipment or systems which might be available whether it is safety-related O s safety-grade) or not. In addition to the design basis events, analyses assuming various event sequences (including multiple failures) that could occur and fall outside of the required design envelope have been utilized in the preparation of the emergency operating procedures. This approach for the plant operators is a result of the lessons learned from the TMI-2 accident. Its objective is to further assure that the operator is able to respond to the complete spectrum of possible events. It would be impossible to assume that an cperator could memorize all multiple failure sequences, and rapidly diagnose the actual, specific O event. Therefore, the approach we use is to guide the operator to recognition of certain symptoms of events, and to respond to
symptoms rather than to a specific event. This involves "all" events being broken down into categories that are all inclusive, e.g., e*2 loss of heat sink, overcooling, loss of inventorygreactivity. Me- ] omT4rws sert wwtp ssp proctw<W.s MwM _trai= cpc.eters end write-peecedtwes3to treat symptoms of these categories and gain control of the plant no matter what combination of failures caused the particular event. This approach is being implemented at the Shoreham plant. In summary, the analyses in Chapter 15 of the FSAR combined with the " defense in depth" approach, which has been extended to include multiple failures outside of the required design basis in the emergency operating procedures, and compliance with approved regulatory guidance, constitute the methodology used to insure that nuclear power plant operation will not result in undue risk to the health and safety of the public. It was never intended nor is it necessary to analyze all possible accident sequences to assure an adequate level of safety. Q.18 Is there any regulatory requirement or has past practice on any nuclear p1wer plant been to classify all equipment which is specified for use in emergency operating procedures as safety-related (or safety-grade)? A.18 No. As previously stated, regulations and the staff practice require that structures, systems, and components be safety-related (or safety-grade) if the structures, systems, and components are
"necessary to assure (i) the integrity of the reactor coolant pressure boundary, (ii) the capability to shut down the reactor and O maintain it in a safe condition, or (iii) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the guideline exposures of this part" (10 CFR Part 100). The key word above is the word necessary in the phrase" ...if the structures, systems, and components are necessary to assure...". Structures, systems, and components which may be utilized in emergency procedures over and above those which are necessary -- actually required -- to assure the functions above are not required to be classified as safety-related (or safety-grade).
O Q.19 Does the staff expect equipment which is not safety-related (or safety-grade) to be operable following an accident? A.19 Yes: in general. It is expected that the operator would use the non-safety-related equipment which remains operable to the maximum extent possible in controlling the course of any accident. However, the regulations and staff require that safety-related (or safety-grade) equipment meeting stringent design criteria and quality assurance requirements be provided to mitigate the consequences of accidents which could result in potential offsite O exposeres compere 81e to the 9uideliae ex9esures of lo CrR eert too. As discussed previously, however, this is only one part of the methodology used to assure no undue risk to the health and safety of the public.
VI. DEf'ONSTRATION OF THE ADE0VACY OF THE CLASSIFICATION OF STRUCTURES, SYSTEMS, AND COMPONENTS AT SHOREHAM Q.20 In the Staff's review of the Shoreham Chapter 15 " anticipated operational occurrence" and " accident" analyses, was adequate consideration given to the safety classification of systems used for
" anticipated operational occurrence" and " accident" mitigation?
A.20 Yes. In the sequence of events for each " anticipated operational occurrence" or " accident" the safety classification of the normally operating plant systems and engineered safety feature systems was reviewed. Further, in addition to analyses of design basis events, Shoreham plant systems design was reviewed against other criteria and requirements of approved regulatory guidance such as applicable
/O V
i
- Regulatory Guides and Standard Review Plan sections.
Q.21 Is the staff aware of the use of any equipment not classified as safety-related (or safety-grade) for the mitigation of any
" anticipated operational occurrence" or " accident" in the Shoreham Chapter 15 analyses?
l
- A.21 Yes. For example in the Feedwater Controller Failure (Maximum Demand) transient (" anticipated operational occurrence"), the high water level (Level 8) trip and the turbine bypass system are used to mitigate the transient. The equipment used for these functions is not classified as safety-related. Use of this equipment in
- mitigation of the transient is based on the consideration that the
equipment is of high reliability and subject to periodic surveillance requirements in the technical specifications. (See O Sections 7.e.u end 1s.2.1 of the Shorehem Sefety eveiuation Report.) Furthennore, the Feedwater Controller Failure event with assumed failure of the Level 8 trip and turbine bypass system would result in only very limited, if any, fuel failure and, thus, would not result in an undue risk to the health and safety of the public. Q.22 Is the reactor vessel water level measurement system at Shoreham safety-related? A.22 Yes. All portions of the Shoreham reactor vessel water level measurement system required to perform safety functions such as reactor trip or engineered safety feature system actuation are safety-related. (The operation of this measurement system is discussed in detail later in this testimony.) Q.23 Is the Standby Liquid Control System at Shoreham safety-related? A.23 Yes. All portions of the Shoreham Standby Liquid Control System required for the injection of fluid including the switch used to initate the system are safety-related. The portion of the control board upon which the switch is mounted is designed to survive a O seismic occurrence. Heaters, indicator lights and alarms not needed , for the actual injection of fluid are not safety-related. The
system is not requirtd to be a totally redundant system since it is I used only as a backup means for bringing the reactor to a O subcriticei coaaitio - Q.24 Is the Reactor Core Isolation Cooling (RCIC) system at Shoreham safety-related? A.24 Yes. The equipment required for the RCIC system to perform its safety function of injecting water is safety-related. The RCIC is a high pressure system primarily designed to maintain sufficient water in the reactor pressure vessel to cool the core and then maintain the reactor in the standby condition in the event the O vessel becomes isolated and feedwater is not available. During a loss-of-coolant accident (LOCA), the RCIC initiates on low vessel water level and delivers rated flow to the vessel through a connection in the feedwater system. Even though RCIC is not a part of the Emergency Core Cooling System (ECCS) network, the RCIC system is traditionally designated as a safety-related system. It is similar to the auxiliary feedwater systems in PWRs. During limiting conditions of operation (LCO), i.e., wher. High Pressure Core Injection System (HPCI) is inoperable, O no er operatio" is eiio ea to coati"#e for e period or time provided RCIC is operable. Moreover, credit is taken for RCIC when HPCI is inoperable in the Shoreham accident analysis (e.g., control rod drop accident).
Q.25 Is the Feedwater Control System at Shoreham relied upon to mitigate
" anticipated operational occurrences" or " accidents"?
l O A.25 No. It is, however, expected that the operator would attempt to manually control this system to mitigate excessive feedwater flow to the reactor vessel caused by a feedwater/ level control system failure. However, the Feedwater Control System is not required for the mitigation of any " anticipated operational occurrence" or
" accident".
Q.26 Would non-safety-related equipment at Shoreham be used during an
" anticipated operational occurrence" or " accident"?
A.26 Yes. Much non-safety-related equipment is in service during normal operation of the plant. This equipment would probably continue to operate during an " anticipated operational occurence" or " accident". It would be logical to make use of this equipment in mitigating an
" anticipated operational occurrence" or " accident" when possible.
However, backup safety-related systems are available to insure the health and safety of the public. An example is the plant feedwater system which is not safety-related. The operator is very familiar with this particular system
~
and would use it during a loss of coolant accident if it is (C' . available. It is not, however, necessary that the system be safety-related even though it might be used during an accident because other items which are safety-related are available to protect public health and safety.
Q.27 Are there structures, systems and components at Shoreham which are not safety-related but for which special design features or other lO considerations have been provided to assure reiiabiiity2 f A.27 Yes. Three specific examples are discussed in Section 7.6.11 of the Shoreham Safety Evaluation Report. The three examples are: (1) the reactor manual control system - rod block monitor ! (2) the feedwater control system high water level trip (" Level 8 trip") (3) the turbine bypass system. l l Q.28 What types of considerations have been applied to these systems over and above provisions which would normally apply to structures, O sxstems end components hevino no "importence to sefety"2
- i .28 The rod block monitor has a self-testing capability and the operability of this self-testing feature will be demonstrated periodically. The " level 8 trip" includes redundant level sensors
! and trip circuits with electrical isolation between the redundant J. portions. The time during which portions of the " level 8 trip" may be inoperable will be limited in the technical specifications. The technical specifi orcqs will require periodic surveillance to
! confirm ope et r.6 '/ the turbine bypass system. (See Sections 7.6.11 and 11.2.1 of the Shoreham Safety Evaluation Report.)
i 1
l VII. DEMONSTRATION OF THE ADEQUACY 0.: THE CLASSIFICATION AND ANALYSIS OF THE REACTOR VF.SSEL WATER LEVEL MEASUREPENT SYSTEM AT SHOREHAM - Q.29 Flashing in the reference leg of water level _ instrument lines has been cited by Suffolk County and the Shoreham Opponents Coalition as asystemsinteractioneffectwhichmaydelayEbCSactions.,What type of events will lead to flashing in the reference leg? A.29 There is the potential for' flashing whenever the reactor coolant system (RCS) pressure drops below the saturation pressure corresponding to the temperature near the reference leg. The staff has identified three possible scenarios which will lead to flashing. These are: (~) (1) Failure of drywell coolers and subsequent depressurization v as for shutdown. This has occurred at one plant (Pilgrim). For water level instruments such as exist at Shoreham, the RCS pressure would have to be lowered to approximately 50 psia for flashing to occur. (2) For a small steamline break, the drywell temperature could reach 340 F._ Flashing could then occur for RCS pressures less than.1 M psia.
// b' (3) A large break LOCA would result in approximately equal drywell and RCS pressure. Subsequent actuation of the containment spray would reduce RCS and drywell pressure and the heat stored in the instrument piping could cause some flashing to occur.
Liquid line breaks or large steamline breaks with resultant two-phase flow out of the break will not result in flashing in the instrument lines except as in case (3) described above. Q.30 Will any of the scenarios discussed above result in delayed actuation of the ECCS?
s-A 30 For case #(1) above, no break exists and there is no need for ECCS actuation. If a LOCA is postulated to occur while the reactor is in O V the shutdown cooling mode of operation and while the drywell temperature is still high, there is a possibility for delayed ECCS actuation. However, this is a very unlikely scenario. l For case (2) aoove, there would be no delay in ECCS actuation. For l case (3) above, the ECCS would already have been actuated prior to l containment spray; thus, there is no delay in ECCS actuation. Q.31 What are the consequences of loss of level indication due to flashing in the instrument lines? O A.31 If water level cannot be determined, the operator is instructed to depressurize the vemal (if not already depressurized) and flood the vessel with low pressure systems. Therefore, the fuel would remain covered and there would be no adverse safety consequences. Q.32 What is the maximum water level error which can result from flashing in the reference leg of the water level instrumentation at Shoreham? A.32 There are two reference columns for the water level instrumentation at Shereham. One reference column has a vertical drop in the O drywei, of 3.4s ft ead the other reference coiuma hes e verticei drop in the drywell of 6.73 ft. The maximum error which can result from flashing due to high temperature in the drywell is just the vertical drop in the drywell. However, the narrow range and wide
range level instruments are calibrated for normal operating conditions (fluid in the reactor saturated at 1000 psi and drywell temperature of 135'F). The vessel depressurization results in saturated fluid at a lower pressure. Therefore, the depressurization results in a decalibration of the wide range and narrow range instruments. The combined error due to flashing and decalibration is approximately 4.6 ft. for one reference column and 9 ft for the other reference column. Q.33 What is the safety significance of the 4.6 ft. and 9 ft. water level measurement error? A.33 There is no safety significance. The ECCS, if required, would be O ectueted prior to depressurizetion. The nom #ei water ievei is
/4 approximately 16 ft. above the top of the fuel. Therefore, even if the operator controls water level using the instrument with the maximum error, the fuel would still be covered with water and would be adequately cooled.
For the case of a large LOCA in a recirculation line and insufficient injection to flood the vessel above the top of the jet pumps, the actual level in the downcomer region (where level is measured) would be at the top of the jet pumps (2/3 core height) and the actual level in the core would be higher due to the generation of voids in the core. Tests conducted by General Electric have shown this water level sufficient to adequately cool the core. I-
Q.34 If there is no safety significance of the flashing phenomenon, why was a board notification issued? O A.34 The vertical drop of the reference legs in the drywell is variable from plant to plant. One operating BWR has been reported to have a maximum vertical drop in the drywell of approximately 40 f t. Several BWRs have vertical reference leg drops of approximately 20 ft. Some corrective measures will have to be taken for those plants (several of these plants are already voluntarily making modifications). Various operating plants are in the process of providing plant specific information. Data on the reference legs for Shoreham were not obtained prior to issuance of the board g notification. Q.25 Is there sufficient redundancy in the water level instrumentation to prevent a sensing line malfunction and another random single failure from impacting ECCS actuation? A.35 There is sufficient redundancy in the water level instrumentation to prevent a sensing line malfunction (e.g., break or leak) and another gwssriac;- cas sc xcic random electrical failure from h;_% CCCS,; actuation. Nov/</5 mdML stersnood woosv u etqJorrto. nsassi scrusn s siema rga g,s e rts roa nac- stencrart trei r won'so a sis rm a risc wsrtR
/ Nt t. ii) nit coird 60Hs not ra p et rdt scn v! /J.!L.
VIII. DISCUSSION OF ALTERNATIVE METHODOLOGIES PROPOSED BY SUFFOLK COUNTY AND THE SHOREHAM OPPONENT 5 COALITION CONTENTION 7B Q.36 Are probabilistic risk assessment, failure modes and effects anlayses, systems interaction analyses, or dependency analyses
- required by either the regulations or staff practice in the safety cla nification of structures, systems, and components?
A.36 No. These techniques have, however, been used in some cases to look for weak points in plant systems designs or to evaluate the risk of particular event sequences. The techniques have been used to identify failure modes and the need for equipment changes, increased surveillance, additional testing, and improved procedures to reduce the risk of particular event sequences. Q.37 Has a systematic methodology been developed for using probabalistic risk assessment, failure modes and effects analyses, systems interaction analyses or dependency analyses for the specific purpose of safety classification of nuclear power plant structures, systems and components? A.37 No, not for safety classification. However, since the mid-1970s the IEEE has considered the need for additional safety classes of electrical equipment and methodologies which could be used to l determine a " level of importance to safety" for nuclear power plant instrumentation and cer. trol systems. To date, the IEEE efforts have not been successful in producing a methodology acceptable on a consensus basis to the IEEE. Techniques for semi-quantitatively determining a " level of importance to .,afety" of instrumentation and control systems have been proposed, but these techniques are currently not sufficiently nature to be acceptable on a consensus basis to the IEEE or NRC staff.
Q.38 What use, if any, will the staff make of the Shoreham Probabilistic Risk Assessment (PRA) particularly as it relates to classification (9 v of structures, system, and components and identification of potential adverse system interactions? A.38 The staff has neither required a probabilistic risk assessment for Shoreham as part of the regulatory review process for issuing an operating license nor does the staff have specific criteria for evaluating such an assessment for Shoreham. The staff will, however, require submittal of the Shoreham PRA and will review it to gain added insight into potential safety improvements and will take appropriate actions. The staff will also review any actions taken by LILC0 as a result of the Shoreham PRA.jtev4i/ rat fraf/'J o 3N 't Q i ., r. grvsa wu 's .% rt& tsptsitscf n wrt sint rat 7;rn 's svaiiern>
/7 zi . d up iniaa reist inic.trts riar trudd & A wm rws,9gwr Other PRAs which are under review by the staff are being used to ### l'###
fn. " rut nM identify outliers, i.e., accident sequences which are major ,f ,7,
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contributors to core melt or events with severe societal fin p.7M. consequences. The staff has not used these PRAs specifically to classify items in the past. Adverse systems interactions that are identified by these studies and are major contributors to dominant accident sequences would be considered for additional action if deemed warranted, f) Classification of structures, systems and components is associated with analyses of design basis accidents, which include conservative analyses of certain postulated events and a single failure in systems relied on to mitigate the consquences of these postulated
events. PRAs use realistic assumptions to consider multiple failure events that result in extensive core damage or core melt. The PRAs Q consider all plant equipment, and the use of component failure probabilities in PRAs attempts to weight appropriately the potential contribution of non-safety grade equipment (to the extent that it is included in the analysis). The inclusion of non-safety grade equipment in a PRA is not necessarily a basis for changing its classification. IX. MANAGEMENT OF UNRESOLVED SAFEU ISSUES A-17 AND A-47 FOR SHOREHAM Q.39 Provide a brief description of the general concern and specific ob,iectives involved in Unresolved Safety Issue A-17, " Systems Interactions in Nuclear Power Plants". Also provide a brief discussion of the status of the staff's program to address and resolve this USI generically and for Shoreham. A.39 The discussion in Appendix B of the Shoreham Safety Evaluation Report will be augmented and updated here. The general concern involved in the systems inter ions issue is the possibility of one reactor plant system acting on one or more other systems in a way not consciously intended by design so as to adversely affect the safety of the plant. In designing reactor plant systems, therefore, a primary objective has been to incorporate design features (e.g., redundancy and diversity in systems that perform required safety functions, and independence of safety systems from all other plaut systems and from each other) such that, ideally, several independent
- 35'-
system failures must occur to degrade unacceptably or to fail totally any necessary safety function. The specific objective of a systems interaction analysis is to provide assurance that the independent functioning of safety systems is not jeopardized by preconditions within the plant design (particularly dependencies hidden in supporting and interfacing systems) that cause faults to be dependent. Within the existing regulatory framework, the systems interaction concern is addressed by evaluating plant designs against well-established deterministic requirements and criteria embodied in existing regulatory guidance documents (e.g., Regulatory Guides and the Standard Review Plan). These current requirements are founded or. the principle of " defense-in-depth"; and they include provisions for design features such as physical separation and functional independence of redundant safety systems, as well as other measures that provide protection against hazards such as pipe ruptures, missiles, seismic events, fires, and flooding. Also, the Quality l Assurance Program that is applied during the design, construction, and operational phases for each plant provides additional assurance l l in this regard by helping to prevent inadvertent introduction of ! adverse systems interactions contrary to approved design. l l Thus, although there is no explicit requirement for a dedicated, comprehensive systems interaction analysis of plant designs, and although there currently exists no well-defined, documented
methodology for systematic analysis of plant designs for systems interactions, the existing regulatory framework provides reasonable Q assurance against many types of potential systems interactions. As stated in a recent letter (dated February 12,1982) from William J. Dircks, Executive Director for Operations to Paul Shewmon, chairman, Advisory Committee on Reactor Safeguards (ACRS), regarding an ACRS recommendation that some additional systems interaction requirements l be imposed immediately on licensee / applicants:
"NRR continues in the confidence that current regulatory requirements and procedures provide an adequate degree of public health and safety" As also noted in that letter to the ACRS, some events have occurred in the past at operating plants that have adversely affected safety system redundancy, and the functioning of safety systems have actually been degraded in other events (e.g., the Browns Ferry partial failure -to-scram). The frequency and possible implications of such events has prompted the staff to consider whether additional system interaction analysis requirements should be developed and imposed in order to examine more fully than currently required the question of susceptibility of reactor plant systems to potential systems interactions. A program has been initiated to address these questions and has progressed significantly over the past few years.
However, the NRC staff has affirmed repeatedly on numerous occasions l l (such as the one noted above) its view that, until the generic program is completed and provides the basis for making an orderly i Q decision regarding the possible need for additional systems inter-actionrequirements,4& quat [reasonableassuranceofpublichealth
and safety is provided by compliance with current requirements and procedures. The staff's program for studying the systems interaction issue as outlined above was initiated in May 1978 with the definition of USI A-17, " Systems Interaction in Nuclear Power Plants." The early phase of this program involved development of a candidate systems interaction methodology by Sandia Laboratory, and a limited-scope trial application of that methodology to the Watts Bar I facility. The objective of this effort was to attempt to evaluate both the methodology developed and (by comparison) the adequacy of existing Standard Review Plan procedures for uncovering potential systems interactions. This Phase I analysis was perfonned by fault trees to identify component failure combinations (cut-sets). The total number of possible independent failure combinations that could have been analyzed was reduced by introducing six linking features into the analysis. This effort identified a few potentially adverse interactions within the limited scope of the study. The staff reviewed the interactions identified for safety significance and generic implications. The staff concluded that no corrective measures were needed immediately at Watts Bar I, except with regard O to the potential for interaction between the Power Operated Relief Valve and its associated block valve. This interaction had been separately identified by analyses of the TMI-2 accident and
l corrective measures were already being implemented. This initial A-17 effort was deemed unsuccessful. O In May 1980, in the aftermath of the TMI-2 accident, the TMI-2 Action Plan (NUREG-0660) was approved by the Coninission. Item II.C.3 of the Action Plan (Systems Interaction) incorporated the USI A-17 effort and broadened the systems interaction program. Special limited-scope (spatially coupled, seismic initiator) system interaction analyses were perfonned at Diablo Canyon Units 1 and 2 and at San Onofre Unit 2. The basic method used in both analyses was in-situ visual examination of plant systems for potential failures of " sources" (i.e., non-seismic Categorjiy I piping / equipment) that could adversely affect the functioning of A V safety-related " targets". The staff and ACRS accepted both analyses even though the results differed significantly in terms of the number of potentially adverse systems interactions discovered. The differences in results obtained were explainable in view of differences in design criteria applied at the two facilities. The l San Onofre unit design criteria required both non-safety and safety-related systems to be mounted with Seismic I qualified mountings. This design criteria had not been applied at Diablo Canyon. l O In January 1981, a staff assessment (based on surveys by three l U , national laboratories under contract to the staff) of then available l methodologies led to the conclusion that application of any single
method could not identify all potentially important systems interactions. Therefore, the staff undertook a program to further develop available methods (or combinations of available methods) and to incorporate them into what has been termed " Interim Guidance" that could be used by licensees / applicants for a comprehensive, systematic systems interaction evaluation of specific facilities. The Interim Guidance was intended to describe an acceptable general approach to a comprehensive systems interaction a sis effort, and to provide at least two distinct alternative detailed step-by-step illustrative procedures for accomplishing that objective. The documentation of one illustrative procedure (characterized as a Fault Tree / Interactive FMEA methodolgy) is essentially complete and ready for trial application at this point. Documentation of the O second iiiustretive precedure (ceiied the Metrix-besed Diegreph Method) is scheduled to be completed by August 1982. The Interim Guidance is based upon experience gained during the Watts Bar limited-scope analysis, the Diablo Canyon and San Onofre seismic-initiator systems interaction reviews, the surveys conducted by the national laboratories, and review of the Indian Point-3 program plan (described further below). 1 Another major element in the expanded systems interaction program l included under Action Plan Item II.C.3 is the broad-scope systems interaction evaluation of the Indian Point-3 facility by the Power Authority of the State of New York (PASNY), employing a methodology developed by themselves. PASNY submitted a preliminary plan for I
this systems interaction study in March 1981, and staff review was compieted six months later. PASNY's final program plan, {} incorporating staff's review comments, was received in January 1982 and has been approved / endorsed for performance at IP-3 by both the staff and the ACRS. The actual study effort got underway in April 1982 and is progressing satisfactorily at this time. It is estimated that approximately one year will be required to complete this study. One remaining major element in the staff's system interaction program plan under Action Plan Item II.C.3, which has not yet been approved or initiated by the NRC staff, is the so-called " Pilot Program" effort. As initially conceived, the Interim Guidance O
- V described in the proceeding was to be applied on a trial basis in several plants undergoing operating license review, and results from I
both the pilot plant analyses and the IP-3 study were to bra evaluated in reaching a final decision regarding the need for additional requirements to perform expanded scope system interaction l l analyses on some or all LWRs. i The staff has also given consideration to the option of requiring ! that systems interaction analyses be performed on the first group of NREP/SEP Phase III / plants using the PASNY methodology as the basis, i
*] The Systematic Evaluation Program (SEP) is an ongoing program involving a deterministic review of operating plants to assess the i adequacy of the design and operation of existing reactors, to l
l (footnote continued on followinj page) l
after the staff has reviewed initial phases of the IP-3 study and identified any needed modifications. Subsequent NREP/SEP plants could perform systems interaction analyses using methodology that incorporates further improvements on the later pilot studies. Thus, the refinement of methodology, and the decision to proceed with each additional step, would depend on what had been learned to date. This option is consistent with the view that performance of systems interaction dependency analyses in combination with current PRAs will better assure that PRA results will provide adequate insight regarding the possible need for improvements in safety and reliability. Therefore, as stated in the SER for Shoreham " . . . studies to date indicate that current review procedures and criteria supplemented by
- the application of post-TMI findings and risk studies provide reasonable assurance that the effects of potential systems interaction on plant safety will be within the effects on p '.
l (Footnote continued from previous page) compare them with current safety criteria, and to provide the basis for integrated and balanced backfit decisions, if required. The program was initiated in 1977; Phase II of the program is now in progress. Phase III (SEP III) is scheduled to begin in FY 1983 for completion in FY-1989. The National Reliability Evaluation Program (NREP) is a program proposed to assess design and operational deficiencies of all l commercial operating power reactors employing probabilistic risk
- assessment (PRA) techniques. The staff will recommend that this ,
program begin by the end of FY 1982. The staff is seeking l Commission approval to coordinate NREP with SEP Phase III and require SEP III licensees to do PRA under NREP. l l
safety previously evaluated." (SER at B-11). And as reaffirmed recently in the Dircks letter dated February 12, 1982 (referred to O above), the staff " continues in the confidence that current regulatory requirements and procedures provide an adequate degree of public health and safety." Q.40 What is the technical concern in Unresolved Safety Issue A-47,
" Safety Implications of Control Systems"?
A.40 This issue is discussed in Appendix B of the Shoreham Safety Evaluation Report (NUREG-0420) and will be discussed again here. The issue concerns the potential for transients or " accidents" being made more severe as a result of control system failures or O malfunctions. Failures or malfunctions may occur independently or as a result of an accident or transient. One concern is the potential for a single failure such as a loss of a power supply, sensor impulse line failure, or sensor failure to cause simultaneous malfunction of several control features. Such an occurrence could conceivably result in a transient more severe than those, transients analyzed as " anticipated operational occurences". A second concern is for a postulated accident to cause control system failures which would make the accident more severe than presently analyzed. Accidents could conceivably cause control system failures by O creatia9 e hersa eaviroa eat 4a the eree of the coatroi en#inmeat or . by physically damaging the control equipment. In accordance with Standard Review Plan Chapter 7, NRC staff reviews
have been performed on currently licensed plants as well as on Shoreham with the goal of assuring that control system failures will O not prevent eut-etic or -nuei initiation end operation of any safety system equipment required to trip the plant or maintain the plant in a safe shutdown condition following any " anticipated operational occurrence" or " accident". The approach has been either to provide independence between safety-related and non-safety related systems or to require isolating devices such as isolation amplifiers between safety-related and non-safety related systems such that failures of non-safety related equipment cannot propagate through the isolating devices to impair operation of safety related equipment. In addition, a specific set of " anticipated operational occurrences" and " accidents" has been conservatively analyzed to demonstrate that plant trip and/or safety system equipment actuation occurs with sufficient capability and on a time scale such that the consequences are within specified acceptable limits. The analyses are intended to be sufficiently conservative to verify that the potential consequences to the health and safety of the public are within acceptable limits for a wide range of postulated events even though specific actual events might not follow the same assumptions made in the analyses. In general, until approximately one year ago systematic evaluation O of contrei systems designs hed eet been performed to determine . whether single event induced multiple control system actions could result in a transient such that core limits established for
" anticipated operational occurrences" are exceeded. Single failures
or events which could induce multiple control system actions would presumably include events such as a loss of power supply or failure Q of a sensor impulse line. If single failure or event induced multiple control system actions do indeed exist, experience with operating plants indicates that incidents resulting in transients more severe than currently analyzed as " anticipated operational occurrences" have a low probability. Until approximately two and one half years ago systematic evaluations of control system designs had not been performed to determine whether postulated accidents could 'cause control system failures resulting in control actions which would make accident consequences more severe than presently analyzed. Licensees ' lave, however, now reviewed the possibility of consequential control system failures which exacerbate the effects of some high energy line breaks and taken action where needed, to assure that the postulated events would be adequately mitigated. The resolution of Unresolved Safety Issue A-47 will systematically determine if current licensing practices with respect to control systems are adequate. Should the resolution of A-47 indicate that additional criteria for control system designs are necessary or that specific problems require resolution, appropriate action will be taken for plants in the licensing process as well as for plants now
] in operation. At this time, the staff knows of no specific control l
system failures or actions on Shoreham or any other plant which would lead to undue risk to the health and safety of the public. O Q.41 What will be done specifically for the Shoreham plant to demonstrate that the consequences of control system failures do not represent an undue risk to the health and safety of the public? A.41 The staff has requested (see Section 7.7 of the Shoreham Safety Evaluation Report) that the applicant identify any power sources, sensors, or sensor impulse lines which provide power or signals to two or more control systems and demonstrate that failures of these power sources, sensors, or sensor impulse lines will not result in consequences more severe than those bounded by the analyses of O " anticipated operational occurrences" in Chapter 15 of the FSAR. In addition, the staff has requested that the applicant perform a review to demonstrate that the harsh environments associated with high energy line breaks will not cause control system malfunctions resulting in consequences more severe than those of the Chapter 15 accident analyses. Upon completion of these efforts by the applicant to the satisfaction of the staff, the staff will be able to conclude, with reasonable assurance, that control system failures do not represent an undue risk to the health and safety of the public. The Applicant will, however, be required to address any Q additional staff guidance which may result from the resolution of Unresolved Safety Issues A-47 and A-17.
- , -. --- . e r - -- m
X. CONCLUSION Q.42 What conclusion does the staff draw with respect to the adequacy of the safety classification and analysis of structures, systems, and components at the Shoreham plant for identifying the items to which General Design Criteria 1, 2, 3, 4, 10, 13, 21, 22, 23, 24, 29, 35 and 37 apply? A.42 The safety classification of structures, systems, and components at the Shoreham plant, and the measures taken to assure the reliability of structures, systems, and components important to safety are in compliance with current Commission regulations and with the staff practice which has evolved since the inception of concercial nuclear power. Those structures, systems, and components that provide reasonable assurance that Shoreham can be operated without undue risk to the health and safety of the public have been adequately addressed in this regard by the applicant and by the staff through the design and review process. O .
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UNITED STATES 8 g([%j t NUCLEAR REGULATORY COMMISSION W ASHINGTON. D. C. 20555 h )*!
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'" ) MEMORANDUM FOR: Paul Shevnon, Chairman Advisory Committee on Reactor Safeguards FROM: William J. Dircks Executive Director for Operations
SUBJECT:
SYSTEMS INTERACTIONS In the January 8,1982 memorandum from J. J. Ray to me on this subject, the Acting Chairman stated the Committee's desire to hear from the staff concerning the 4 4 systems interaction program at Indian Point-3, and the staff's plans for systems interaction reviews at all plants. As noted, a meeting with the cognizant ACRS subcommittee, originally scheduled for January 5,1982, to discuss these matters was postponed because of a delay in the submittal by the licensee describing the Indian Point-3 systems interaction program. That submittal has now been received by NRC; and the subcommittee meeting has been rescheduled for February 26, 1982. Our suggestions for topics to be discussed at that meeting are provided in an enclosure to this memorandum. p The staff's licensing reviews already deal with some aspects of systems interaction. Q Applications for Cps and OLs are evaluated against the Standard Review Plan which requires interdisciplinary reviews of safety-grade equipment and addresses several different types of potential systems interactions. Two specific sections of the SRP (Sections 3.6 and 7.4) extend the reviews to include the adverse effect of nonsafety equipment, i.e., high energy lines and associated electrical circuits. The staff's ovaluations of systems interactions occurring from high energy line breaks, jet-impingement, local ficoding, and pipe whip are summarized in Section 3.6 of the SERs. The staff's evaluation of the environmental qualification of equipment is covered in Section 3.11 of the SERs. The evaluations of systems interaction due to masonry walls (IE Bulletin 80-11) are addressed in Section 3.12 of the SER. The staff's evaluations of potential interactions between reactor protection and control systems are addressed in Sections 7.2 and 7.4. (This includes the staff's evaluations of the applicant's response to IE Bulletin 79-27 and IE Notice 79-22). The staff's evaluations of j interactions between fire protection systems and safety-grade systems are addressed in Section 9.5. Also, the quality assurance program which is followed during the design, construction, and operational phases for each plant can contribute to the prevention of introducing adverse systems interactions. NRR continues in the confidence that current regulatory requirements and procedures provide an adequate degree of public health and safety. However, the frequency of pventsthatadverselyaffectsafetysystemsredundancyatLWRsjustifiedtheproposed d RR level of effort directed toward enhanced systems interactions analyses. s~ n -
Paul Shewmon The level of effort currently given to systems interactions was established against the backdrop of many other regulatory programs that compete for limited staff and utility resources. Only the items cited above are routinely reviewed for all applications. No g explicit requirement presently exists for operating plants or applicants to perform a dcomprehensive,systematicsystemsinteractionanalysis. Special, limited systems inter-actions analyses have been performed at Diablo Canyon and San Onofre-3 and have been described to the ACRS. The staff views the forthcoming Indian Point-3 systems interactions review as the most comprehensive, systematic review to date, and also proposes to begin soon with reviews of four NTOL plants using two different methodologies for two plants each. Although the four plants have not yet been selected, the leading candidates are Seabrook, Perry, Midland-2 and San Onofre-3. The first two LWRs would begin next month using a Fault Tree / Inter-active Failure Modes and Effects Analysis method. The other two LWRs would begin by July 1982 using a matrix-based digraph method. This phased program has been underway for more than a year, and is planned eventually to form a part of the NREP/SEP combined review program (ref. H. Denton, NRR, to R. Fraley, ACRS, memorandum, " Seismic-Induced and Other Interactions Between Non-Safety and Safety Systems", dated November 20, 1981). However, the staff recommends expediting the phased approach by requiring that systems interaction analyses be performed on the first group of NREP/SEP Phase III plants using the PASNY methodology. Subsequent NREP/SEP plants would perform systems interactions analyses using methodology that incorporates further improvements based on the conclusions from the pilot studies. An updated schedule showing the interrelatiorihips of these programs is enclosed. O we do not believe it is appropriate at this time to elevate the efforts of all other ap-plicants (much less licensees) by a regulatory requirement to perform a comprehensive systems interaction analysis. The reasons not to elevate the efforts of others at this time are: First, a comprehensive systems interaction evaluation appears to be a resource-intensive undertaking (a crude estimate is $2M) and the benefits of such an undertaking have not yet been measured. The pilot programs should measure the benefit, and refine and reduce the cost. Second, a requirement now would preempt the future possibility of a conclusion that the benefits do not justify the cost. Third, no acceptance criteria or guidelines have been established to judge the adequacy of such an effort. The pilot pro-grams are believed to be needed for this purpose, also. Finally, development of a methodology for systems interactions analyses has been a complex problem. The analyses include topics outside the present scope of nuclear reactor safety review. The Committee noted by the January 8,1982 memorandum that " current probabilistic risk assessments (PRA) do not usually include a systematic examination of systems interactions l and cannot be counted upon to provide adequate insight regarding possible improvements in safety and reliability." The staff also has stated that PASNY should not rely principally on PRA results in its systems interaction study (paragraph I.B of memorandum Conran to Thadani, " Meeting Summary and Status Report," 10/20/81, enclosed.) The staff believes that the systems interactions methodology can be usefully integrated with the scope of present-day PRAs, and the . strengths of these two efforts offer opportunities for en-hancing safety and effective utilization of both staff and utility resources. l
A Paul Shewmon - 3-The nonsafety-grade / safety-grade dependency information discovered by a systems inter-
- tion analysis is important for the accuracy of PRA results. PRA is a framework for
(^issessing s the safety implications of systems interactions. We look forward to the February 26, 1982, meeting and welcome your comments on the sug-9ested topics. [ . N William J. Dircks Executive Director for Operations
Enclosures:
- 1. Conran memo dated 10/20/81
- 2. Suggested topics
- 3. Updated schedule O
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1 ENCLOSURE 1
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UNITED STATES [)
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(_ v ,/ OCT 20 1981 Docket Nos. : 50-247 MEMORANDUM T0: Ashok Thadant, Chief Af n 50-286 Reliability and Risk Assessment Branch Division of Safety Technology, NRR THRU: Franklin D. Coffman, Jr., Section Chief Systems Interaction Section Reliability and Risk Assessment Branch Division of Safety Technology, NRR FROM: James H. Conran, Principal Systems Engineer Systems Interaction Section Reliability and Risk Assessment Branch Division of Safety Technology, NRR
SUBJECT:
TRANSMITTAL OF MEETING SUMf!ARY AND STATUS REPORT Attached is a combined " Meeting Summary and Status Report" relating to the Indian Point-3 systems interaction study effort. This report is principally a summary of discussions of a July 24, 1 981 meeting between the Systems
. Interaction staff and the Indian Point-3 licensee (PASNY) and their con-tractor (EBASCO). The purpose of that meeting was to discuss the staff's final review comments on PASNY's preliminary submittal describing the pro-posed IP-3 systems interaction study program. The report is in the format g/
t, of a " Meeting Summary"; however, since the report also reflects developments subsequent to the meeting (e.g. as recent as the simulator trials at the Indian Point facility on September 23-24), it is also termed " Status Report". Jam.es H. Conran Systems Interaction Section Reliability and Risk Assessment Branch Division of Safety Technology, NRR Attachments - Report as stated in text ' cc: T. Murley - DST M. Ernst - DST J. Thoma - DL J. Greismeyer - ACRS staff V e
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MEETING NOTICE DISTRIBUTION Docket-File' J. Stolz NRC PDR S. Hanauer
' Local PDR P. Collins TIC D. Vassallo NSIC D. Ziemann TERA T. Murley Branch File ! O E. Case F. Schroeder K. Kniel D. Eisenhut -
D. Skovholt R. Purple G. Knighton
; T. Novak M. Ernst , S. Varga W. Minners T. Ippolito E. Adensam R. A. Clark A. Thadani N. Hughes ACRS (16)
R. Tedesco Attorney, DELD
, J. Youngblood OIE (3)
A. Schwencer OSD (7) F. Miraglia Licensing Assistant K. Parrish J. R. Miller J. LeDoux. I&E G. Lainas I&E Headquarters D. Crutchfield I&E Region I W. Russell I&E Region II J. 01 shinki I&E Region III R. Vollmer I&E Region IV R. Bosnak I&E. Region V F O a.. c. Schauer G. Lear Jeckson naC vert 4cioents: L. Ol shan W. Johnston J. O. Thoma i
- 5. Pavilicki ~~
V. Benaroya C T.'~Cof
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Z. Rosztoczy J. Conran W. Haass D. Muller Licensee Participants R. Ballard J. Lamberski - PASNY W. Regan Y. Kishinevsky - PASNY V. Moore R. Mattson P. Check F. Congel
- 0. Parr F. Rosa W. Butler i W. Kreger R. W. Houston -
, .W. Gammill l Q L. T. Rubenstein Speis M. Srinivasan B. Grimes S. Schartz F. Pagano S. Ramos J. Kramer i
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MEETING SUMf1ARY AND STATUS REPORT FOR MEETING WITH PASNY/EBASCO ON PROPOSED IP-3 SYSTEMS INTEP. ACTION PROGRAM JULY 24,1981 Introduction and Background A meeting was held in Bethesda, Md., on July 24, 1981 with representatives of the Power Authority of the State of New York (PASNY) and their contractor (EBASCO) to discuss the staff's comments on PASNY's " Preliminary" submittal on the proposed systems interaction study program to be performed at the Indian Point-3 facility. The " Preliminary" submittal (2 volumes) consisted of: Volume I - description of the objectives and scope of the program, project organization, and criteria and methodology to be applied in identifying and evaluating systems interaction. ' Volume II - extensive compilation of results of application of the proposed criteria and methodology to the AFW system, for the purpose of illustrating the workability of the proposed methodology and the depth of treatment of plant systems generally in the study. The review of the PASNY submittal was performed by the NRC systems interaction staff (Reliability and Risk Assessment Branch) assisted by contractors (LLL and SAI) and a senior reviewer from the Auxiliary Systems Branch, NRR, experienced in the review of AFV systems. The review process in its entirety extended over 7 nearly 4 months (April-July), and included review of a number of sections of the (d Pickard, Lowe, and Garrick Zion / Indian Point PRA study report (April 1981 Draft) now in the final stages of completion. (Explicit reference is made to "consid-eration of Z/IP PRA fault trees" in the description of the IP-3 proposed systems interaction study.) The scope of the RRAB (and LLL/SAI) review effort included all aspects of the PASNY submittal; but the main focus of this part of the review was a critical review of proposed criteria and methodolagy. The Auxiliary Systems Branch re-viewer concentrated primarily on Vol . II of the PASNY submittal (i.e., results of application of proposed methodology to the AFW system only) from the per-spective of one knowledgeable in the details of specific system design and operation (see Enclosure 6). All questions and comments developed by this ex-tensive review process were discussed preliminarily with PASNY/EBASCO project personnel via conference calls arranged periodically during the review process. The Detailed Agenda for the July 24 meeting (see Enclosure 2) reflects the final staff comments on the " Preliminary" PASNY submittal. Discussion The following summary of detailed discussions at the July 24 meeting is keyed to (qy specific items on the Detailed Agenda for the meeting (Enclosure 2). I.A. _NRC Philosophy on SI Analysis J. Conran presented an overview of current RRAB staff thinking on the systems interaction problem in general to properly frame the staff's comments on PASNY's proposed SI program. Enclosure 3 provided the
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outline for his presentation which summarized the ways that the NRR SI staff has " cross-cut" the overall SI topic, as its thinking has developed and evolved over the past 1 year. That presentation and subsequent discussion throughout the meeting developed the following important points: o Systems interaction analysis involves (1) the systematic search for heretofore " hidden" or-inadequately analyzed interconnections or O- couplings that link safety and non-safety systems in the reactor plant, and (2) the evaluation of the effects of non-safety system failure (or maloperation) propagated into the safety system by such interconnections / couplings. o The SI staff stated that the treatment of sis that agg' ravate acci-dent conditions and exceed the capabilities of installed safety systems (in addition to SI's that degrade safety system capability) is considered to be within the scope of a comprehensive SI analysis. And methods are available for treating a number of types of SI's, as outlined in Enclosure 3. The SI staff acknowledged, however, that methods are not now available for treating comprehensively the so-called " higher-order" type SI's in interconnected systems. The cap-ability does now exist for treating thoroughly specific events (or postulated events) involving higher-order SI's (e.g., as was done in the extensive analyses of the TMI-2 accident, the Crystal River loss-of-coolant event, the Brown's Ferry partial scram failure, etc.). But the SI staff believes that improved simulator / engineering analyzer capability must be developed.if " higher-order" type.SI's can be treated systematically and comprehensively in future SI studies. - o The staff emphasized that consideration cf operating experience is an inportant element in the systems interactier. analysis of a facility and should be treated explicitly in the IP-3 SI study. Extrapolation of events that have actually occurred is, of course, an effective and accepted method for identifying additional potential SI's with nexus to what has already actually occurred. Consideration of operating experience can also be useful in another important way. The suit-ability / workability of a proposed SI analysis methodology can be demonstrated if it can be shown that application of that methodology will identify and lead to correction of adverse systems interactions similar to those that have occurred in the past.. o With regard to the question of suitability / workability of various analytical methods for SI analysis purposes, the SI staff does not feel that Event Tree /tault iree metnoas nave yet been satisfactorily demonstrated in the limited applications attempted to date (e.g. Sandia Phase I A-17 effort; or Battelle/BNL/LLL_ State-of-the Art surveys).* PASNY has proposed use of " dependency analysis" techniques (e.g., combining shutdown logic diagrams, safety systema ' uxiliary O diesrems. eoxiiiers sefets sistem commoneiits diescems. dependency
*Battelle, BNL, and LLL have continued efforts to, adapt , Event Tree / Fault Tree methodology for SI analysis purposes. Their efforts are reflected in Interim Guidance being developed; and Event Tree / Fault Tree methodology will be one pro-posed SI analysis technique tested in " pilot" reviews planned in the near future.
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tables / matrices Ft1EAs) as the primary means for identifying SI's in the IP-3 study. PASNY has proposed also the use or " consideration" of individual system Fault Trees (available from the IP-3-PRA study) as a supplemental means of identifying and evaluating SI's. This is acceptable to the staff; but PASNY should emphasize and concentrate efforts on application of " dependency analysis" methods in the actual performance of the IP-3 study. I.B. Relationship Between PRA and SI P. Alesso, LLL, presented an overview on the relationship between PRA and SI analysis, based on his background and experience in applying PRA techniques, and on perspectives gained from the RRAB/LLL/SAI review of both the PASNY SI submittal and Draft sections of the Z/IP-3 PRA report (provided separately by PASNY at RRAB's request to facilitate - the SI submittal review). His presentation (see outline in Enclosure 4), and subsequent discussions throughout the meeting developed the following main points: o Early PRA studies focused largely on safety systems, and (because of assumed independence between ncnsafety and safety systems) did not treat nonsafety system-related effects to any great extent. This approach seemed valid in view of stringent criteria applied in the design and licensing review process (i.e., single failure criterion, separation criteria, etc.) for the express purpose of achieving and maintaining nonsafety/ safety independence. Also, consideration O was given in e rly PRA efforts to comon-mode failure mechanisms and effects; but, again, the emphasis was on couplings (and their effects) between safety systems (not between safety and nonsafety sys t ems ) . In this sense, some consider SI studies as merely an extension of the toc-restrictive boundary concitions imposed in early PRA studies to encompass full treatment of comon cause/corrnon mode effects involving both nonsafety and safety systems. Consistent with this view, recent " enhanced" reliability and risk analyses (e.g. , IREP and the Z/IP-3 PRA) d_o, include significantly improved treatment of nonsafety front line and support systems. o The SI staff does not agree with characterization of SI analysis as "just a part of an enhanced PRA" for the following reasons: (1 ) SI analysis is a useful exercise and has inherent value completely aside and apart from PRA.The nonsafety/ safety dependency information developed by SI analyses is certainly important in assuring the accuracy of PRA results (in fact SI analysis must be regarded. logically as a prerequisite to PRA). But nonsafety/ safety dependency information can be used readily and effectiyely to improve safety in the context of the current " deterministic" licensing approach even if PRA is never done. (2) Thinking of SI analysis as " simply a part of PRA" can lead to undue empahsis or reliance on use of analysis methods usually associated with PRA (i.e., Event Tree / Fault Tree Analysis), that have not yet been satisfactorily derdonstrated (for SI analysis purposes) in appitcations attempted to date.*
*See footnote preceding page.
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4 o As a final point in the area of PRA/SI relationship, PASNY stated that the results of the IP-3 PRA study would be an important factor in the final selection of specific systems to be treated in the IP-3 SI analysis. The SI staff stated that PASNY should not rely pri-pb marily on those PRA results in making such determinations regarding th critical parameters of the SI study. If the PRA is flawed by not taking into account some hidden dependency in the IP-3 systems that could be found by a SI analysis, there is a logical inconsis-tency in using the results of such a potentially flawed PRA (in any controlling manner) in determining scope or depth of treatment of the SI analysis. PRA results may be useful in confirming the selection of systems (for SI' analysis) arrived at by applying the methods and criteria described by PASNY in their Preliminary submittal II.A Definition of SI and Application of Single Failure Criterion o PASNY and the SI staff agreed explicitly that the threshold for identification of adverse SI's will be a nonsafety system or component failure that leads to the defeat of one train of a safety system or engineered safety feature... even if the 're-maining trains of the affected safety system or ESF could per-form the intended safety function. This is a more stringent criterion than the Single Failure Criterion currently applief pb in the licensing review process; but it was emphasized that it - is specified by the staff at this point only as a SI search criterion. SI's identified by applying this search criterion may require design change or plar.t modificatior.; but not necessarily so. o The choice of the stringent search criterion discussed in the preceding stems from the SI staff's objective of assessing the effectiveness of existing deterninistic criteria in achieving independence between safety and nonsafety systems. The assump-tion of nonsafety/ safety systems independence (in accordance with existing design and licensing review criteria) forms an important part of the rationale for determinations of " adequate safety" for existing plants sans systematic and ' comprehensive
. analysis of nonsafety failure ef fects. If numerous nonsafety/
safety system dependencies are found by application of the search criterion specified above, that could indicate a funda-mentally different level of reliability in safety systems than is now assumed, and could (for example) indicate the need for reassessment of the adequacy of the Single Failure Criterion p as currently applied. G
4 II.B Interconr.ected Systens Interaction Analysis o PASNY amplified in discussions at this meeting their description in the Preliminary submittal of how Shutdown Logic Diagrams (SLD's) Safety System Auxiliary Diagrams (SSAD's), and Auxiliary Safety System o Commonality Diagrams (ASSCD's) will fit together with FMEAs and Fault V Trees on individual systems, to identify and evaluate SI's (depen-dencies) in the IP-3 study. As the staff now understands iti SLD's, SSAD's, and AS3CD's are basically devices employed (1) for identify-ing the safety and support systems (including nonsafety systems) that are to be analyzed for interactions, and (2) for correlating and combining the results of FMEA's on individual systems in order to understand and portray,how interconnections, couplings and de-pendencies among all systems can propogate nonsafety system failure (s) into the safety system. (PASNY also agreed to consider the use of matrix based methods, as suggested by the SI staff, as a refinement on the above mentioned methods in identifying dependencies among interconnected systems.) In. addition, as a supplemental device in searching for sis, and as one of the principle methods for the evaluation of SI's identified, PASNY will use or " consider" Fault Trees on individual systems already available. from the Z/IP-3 PPA. PASNY may develop new Fault Trees for systems covered in the S? analysis, if these systems were not covered or were not modeled in sufficie::t detail (for SI purposes) in the PRA. All SI's pd identified are not expectad to require use of Fault Trees for evaluation; engineering judgment, liased on and appropriately reflecting existing determinis tic triteria, will be used in some cases, o A. staff concern regarding the effectiveness of PASNY's proposed method for generating system / component listings corresponding to required safety functions was resolved by PASNY's statement that Table 6.1 presented in Vol.1 of the " Preliminary" s' ubmittal was not intended i to be complete -in that respect (e.g., it did not include the PORV) l explicitly at the tir,e, but would do so in the final submittal). At this point the table was intended for illustrative purposes only. 1 o PASNY's amplifying comments referred to in the preceding also answered specifically a staff concern regarding adequacy of the FMEA approach to be applied to all systems generally on the basis of conclusions drawn from the FMEA of the AFW system alone (see Fig. A-2.1 in Vol. II). Specifically the staff questioned the validity of " Acceptable" conclusions N for various failure modes postulated in the AFW system, without considering ! (d possible combined effects of failures in other systems (e.g., due to failure of support systems shared by the AFW and other systems, or other coupling mechanisms).
a , . . o An important area of disagreement between the SI staff and PASNY all along has been the question of treatment of nonsafety control. system failure effects, nonsafety power system failure efft cts, and nonsafety instrumentation failure effects. These types of .C 's have played major p roles in a number of very serious operating incidents, and are of great concern and are considered high priority aspects of the overall SI h problem by the staff; but PASNY indicated in the Preliminary submittal that they intended to address these types of sis only very limitedly or not at all in the IP-3 study. , _ _ _ _ _ _ _ _ _ _ With regard to the treatment of SI's involving nonsafety instru-mentation failure effects. PASNY stated in their " Preliminary" submittal that they did not intend to treat latent-or-dynamic human error-induced failures within the scope of their SI analysis. Consistent with this position, they specifically excluded treatment of "... failures which deprive the operator of required information for normally controlling plant conditions, or which provide confusing or incorrect information to the operator..." A part of PASNY's rationale in this respect was that it was simply too difficult to predict and anal.yze the many ways in which an operator might act incorrectly. The SI staff bell'eies that it is, p_o.ssible to treat,one specific irJportant type of interaction involving the human error as a coupling or linking mechanism. That type of SI has been termed " induced operator error" (see Enclosure 3), and involves a set of circumstances in which (1) - O e noasefety system feiiure causes loss (Perticuierly messive 1oss) of normal control instrumentation display, and (2) the operator is assumed to act correctly (procedurally speaking) on the basis of incorrect reading (s) produced by the initiating failure. Thus, the difficulty of trying to predict and analyze . incorrect actions is eliminated. PASNY appeared to understand and appreciate the staff's comment in this regard (provided in the initial meeting on 4/2/81), but has not yet explicitly committed to including treatment of this type SI within their intended scope of study. The SI staff continues to believe that the ser.iousness and likelihood of this kind of failure are both such as to warrant its treatment in' the IP-3 SI study.
-- With regard to nonsafety control systems failure effects, PASNY merely referenced in their Preliminary submittal the PASNY response to IEB 79-22. This was somewhat confusing in that context because IEB 79-22 addressed control system failurel only in the context of non-connected SI effects (specifically, high energy line break O_ effects) eiso P^s"v's resPoase focused oa oair e rew coatroi systems. Further, there was no indication in the Preliminary ,
submittal that PASNY intended to consider adequately nonsafety power system failure effects caused by or propagated by nonsafety control systems, The staff therefore considered this aspect of PASNYts Prelininary submittal inadequate.
, ,, .s Subsequently, PASNY added reference to their responses to IEB 79-27 and NUREG-0588 as applicable and sufficient in this context, PASNY considers anything much beyond that to fall within the scope of.one or another Unresolved Safety Issue (e.g. A-47 Control Systems Dynamics),
not assignable by requirement to an individual licensee for resoluiton. O- The staff understands PA"NY's legalistic position in this regard, but has required that at a minimum PASNY's treatment of SI's in in.terconnected systems should consider explicitly nonsafety control system failure effects and nonsafety power system failure effects to a degree con-sistent with requirements imposed by current staff practice for detailed information regarding nonsafety system aspects of plant
- design, e.g., recent ICSB review questions to OL applicants in the SNUPPs project. (A copy of the ICSB review questions referred to have been provided to PASNY.)
Beyond this minimum requirement, the staff has requested that PASNY consider possible application of the Indian Point simulator in the treatment of "first-order" types of SI's (see Enclosure 3) involving nonsafety control and power systems. The SI staff believes that to the extent that such a training simulatoi accurately models at lea ~st ~ direct interconnections between safety and nonsafety front line systems and their support systems it may be possible to do more comprehensive and systematic analysis of their failure effects more easily and efficiently by use of the simulator. (It would not be necessary for 3ro' cess cou alings or systems dynamics the to be simulator useful intothisregard. accurately)model It s1ould also be noted that a training O simuletor would appear to be ea almost ideei tooi to be ePPlied <a treating more systematically and comprehensively nonsafety instru-mentation display failure effects (i .e., the induced operator error SI) as discussed in the preceding. PASNY has agreed to investigate these possibilities and has examined on a very preliminary basis some _ specific -scenarios and failure combinations of partic.ular interest in this respect.- The SI staff was invited to observe and participate l in initial trials on September 23-24, 1981 at the Indian Point Simulator fa cili ty. We believe that PASNY is to be commended for responding in this fashion, and in demonstrating the willingness to examine novel (potential) alternative approaches to this very difficult aspect of SI analysis. I II.C Non-connected Systems Interaction Analysis o The staff considers the methods and criteria proposed by PASNY for use l in identifying and evaluating seismic-initiateB SI's to be acceptable. The methods and criteria proposed are similar to those which have been
'ps employed previously at the Diablo Canyon facility; but the staff has noted refinements introduced by PASNY in this area that should facilitate the evaluation and utilization of results obtained in the walk-down inspections of IP-3 systems.
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-4 o With regard to treatment of other (non-seismic) types of event-induced SI's, it appears that PASNY essentially proposes to perform" enhanced"
' versions of the kinds of analyses already required under existing licensing requirements in this regard (e.g., Fire Protection Analyses Flooding Protection Analyses, HELB Analyses, etc.). The " enhanced" analyses as pro-h posed would feature increased emphasis on, and mdre comprehensive consider-ation of, nonsafety components in the vicinity of safety system components that could be damaged by failure of the nonsafety components. This proposed effort appears to go considerably beyond what is now required under existing requirements.although it relhs heavily on methods and criteria in existing regulatory guidance. The staff believes that such enhanced treatment of nonseismic event-induced SI's can be safety beneficial; and the methods and criteria proposed by PASNY in this regard appear acceptable to the staff within the scope intended by PASNY. ,
PASNY's proposed approach however, considers onlyfdirect effects of-event-induced nonsafety component failures on the functioning of safety systems, i.e., nonsafety (source)/ safety (target) interactions. The SI staff believes that the IP-3 study should also include some consider-ation of effects of event-induced nonsafety component . failures on important nonsafety systems functioning and the possible resulting impact on safety system functioning, i.e., nonsafety (source)/nonsafety (target) inter-actions and resulting effects on safety systems. PASNY's objections to including treatment of such interactions in the IP-3 study were based on . concerns regarding how to bound such analyses (e.g., would all non-safety (target) systems within an entire compartment have to be consider- - O- ed with regard to effects of an event-induced steam environment). The staff recognizes the validity of such concerns, and for that reason the sub-sequent to the July 24 meeting suggested a rcztentbly-bounded approach to an initial effort in this direction that could be accomplished within the scope of the IP-3 study. As a first step in the suggested approach, PASNY would select (subject to agreement by the staff) a representative high-enerqv nonsafety system. f - The agreed upon (source) system would be walked-down while surveying the vicinity surrounding for (target) nonsafety systems wMcn ..ad already
' been treated in the interconnected SI analysis phase of their study and_
had been shown to have safety significance, i.e., could adversely affect, a If safety function a situation if their is found own in the (non-safety) walk-down functioning)were of the impaired. (source high energy j system in which such (target) nonsafety systems could be damaged by i failure of the high energy (source) nonsafety system, a potentially adverse " coincidence" or systems interaction would have been identified. 1 i . If such potentially adverse " coincidences" were found to occur frequently,'that might indicate a need for extending such analyses I l generically. On the other hand, if no (or very few) such potentially adverse coincidences were identified, that could be taken as additional assurance that the existing licensing basis is adequate without the need for requiring or extending this type of SI analysis. The staff
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believes that this limited additional effort could contribute signi-ficantly toward better definition and understanding, if not complete j resolution, of this unexplored aspect of the overall systems interaction question. i . L
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III.A Safety Classification Terminologies o The staff emphasized that, because SI analysis involves extensively the i treatment of systems ranging widely in degree of importance to safety, O ~ careful use must be made of the safety classification terms which properly reflect such differences. In this context, the SI staff provided to PASNY standard definitions for three most commonly-used safety classification terms (see Enclosure 5). IV Schedule for Completion of IP-3 SI Analysis Progress o PASNY agreed to prepare a Final IP-3 study submittal that incorporates or addresses the staff's review comments; the revised submittal is expected to be available in late-October.
. o ACRS has tentatively scheduled a meeting of the appropriate sub-committee in mid-November to discuss the revised (Final) submittal, o
PASNY estimates that completion of the actual IP-3 SI analysis effort could take 6-12 months after initiation.- () ___ l l l I
List of Attendees Indian Point 3 Systens Interaction Study July 24,1981 L. 01shan NRC J. Kelly SAI - P. Alesso LLNL J. O. Thoma NRC J. Lamberski PASNY W. D. Hamlin PASNY Y. Kishinevsky PASNY K. S. Sunder Raj PASNY Roberto L. Goyette PASNY George Wilverding PASNY S. S. Iyer PASNY Edward J. Bore 11a EBASCO
, . Ralph J. Giorgio EBASCO Michael G. Gagliardi EBASCO F. Coffman NRC E. Che111ah NRC
'J. Conran NRC
() - e O (:) Enclosure 1
, DETAILED MEETING AGENDA Discussion of Indian Point 3 Systems Interaction Analysis July 24, 1981 I.' INTRODUCTION / BACKGROUND A. NRC Philosophy on SI Analysis (NRC)
- 1. Concentrate on safety /nonsafety system dependencies and nonsafety system failure effects
- 2. Consider significant operating experience in scoping SI analysis effort and in demonstrating effectiveness of methodology employed B. Relationship between PRA and SI (NRC)
- 1. Historical perspective (PRA and SI essentially complementary)
- 2. Current efforts (More SI included in PRA)
- 3. Future direction (Comprehensive PRA could include SI)
O II. DISCUSSION OF INITIAL IP-3 SUBMITTAL AND NRC REVIEW COMMENTS A. Definition of SI and Appl: cation of Single Failure Criterion
- 1. Degradation of safety system vs defeat of safety l function (NRC)
- 2. Trea.tment of SI that aggravate accident conditions or exceed safety system capability (NRC)
- 3. Identification of critical safety functions and corresponding plant systems / components (PASNY)
(e.g., how.is PORV treated?) B. Interconnected Systems Interaction Analysis i 1. How do shutdown logic diagrams, safety system i auxiliary diagrams, and auxiliary safety system q comonality diagrams fit together with FMEAs and l' tv PRA event trees / fault trees to identify adverse systems interactions? (Amplify on Vol. I description) (PASNY)
- 2. Treatment of nonsafety control system failure effects, nonsafety power supply effects, and nonsafety instrumentation display failure. effects
- a. 79-22 submittal in' adequate for SI purposes (NRC)
Enclosure 2 ,
-- considers only one type of environmentally induced failure
-- does not consider all nonsafety control systems
-- based on FW HELB analysis where break sizes /
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locations are chosen for direct effects on safety systems
- b. Misinterpretation by PASNY of NUREG-0578 (NRC)
" requirement" for nonsafety system analysis
- c. Possible alternative approaches for treatment in IP-3 SI program
-- investigate use of Indian Point simulator (PASNY)
-- comprehensive dependency analysis (e.g.,
digraph) (NRC)
-- current ICSB review approach, as reflected in SNUPPS questions provided to PASNY C. Nonconnected Systems Interaction Analysis
- 1. Criteria / methodology presented in Vol. I appear O generally very good (NRC)
- 2. Should take credit explicitly for SI analysis already done in fire protection, flooding, HELB analyses, etc. -
(NRC)
- 3. Describe in greater detail how and to-what-extent (PASNY)
SRP/ Reg. Guide guidance used for SI analyses in (2) will be applied in determining effects of fire, flooding, HELB, etc. , on nonsafety control systems, power sources, instrumentation cabling, etc. (which could in turn adversely influence safety functions) III. SAFETY CLASSIFICATION TERMINOLOGIES /IP-3 HEARING ISSUES A. Use definitions developed in NRC TMI-1 Restart Hearing Testimony (NRC) B. Systems Interaction--Major Issue in IP-3 Hearing (PASNY) (]), (What is current hearing schedule?) IV. SCHEDULE FOR COMPLETION OF.IP-3 SI PROGRAM A. Final Submittal /ACRS Meeting, Sept. 1981 - (PASNY/NRC) B. NRC Audit Review / Walk-Through (NRC) C. SER on IP-3 SI Program, March 1982 (NRC)
SYSTEMS INTEPACTIO!! PROGRAM SCOPE COMMON-CAUSE FAILURES TliAT: O -- VIOLATE RCPB INTEGRITY (E.G., PIPE BREAK, RELIEF / ISOLATION VALVE FAILURE, PUMP SEAL FAILURE) DEGRADE OR DEFEAT SAFETY SYSTEMS (SCRAM, ECCS, RHR, & ESF) EXCEED SAFETY SYSTEM CAPABILITIES (E.G., EXTREME OVERPRESSURE, OVERC00 LING EMPHASIS ON NONSAFETY SYSTEM FAILURE EFFECTS PROCESS & SilPPORT SYSTEMS O EQUIPt1E!!T FAILURE & HUMAN ERROR FAILURE TO OPERATE & I!! ADVERTENT OPERATI0il TYPES ,
- N0!!CONilECTED SYSTEMS I!lTERACTTONS (C0UPLIllG IS BY SliARED SPACE OR ENVIRONMENT) l
- IflTERC0f!tlECTED SYSTEMS INTERACTIO!!
A. FIRST-0RDER (CHARACTERIZED BY: DIRECT C0!lNECTI0tlS: "0llE-WAY" DEPE!1DENCE: O NO SYSTEt1 DYNAMICS OR FEEDEACK EFFECTS INVOLVED) B. HIGHER ORDER (CHARACTERIZED BY: PROCESS COUPLING: SYSTEMS DYi!AMICS EFFECTS) IflDUCED HUMAN ERROR (INSTRUMENTATION DISPLAY ERROR: ASSUME PROCEDURALLY CORRECT OPERATOR ACTI0fD Enclosure 3
METHODS
- WALK-THRU OR WALKDOWN O' ANALYTICAL METHODS (EVENT TREE / FAULT TREE, DEPENDEf!CY ANALYSIS, FMEA) -
EVALUATION & EXTRAPOLATION OF OPERATING EXPERIENCE SIMULATION METHODS TRAINING SIMULATORS - (INTERCON!'ECTIONS WELL-MODELED; DYNAMICS POORLY MODELED) ENGINEERING ANALYZER O (INTERCONNECTIONS & DYNAMICS WELL MODELED) BASIC SAFETY FUNCTTONS ABILITY TO ACHIEVE & MAINTAIN ENTIRE CORE SUBCRITICAL ABILITY TO TRANSFER DECAY HEAT TO ULTIMATE HEAT SINK ABILITY TO MAINTAIN RCPB - ABILITY TO PROVIDE ENGINEERED SAFETY FEATURES 1 (
I. PURPOSE OF PRESENTATION O o To PRESENT THE SYSTEMS INTERACTION (SI) PRdBLEM IN TERMS OF PROBABILITY RISK ASSESSMENT (PRA), AND o To STIMULATE DISCUSSION AND ENCOURAGE FEEDBACK FROM INTERESTED GROUPS. - e j.t O . e
- O e
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. Enclosure 4 .
l ._ - . . , _.. __ _ _ . _ _ _ _ . _ . _ _ _ . . . . - _ . , _ . _ - . _ _ _ . _ . . . , . . . - - . -, . . . _ _ _ _ _ _ _ _ _
II. BACKGROUNb . O :
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. O EARLY REACTOR DESIGN WAS DONE WITHOUT FO'RMAL RISK ,
ANALYSIS. O THE NEED TO BALANC THE LIXELIHOOD OF A POSTULATED SCENARIO WITH ITS CONSEQUENCES LED TO . THE . REACTOR SAFETY STUDY (RSS) 1975. . O SUBSEQUENT RISK ANALYSIS WAS PRA. i, i i O . i I ( O ef f l0 . G S I l
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PRA . . O l
; LEVEL 1: EVENT TREES.
e' O RELATES THE SAFETY FUNCTIONS TO S STEMS NECESSARY TO PREVENT A CORE DAMAGE.. SYSTEM A SYSTEM B SUCCESS . - SUCCESS . FAILURE , ,. O FAILUKE o THE RESULTS ARE ACCIDENT SEQUENCES. USUALLY SAFETY SYSTEMS ALONG WITH THE MAIN FEEDWATER SYSTEM. G 8 o O % O s
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PRA . O - LEVEL 2: FAULT TREES:
- THESE WERE USED TO, DETERMINE THE F AILURE PROBABILITY FOR EACH SAFETY SYSTEM WITHIN THE ACCIDENT SEQUENCE BOUNDARY FAILURE OF SAFETY SYSTEM A SYSTEM i
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i i l I i I i El VIOLATES SINGLE FAILURE CRITERIA i h q
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- 'O . souNDARY CoNDITIouS PRA il l' LEVEL 1: EVENT TREES'-
ADDITIONAL / _ ACCIDENT SEQUENCES CONSIDERATIONS-jt . LEVEL 2: FAULT TREES OF SAFETY SYSTEMS i
- 1. SHARED ^ '
- ENVIRONMENTAL CONDITIONS -
- 2. DYNAMIC HUMAN LEVEL 3: ANALYSIS OF DEPENDENCIES i'
ERROR IN NONSAFETY SYSTEMS O . l 1 l i 'I { \ '.
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1 *. i . 1 . PAST LIMITATIONS OF PRA - 1 O. i j o LIMITED BOOLEAN COMPUTATIONAL ABILITY. o LACK OF FAILURE RATE DATA - s . RESULTS . t i
; o SAFETY SYSTEM BOUNDARY CONDITION LIMITS. .
, o APPROXIMATION FOR NONSAFETY SYSTEMS 4
i
,Q P(AA B)2 PCA)
- P(B) .
(OMITS SOME DEPENDENCE FROM EACH ANALYSIS) i ' I a k e e g 1 ( l
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III. THE PROBLEM i . . jO .. ,I HOWEVER, ACCIDENTS SUCH AS TMI, BROWN's FERRY, 'l AND CRYSTAL RIVER HAVE OCCU'RRED, THAT HAD NOT SURFACED l EXPLICITLY IN PRA. t lI O ARE THE MATHEMATICAL METHODS OF PRA I *
,' INADEQUATE? ~
0 ARE THE BOUNDARY CONDITIONS TOO RESTRICTIVE? I7 . O IS A NEW UNIQUE APPROACH NECESSARY? t . e O - h . I i h 9 S 0 . s
=__ .. .._____._ _ __ _ _ _ _ _ _ _ _ _ _ _ . ._ - ._ _ . ..___.,_. ._ __ _ . _ _ . _ _ .. __ _ ____ _ _ _ . __ _
- . .j ,
8 ' l - l o WHY ALL THE DIV5RSITY IN METHODOLOGY't POINTS OF VIEW 4 J ! O PRA STUDIES HAVE NOT FOUND SOME sis BEFORE AND i' THEREFORE MUST BE INADEQUATE. l . i' O sis SHOULD BE EXAMINED IN ISOLATION. k
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, O IDENTIFYING SYSTEMS INTERACTIONS 0 EVALUATING SYSTEMS INTERACTIONS 0' LACK OF FAILURE RATE DATA (IF PRA METHODS USED) ,
i . . O CRITICISMS OF SHORTCOMINGS / LIMITATIONS USING l ENGINEERING JUDGMENT, DETERMINISTIC CRITERIA, HEURISTIC TECHNIQUES ETC. , O t 9 . j -
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O ' O INDEPENDENT MODULES O SUPERCOMPONENTS - WHAT ABOUT METH'0DS OF HANDLING DEPENDENT EVENTS 7 SUCH METHODS ARE METHODS OF SYSTEMS INTERACTIONS. THEY -
'. INCLUDE: - ~
O HEURISTIC TECHNIQUES (HAZARD INDEX) O GRAPHED BASED LOGIC ANALYSIS O ' 0' ENHANCED PRA S O . e (
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O - COMON CAUSE FAILURE (CCF) ANALYSIS OVERVIEW
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, i PROBABILITY MODELS HAVE BEEN DEVELOPED TO EST CAUSE PROBABILITIES FROM DATA PROBABILITY N0DELS ARE BEING APPLIED TO LER AND TO OBTAIN CCF PROBABILITY ESTIMATES O CCF DATA A.RE BEING CLASSIFIED BY SCENARIO VARIA3L IDENTIFY FACTORS CAUSING HIGH CCF PROBABILITIES i,
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SUBJECTIVE ENGINEERING APPROACHES BEING DEVELOPED QUANTIFYCCFPROBABILITIESBYPLANTVARIABLES j -
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IV. ENHANCED PRA O . THERE IS NOTHING FUNDAMENTALLY WRONG WITH THE -
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i ITS BOUNDARY CONDITIONS SHOULD BE EXTENDED WITH . EMPHASIS ON DEPENDENT FAILURES SUCH AS: ! O SHARED ENVIRONMENTAL CONDITIONS 0 NONSAFETY SUPPORT SYSTEMS . O DYNAMIC HUMAN ERROR 9 I~ l l e l C:) 9
WE SEEK . O LEVEL 2: BOUNDARY BOUNDARY l FAULT TREE FAULT TREE 0F SAFETY OF SAFETY . SYSTEM A SYSTEM B l l l l _//// / / // / / / / / / / / / / / / f f / / / / / / / / / / / / / / / / / / / / / / / / / // /// l LEVEL 3: - NoNSAFETY SUPPORT SYSTEM O e O e
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SUMMARY
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O' SYSTEMS INTERACTION ANALYSIS CAN BE AN EXPANSION OF THE BOUNDARY CONDITIONS OF PROBABILITY RISK ASSESSMENT ANALYSIS USING THE SAME TOOLS AS THE PRA, BUT DEVELOPING A MORE DETAILED EMPHASIS' ON DEPENDENT FAILURES. e D O 4 g e S
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i DEFINITION OF TERMS Important to Safety e Definition - From 10 CFR 50 Appendix A (General Design Criteria) - see first paragraph of " Introduction."
"Those structures, systems, and components that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public."
e Encompasses the broad class of plant features, covered (not necessarily explicitly) in the General Design Criteria, that contribute in important way to safe operation and protection of the pLblic in all phases and aspects of facility operation (i.e., normal oepration and transient control as well as accident mitigation). o Includes Safety-Grade (or Safety-Related) as a subset. Sa fe ty-Rela ted e Definition - From 10 CFR 100, Appendix A - see sections III.(c), VI.a.(1), and VI.b.(3).
"Those structure, systems, or components designed to' remain functional for the SSE (also termed ' safety features') necessary to assure required safety O fuactioas,i.e.:
(1) the integrity of the reactor coolant pressure boundary; (2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could. result in potential off-site exposures comparable to the guideline exposures of this part. e Subset of "Important to . Safety" e Regulatory Guide 1.29 provides a LWR-generic, function-oriente_d listing of
" safety-related" structures, systems, and components needed to provide or . perform' required safety functions. Additional information (e.g., NSSS type,
- BOP design A-E, etc.) is needed to generate the complete listing of safety-related SSC's for any specific facility.
Note: The term " safety-related" also appears in 10 CFR 50, Appendix.B Os (Q.A. Program Requirements); however, in that context it is framed in somewhat different language than its definition in 10 CFR 100, Appendix A. That difference in language .between the two appendices has contributed to confusion and misunderstanding regarding the exact
. meaning of " safety-related" and its relationship to "important to sa fety" and " safety-grade." A revision to the language of Appendix B has been proposed to clar.ify this situation and remove any ambiquity in the meaning of these terms.
ENCLOSURE 5 ,
v .
.i
- 2 Sa fety-Gra de i e Term not used explicitly in regulations but widely used/ applied by staff and industry in safety review process.
e Equivalent to " Safety-Related," i.e., both tenns apply to the same subset O of the broad class "Important to Safety." e e O e 9 j r e O e 6 m O - O
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d ASB REVIEW COMMENTS A-3.2 LossUof Air to Speed Controller TDAFW? O Not on Table A-3 or Fig. A-2.1 , A-1.2 Did not consider loss of non-safety grade control systems. Justified by response to IE notice 79-22 via IPN-79-74, Oct.11,1979. A-2.1.1 Acceptance criteria that AFW is delivered within 30 minutes of initial demand - How can this be backed up as the required time for AFW initiation for all accidents - It may take 30 minutes to boii dry but flow may have to be initiated earlier for the AFW system to " catch up" and prevent dryout. Also,is dryout suffic-fent criteria since the accident analyses in Chapter 15 uses other criteria. A-2.2.3 What about toronado protection for the condensate storage tank? , A-2.2.5 Fi g. A-2.1 Sheet 3 of 9 M-6, M Should mention that pumps are protected by O , automatic c~ rip. (Will correct operator action assumption JHC, per PASNY 7/24/81; Should have PAS /RRAB look at Fault Trees and ICSB look at logic diagrams and electrical failures; on surface the electrical failures look OK. General Power / Air failures are evaluated.with respect to individual components and their effect on the system. What about a combinationof these components if one electrical / air failure can affect groups of componentst For instance, a complete loss of A-C power (on & off) wo'uld affect many of the components in Fig. A-2.1. How is the scenario followed in this report? G O e o Enclosure 6 ,
ENCLOSURE 2 SUGGESTED TOPICS: SYSTEMS INTERACTION PROGRAM ACRS MEETING, FEBRUARY 26, 1982 O I. PASNY-(INDIAN POINT 3 OWNER) Description of the IP-3 Program Scope and Magnitude of Program Methodology Criteria Occupational Exposure Estimates for In-Situ Examinations II. NRC STAFF e NRC Systems Interaction Program o Methodology e Indian Point-3 e 4 Pilot Reviews e All Plants ) e SEP/NREP e 01 Reviews e CP:ML Piants O
o , ENCLOSURE 3 UPDATED STATUS OF SYSTEMS INTERACTION PROGRAM !O t MILESTONE STATUS
- Evaluation of Diablo Canyon 10/80 (NUREG-0675, Supp 11)
{ Survey of Methods 1/81 (NUREG/CR-1859,18965 1901) Evaluation of San Onofre 2/3 5/81 (NUREG-0712, Supp 2) Selection of plants for demonstration analyses 2/82 Implementation of Indian Point-3 methodology' - 10/82 on first NREP/SEP Phase III plants Evaluation of Indian Point-3 Study 6/83 Evaluation of selected plants
- 10/83 i
Issue Requirement . A General Guidance Concern- 1/84 j ing Systems Interaction ** Issue Regulatory Guide ' 1/85
- O j
- Includes measures of the benefits of the analyses and refinements to reduce future j Costs. 's
** Includes acceptance criteria within the Guidance and the scope of the requirements for j future NREP/SEP-III plants.
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PROFESSIONAL QUALIFICATIONS THEMIS P. SPEIS REACTOR SAFETY GROUP DIVISION OF SYSTEMS INTEGRATION My name is Themis P. Speis. I am employed by the U.S. Nuclear Regulatory Commission, Washington, D. C. 20555. Since September,1981, I have been the Assistant Director for Reactor Safety in the Division of Systems Integration, Office of Nuclear Reactor Regulation. My responsibilities include the planning l and supervising the programs and activities of the Reactor Safety Branch which include the Containment Systems Branch, the Reactor Systems Branch, and the Instrumentation and Control Systems Branch. These activities pertain to safety evaluation of reactor safety systems matters on proposed and operating reactors. 3 summary of my previous professional positions is provided below: 1975 to Present - Assistant Director for Reactor Safety Branch Chief, Reactor Systems Branch Branch Chief, LMFBR Branch U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C. 1974 - 1975 Senior Reactor Engineer / Acting Branch Chief O LMFBR Branch U.S. Nuclear Regulatory Commission Division of Reactor Licensing Washington, D. C. 1967 - 1974 Reactor Physicist / Reactor Engineer U.S. Atomic Energy Commission Division of Reactor Development and Technology Washington, D. C. 1962 - 1967 Engineer / Senior Engineer Westinghouse Astronuclear Laboratory Westinghouse Electric Corporation Pittsburgh, Pennsylvania 1958 - 1962 Associate Engineer / Engineer Westinghouse Testing Reactor Westinghouse Electric Corporation Pittsburgh, Pennsylvania 1956 - 1958 Associate Engineer O sie -kaox co. Chemical Plants Division , Pittsburgh, Pennsylvania
My duties as Chief of the Reactor Systems Branch involved the management of the Branch activities dealing with the review and evaluation of the design O and performance of reactor thermal-hydraulic systems, reactor coolant systems, emergency core cooling systems and associated auxiliary systems. It also included responsibility for the review, analysis and evaluation of calcula-tional methods developed and utilized by applicants and licensees for the following activities: independent calculations and complex computer coding. Other responsibilities included the analyses and evaluations of the effects of s'evere accidents, including core degradation and melt accidents on present Light Water Reactor (LWR) designs and the effectiveness and impact of proposed severe accident mitigation features on present and future LWRs. A summary of my education is listed below: B.S., Chemical Engineering, University of Pittsburgh,1956 M.S., Mechanical Engineering, University of Pittsburgh,1966 Ph.D., Nuclear Engineering, University of Maryland,1975 I have been an invited lecturer on a number of subjects dealing with nuclear reactor safety at a number of Universities (University of Florida, Massachusetts Institute of Technology, Purdue University, University of Maryland) and most recently (Fall '81) at the International Centre for Heat and Mass Transfer in Yugoslavia. I am the author of over 25 papers on advanced reactor and LWR O safety. l l O .
September 1981 WALTER P. HAASS PROFESSIONAL QUALIFICATIONS CHIEF, QUALITY ASSURANCE BRANCH DIVISION OF ENGINEERING O' OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION My name is Walter P. Haass, I am Chief, Quality Assurance Branch, Division of Engineering in the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). My duties are to direct, supervise, and coordinate the review of nuclear power plant license applications and topical reports to determine com-pliance with the Commission's quality assurance criteria stated in Appendix B to 10 CFR Part 50 for plant design, construction, and operation in order to promote pro-tection of public health and safety. I received a Bachelor of Science degree in Mechanical Engineering from Stevens {) Institute of Technology in 1952. Upon graduation, I joined the Westinghouse Electric Corporation with an ini-tial assignment on the Graduate Student Training Program. As part of this program, I spent one year at the Oak Ridge School of Reactor Technology. My next assignment was at the Atomic Power Division where I was engaged in the thermal-hydraulic as-pects of the design of proposed nuclear power plants. In 1959, I accepted a position at the Martin Marritta Corporation, Nuclear Division. My activities included project engineering work on the mechanical design aspects of the PM-1 and PM-3A portable nucioar power plants at Sundance, Wyoming and McMurdo Sound, respectively; and program management work for several radioiso-topic SNAP programs including SNAP-11 and SNAP-13. O In 1968, I joined the Atomic Energy Comission's regulatory staff (now NRC) as - a licensing program manager (LPM) responsible for overall management of the staff's review of several nuclear power plant applications for construction pennits. I
was also involved in the development of guidance for the review of quality assur-ance program descriptions based on the QA criteria given in Appendix B. In 1972, O, I became the Technical Assistant for Boiling Water Reactors, reporting to the Assis-tant Director for BWRS. In 1974, I was assigned to the position of Special Assis-tant for Standardization with the responsibility for developing the programmatic - requirements for the licensing of standardized nuclear power plants. In June 1978, I was appointed to my present position of Chief, Quality Assur-ance Branch. O O .
- b. m h . A .1 A a L ,a* . o'n . . -ma = _w-- Wo --
- Marvin W. (Wayne) Hodges professional Qualifications Reactor Systems Branch O oivisio" er svste s '#t ar tio" U. S. Nuclear Regulatory Commission I am employed as a Section Leader in Section B of the Reactor Systems Branch, DSI.
I graduated from Auburn University with a Mechanical Engineering Degree in 1965. I received a Master of Science degree in Mechanical Engineering from Auburn University in 1967. In my present work assignment at the NRC, I supervise the work of 7 graduate engineers; my section is responsible for the review of primary and safety O~ systems for BWRs. I have ser.ved as principal reviewer in the area of boiling water reactor systems. I have also participated in the review of analytical models use in the licensing evaluations of boiling water reactors and I have the technical review responsibility for many of the modifications and analyses being implemented on boiling water reactors post the Three Mile Island, Unit-2 accident. As a member of the Bulletin and Orders Task Force which was formed after the TMI-2 accident, I was responsible for the review of the capability of BWR systems to cope with loss of feedwater transient and small break loss-of-coolant accidents. I have also served at the NRC as a reviewer in the Analysis Branch of the NRC in the area of thermal-hydrulic perfonnance of the reactor core. I served as a consultant to the RES representative to the program management group for the BWR Blowdown / Emergency Core Cooling Program.
Prior to joining the NRC staff in March,1974, I was employed by E. I. DuPont {} at the Savannah River Laboratory as a research engineer. At SRL, I conducted hydraulic and heat transfer testing to support operation of the reactors at the Savannah River Plant. I also performed safety limit calculations and participated in the development of analytical models for use in transient analyses at Savannah River. My tenure at SRL was from June 1967 to March 1974. From September 1965 to June 1967, while in graduate school, I taught courses in thermodynamics, statics, mechanical engineering measurements, computer programming and assisted in a course in the history of engineering. During the summer of 1966. I worked at the Savannah River Laboratory doing hydraulic (p testing.
STATEMENT OF PROFESSIONAL QUALIFICATIONS CHARLES E. ROSSI I have been with the U. S. Nuclear Regulatory Commission (NRC) since v October 1980. Since August 1981 I have been a Section Leader in the Instrumentation and Control Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation. I am responsible for supervising the review of nuclear power plant instrumentation and control system designs for compliance with regulatory criteria. From October 1980 to August 1981 I was a Principal Reactor Engineer in the Instrumentation and Control Systems Branch. I performed the operating license review of the Callaway and Wolf Creek instrumentation and control system designs, the review of construction permit applicant responses to Three Mile Island Lessons Learned Items related to instrumentation and control systems, and the review of licensee responses to g recommendations made by Babcock and Hilcox resulting from failure modes and (f effects analyses of the Integrated Control System. I have a Ph.D degree (1969) and M.E degree (1967) in Applied Physics from Harvard University, a M.S degree (1962) in Physics from George Washington University and a B.A degree Magna cum Laude Highest Honors (1958) in Engineering l and Applied Physics from Harvard University. I have a certificate from a six month reactor engineering course given by the Bettis Atomic Power l Laboratory (1960). I was elected to Phi Beta Kappa in 1958 and Sigma Xi in 1962. I from June 1958 to July 1962 I served as a commissioned officer in the United States Navy. I was assigned to Naval Reactors, U. S. Atomic Energy
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Commission, where I reviewed and approved test and operating procedures for submarine nuclear power plant fluid systems and reactor instrumentation and control systems designs for the pressurized water reactor at Shippingport, PA.
Professional Qualifications Charles E. Rossi From September 1966 to November 1977 I held professional and management positions in the Nuclear Energy Systems division of the Westinghouse Electric Corporation. As a manager I supervised the preparation of system functional design requirements for nuclear reactor plant systems which affect plant control, protection, and transient performance. In addition to reactor control and protection systems, these systems included emergency feedwater systems, emergency boration systems, and steam dump systems. For four years l I was the lead engineer responsible for establishing functional requirements for reactor control and protection systems used in the Westinghouse 3 loop nuclear reactor plants and for perfonning transient and accident analyses of these plants for safety analysis reports submitted to the Atomic Energy Commission. l0 l From November 1977 to October 1980 I was Systems and Civilian Applications Program Manager in the Office of Inertial Fusion at the U. S. Department of Energy. In this position, I provided technical and administrative direction for studies of the commercial applications of inertial confinement fusion. I I am a member of the American Nuclear Society and past member of the IEEE Nuclear Power Engineering Committee Standards Subcommittee (SC-6) on Safety Related Systems. I have authored or co-authored over ten technical articles for presentation at conferences or publication in journals. l l
TECHNICAL QUALIFICATIONS INFORMATION JAMES H. CONRAN SYSTEMS INTERACTION BRANCH DIVISION"0F SYSTEMS INTEGRATION Q OFFICE OF NUCLEAR REACTOR REGULATION Education: B. S- in Physics,1963. The Colorado Co11epe, Colorado Sor_ings m_ _ Col _o rado. Post-graduate a,nd Pro'fe'ssional Courses in Physics and _ Solid-State _ Electronic En.gineering; University of Kansas 1962-1963. Professional Courses in Fault-Tree Analysis 1972 and 1980. . . _. Experience: U. S. Nuclear Regulatory Comission/U. S. Atomic Energy Comission Washington, D. C., 1973 to Present
- Principal Systems Engineer, Systems Interaction Branch, Division of Systems Integration, and Reactor and Risk Assessment Branch, Division nf Safety Technology, Office of Nuclear Reactor Regulation.
Responsible for: development of systems interaction analysis methods, . systems integration review methods, and corresponding regulatory guidance; systems integration review of operating license and construction permits; and review of operating experience for~ systems interaction effects. _
- Senior Project Manager on[ special assignment for one year to the Lessons Learned Task Force and follow-on implementation activities.
Responsible for: identification and evaluation of safety concerns arising out of TMI-2 accident, and reconmendatior. of changes to licensing requirements and safety licensing process; liaison with' the Bulletins and Orders Task Force and ACRS on TMI-2 accident review matters, follow-on implementation of Lessons Learned Task Force recommendations to Near-Term Operating License Applications;
development of Near-Term Construction Permit Lessons Learned licensing requirements; and participation in the formulation of the overall NRC TMI-2 Action Plan (NUREG-0660). O - Senior Project Manager, Standardization Branch, Division of Project Management, Office of Nuclear Reactor Regulation. 1 Responsible for management and coordination of safety review of applications for standard design approvals, and development of standardization policy.
- - Senior Nuclear Engineer, Reactor Systems Safety Branch, Division of Engineering Standards, Office of Standards Development.
Involvement in development of quality assurance standards and Regulatory Guides for nuclear material processing facilities, O v protection-of-informants policy studies,and special safeguards-related investigations and hearings.
- Systems Engineer and Senior Safecuards Analyst, Requirements Analysis branch, Division of Safeguards, Office of Nuclear Material l
Safety and Safeguards. Responsible for comprehensive studies of adequacy of safeguards for existing licensed nuclear facilities (including nuclear materials processing facilities and power reactors), I and development of applicable safeguards regulations and other regulatory guidance. , s
- Senior Safeguards Analyst, Special Safeguards Study Project, Office f
( .. of Special Studies. Responsible for: management, coordination, and technical review and evaluation of contractor studies relating' to safeguards issues identified in GESMO (plutonium recycle) proceedings; development of recommendations regarding the Reference '
Safeguards System concept.
- Senior Staff Assistant / Project Engineer, Advisory Comittee for Reactor Safeguards. Senior project leader responsible for:
(] coordinating activities of ACRS project subcomittees, ACRS consultants, Regulatory Staff, and applicants in support of ACRS licensing reviews; preparation of reports for ACRS use identifying areas requiring detailed evaluation or resolution of deficiencies. U. S. Atomic Energy Commission, Albuquerque Operations Office (ALOO),
'1970 - 1973
- Reactor and Criticality Safety Engineer, Reactor and Criticality Safety Branch, Division of Operational Safety. Responsible for:
inspection and evaluation for criticality safety of all the facilities within the ALOO complex (e.g., weapons design and O research laboratories , weapons production plants, weapons test sites) that support the U. S. Nuclear weapons program, and all pertinent , activities therein (e.g., rescarch reactor and critical assembly operation, uranium and plutonium processing, weapons l assembly, packaging and transportation of fissle materials, etc.); - and safety review of reactor and critical assembly instrumentation , control, protection, and electric power systems, including proposed modi fi cations. San Francisco Bay Naval Shipyard, Vallejo, California, 1967 - 1970 0 .- Nuclear Power Engineer. Test Engineering Branch, Nuclear Power . Division. Qualified for Shift Test Engineer position; responsible for preparation of detailed. test procedures and direction of on-board shift testing operations involved in the acceptance testing
l (pre-operational flushing and hydrostatic testing, systems tests, initial criticality and power range testing, and sea trial) of naval nuclear propulsion systems (new construction, refuel and O overheui).
- Electronic Engineer, Refueling Engineering Branch, Nuclear Power Division. Qualified for Assistant Refueling Director position; responsible for direction of dockside and on-board shift refueling operations for naval nuclear propulsion systems (refuel and overhaul)
Western Electric Company, Kansas City Manufacturing Works, Lee's Summit, Missouri, 1960 - 1967
- Product Planning and Design Engineer, Test Planning Engineer, and Test Equipment Design Engineer. Responsible for: planning and i direct engineering support in the production and testing of radio and voi:: frequency telephone carrier systems; design of major production test equipment; and trouble-shooting problems encountered in the production testing and field application of the telephone communications equipment manufactured at the Kansas City Works.
! O . 1 l 4
Robert Kirkwood Professional Qualifications Mechanical Engineering Branch - Division of Engineering Office of Nuclear Reactor Regulation I am a Principal Mechanical. Engineer in the Mechanical Engineering Branch responsible for the review and evaluation for compliance with the Codes and Standards Rule, Section 50.55a of 10 CFR Part 50, pertaining to the codes and standards under which pressure-retaining components of the reactor coolant pressure boundary are designed, fabricated, erected, and tested. Included in this review and evaluation is the classification system pertaining to the codes and standards under which pressure-retaining components of other fluid systems important to safety of a nuclear power plant are designed, fabricated, erected, and tested. I am responsible for the review and evaluation pertaining to the identification of structures, fluid systems and components and other mechanical components that should be designed to withstand the effects of the' Safe Shutdown Earthquake (seismic Category I) and within the scope of a Quality Assurance Program that is in compliance with 10 CFR 50, Appendix B. I graduated from Belfast College of Technology with a B.S. degree in Mechanical Engineering. I am a registered professional engineer in the State of California. From January 1949 to March 1951, I was employed by Monsanto Chemical Company, Montreal, Quebec, Canada. During this period, I was engaged in chemical plant layout and associated design of pressure vessels, storage tanks, piping systems and mechanical equipment. From March 1951 to September 1956. I was employed by Atomic Energy of i Canada Limited, Chalk River, Ontario, Canada. During this period, I was engaged in the design of fuel elements, fuel handling equipment, remote handling equip-ment, experimental loops, pressure vessels and nuclear piping systems. From October 1956.to November 1959, I was employed by General Dynamics /Convair Scientific Research Laboratory, San Diego, California. During this period, I ! was responsible for the design, fabrication and installation of laboratory l equipment. 1 From November 1959 to July 1968 I was employed by Gulf General Atomic, San Diego, California. During this period, I was the engineer in charge of a design group in the High Temperature Gas-Cooled Reactor Division, responsible for nuclear power plant arrangement. designs including detailed piping layouts for the nuclear steam supply system. Other areas of responsibility included O- conceptual and preliminary design of reactor concepts utilizing prestressed concrete reactor vessels, reactor vessel internals, and associated design of - l fuel handling equipment. In August 1968 I started work for the U.S. Atomic Energy Commission as a specialist in the Engineering and Component Branch, Division of Reactor Standards, where I. participated in the development of reactor standards, codes and criteria. In October 1971, I was reassigned to the Mechanical Engineering Branch, Division Ie
ME nuclear of Reactor Standards, In Aprilwhere I participated 1972, I was reassigned tointhe the development Reactor Systems d of AS codes Branch, and standards. Division of Reactor Standards, where I light-water- participated d in ANS s development and C.P. review of the applicability of codes and standard , seismic classification of structures, systems, and components ofI remaine cooled and gas-cooled nuclear power plants. In December.1975, I was reassigned into the U.S. Nuclear Regulatory Commission. In January 1977, to the A/D for Plant Systems with duties similar to the above. d in ANS (v'; I was reassigned to the Auxiliary Systems Branch, where I participated standards development and C.P. and 0.L. review of the applicability od components and standards and seismic classification of structures, systems, anIn of nuclear power plants. Engineering Branch with duties similar to the above. g-
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1-ERRATA SHEET NRC STAFF TESTIMONY ON SC/ SOC CONTENTION 78 AND S0C CONTENTION 19(b) PAGE NATURE OF' CHANGE-1 5(A.4) Within the quotation at bottom Add a closing parenthesis after
" Criteria" in the third line of the quotation.
Add the following after the third line of the quotation: "Those structures, systems and components that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public." . Underscore the word "all" in the seventh line of_the quotation. 8(A.5) Third line of A.5 i O Chanse the werd "str#ctrures to
" structures" l
{ 18(A.17) Bottom line Change the word "qaulity".to " quality" l ( 19(A.17) Seventh line Change "operattom" to " operation" Third line from bottom Change the word "assiciated" to " associated" t 21(A.17) Third and fourth lines from top q Insert "and" between " inventory" and gj " reactivity". Change the phrase "We train operators and write procedures. . . ." l to " Operators are trained and procedures written . . . ."
28(A.29) Within Section (2) Change "115" to "118" 30(A.33) Third line of the first paragraph of A.33 Change "18" to "16" 31(A.35) Third line of A.35
- Delete " impacting ECCS" and insert
" defeating ECCS or RCIC" After " actuation.", add "However, manual actuation would be required.
Manual actuation within ten minutes following reactor trip would maintain the water level in the core above the top of the active fuel." 33(A.38) After the last sentence of the first paragraph of A.38 Add the following: " Although the Staff's
; objective is to review PRA's faster, experience to date with the PRA's sub-mitted for Zion and Indian Point indicates that review of a PRA takes about one year from the time of its submittal in final form."
1 34(A.39) Third line of the first paragraph of A.39 ! Change the word "interations" to
" interactions"
- 36(A.39) Bottom line Delete the word " adequate"
'I 38(A.39) Within the eleventh line Change the word "Categoruy" to
" Category" 39.(A.39) Within the eighth line
- Change the word "anlysis" to
! " analysis" 4.-- -,. - - - . - - _ -- .- m. . -- -- - - - - - - - - -
l 6358 () 1 MR. ELLIS: Judge, we may, after our 2 c ro ss-e xa mina tion , if it appears that some portion of 3 that we believe are not relevsnt, we may move to strike 4 it at that point in time. But we don't think we have a 5 basis a t this time to argue to you that it should not be 6 accepted. Mr. Conran has testified that he prepared it 7 and he is familiar with it, and I think on that basis l 8 certainly we have no basis to object now. But after 9 testimony we may move to strike, and I didn 't want to be 10 silent and not say that. 11 JUDGE BRENNER: Well, you can always move to 12 strike after. I will point out to you that if the basis
. 13 for a motion to strike is relevance, those motions are 1
(_/ 14 very rarely even made, let alone granted, af ter the i 15 cross-examination, as distinguished from what I thought 16 I also heard you say, that is the absence of any support 17 such that the weight which matters should be given is 18 zero in the mover's view and therefore you would move to 19 strike. 20 But make whatever motion you want to after and 21 we will deal with it. One reason I an hesitating is I
! 22 want to do things in such a way that we can focus on the 23 PRA-related matters first, and I will let you proceed 24 with that in mind, in whatever order you want to.
t , 25 MR. RAWSON: Judge, I thought it might be i O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6359 () 1 useful simply to get the remainder of the testimony into 2 the record and then proceed. 3 JUDGE BRENNER: Yes, I agree. I'm wondoring 4 if we should go right to binding in the rebuttal 5 testimeny or get the overall summary first or just 6 summarize the PR A-related matters first. But you have a 7 much better idea than I do of the relative time that 8 you're going to spend on each"of these. So I will just 9 let you proceed with the overall goal in mind of gettihg to to the PRA matters. 11 MR. RAWSON I think we can tie it up very 12 briefly, Judge, and then perhaps we can have a brief 13 summary of the Staff's position on the PRA matters from t O 14 Mr. Conran and hold off on the broader summary until 15 perhaps next week. 16 JUD'GE BRENNER: However you want to do it. 17 Should we bind the rebuttal testimony in now or go to 18 some summary first? 19 MR. RAWSON: Well, if I could just establish 20 through Mr. Conran that it is correct and ready to be 21 bound in, yes, sir, I think that would be appropriate. 22 BY MR. RAWSON: (Resuming) i 23 0 Mr. Conran, do you have a copy of the rebuttal l l 24 testimony before you? 25 A (HITNESS CONRAN) Yes, I do. O . ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
6360 () 1 MR. RAWSON: Judge, I have conferred with Mr. 2 Lanpher on the matter that he raised with Your Honor 3 last evening. The Staff has agreed that question 7 and O 4 answer 7 on page 5, together with attachment R-2, should 5 be stricken from the rebuttal testimony. The materials 6 referred to within that question and answer and I 7 attachment are available f or legal argument, and we l 8 think it is not nece'ssary to include them in the 9 testimony at this point. 10 JUDGE BRENNER: You are talking about in the 11 attachment? l 12 MR. RAWSON: I am talking about question and \ i 13 answer 7 on page 5 of the rebuttal testimon y, together ( 14 with attachment R-2, yes, sir. 15 JUDGE BRENNER: So we will strike that, or you 16 have withdrawn th a t, to be more accurate. 17 BY MR. RAWSON: (Resuming) j 18 0 Mr. Conran, do you have a copy of the reb uttal l 19 testimony before you? l 20 A (WITNESS CONRAN) Yes. 21 0 Are there any corrections or additions that 22 you wish to make to that rebuttal testimony at this 23 time? ! 24 A (WITNESS CONRAN) No, I know of none. ( 25 C Is it true and correct and do you adopt it as ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6361 () 1 your testimony in this proceeding? 2 A (WIT. NESS CONRAN) Yes. 3 0 Do you also have a copy of the letter dated 4 June 30th, 1982 from Robert B. Minogue, with an 5 indication that the original was signed by Denwood F. 6 Ross, Jr., to Mr. R.E. Allen? 7 A (WITNESS CONRAN) Yes, I have tha t letter. 8 Q dan you identify that document and its 9 significance in this proceeding for*me? 10 A (WITNESS CONRAN) Well, the document is in 11 response to a memo that was an attachment to Applicant's 12 testimony. I believe it was enclosure 4 In summary, 13 the letter is responding to the Chairman of the Industry 14 Standards Committee, and basically it says: 15 Thank you for your letter pointing out certain
- 16 difficulties in the usage of the terms "important to 17 safety" and "saf ety-related ". We have recognized this 18 problem and have tried to correct it by Mr. Denton's 19 memorandum of November the 20th of last year. With 20 regard to your suggestion that we stop using the term 21 "important to safety" until we can clarify this matter 22 further, we can't do that. The term is used too 23 extensively in our implementing regulatory guidance 24 documents and has been defined in the regulations since 25 1971.
O ALDERSON REPORTING COMPANY,INC, 1 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6362 () 1 We think we should continue to work together 2 to further resolve this language difficulty that we both 3 notice. 4 MR. RAWSON Judge, at this time I would ask 5 that the document be attached as attachment one to the 6 Sts ff 's rebuttal testimony of Mr. Conran and bound into 7 the record.
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8 MR. LANPHER: Shouldn't that be attachment 9 two? 10 JUDGE BRENNER: That is my fault, I'm sorry, 11 when I went through that off the record. 12 MR. LANPHER Because his TEI testimony is 13 attachment one to the record. . 14 JUDGE BRENNER: It's all my f ault. Let me see i 15 if I could -- I forgot about the other two attachments. 16 I guess it would be attachment R-3, "R" presumably being 17 rebuttal. B-2 has been identified and I guess it cas 18 bound in, although presumably crossed out in some 19 f ashion , given your withd ra wal. 20 MR. RAWSON: It will be, Judge. It has not 21 yet been. 22 JUDGE BRENNER: Let's go off the record. 23 ( Discussion of f the record.) 24 JUDGE BRENNER: In the absence of objection, 25 then, it will be -- I'm sorry. Mr. Ellis ? ALDFRSON REPORTING COMPANY. INC, 400 VIRGIN!A AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
6363 () 1 MR. ELLIS: Yes, Judge Brenner. I have a 2 concern and I want to state an objection to the 3 inclusion as an attachment of the copy of the prefiled 4 testimony from the T3I restart hea ring . I thought, and 5 I didn't think enough, that that would have been covered 6 by the same concern that Mr. Lanpher apparently 7 expressed in connection with what was agreed to be 8 stricken. 9 I think*it is unusual, to say the least, to 10 have a portion of testimony from another hearing made a 11 part of this one. I think we run the risk -- indeed, 12 this contention already bids f air to swallow every other 13 issue. And ve may import into this one relitigation of O 14 TMI. 15 And therefore, if the purpose of it -- in any 16 event, I think the findings of that board are certainly 17 there for parties to cite in argument and so forth. But 18 I think that selecting pieces of testimony from 19 witnesses to insert here is inappropriate. 20 JUDGE BRENNER: Well, I don't understand the 21 objection very well. It is much different than the R-2 22 problem. It is Mr. Conran himself. He is the same 23 person. Instead of retyping the same testimony, he has 24 attached it and has said this is his testimony. So it 25 is there for cross-examination. (^) ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6364 () 1 Now, it would be different if it were 2 testimony of a different witness to which we should give s 3 some magic weight. But we're not giving it any weight I 4 other than the saie as any of his other testimony that 5 we are admitting and he is open to be cross-examined 6 about it. 7 MR. ELLIS: Yes, sir. But my point was really 8 a point that goes to the fact that it was in a different 9 p ro ceed i*ng on a different plant, with a different FSAR 10 and all of the re s t . 11 JUDGE BRENNER: Unless you can point me to 12 something particular, there is almost nothing -- I don't - 13 vant to say nothing, but almost nothing -- in the (/ 14 testimony, if you cover up the caption of the case, that 1 15 relates to the TMI reactor per se as distinguished from 16 the Shoreham reactor. - 17 It is the Staff's methodology. Now, if the ! 18 Staff is saying it's the same methodology, then that 19 would be part of cross-examination to some extent. If 20 you establish very early that their approach was 21 completely different for the different reactors in terms 22 of systems, classification of systems and components as 23 important to safety, that would be something else. 24 I haven't read the testimony in two days, the l 25 rebuttal testimony. But that is my strong recollection l ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
6365 1
) 1 of it. It is not an analysis of the TMI reactor.
2 Do you disagree with tha t, H r. Ellis? I guess 3 I'm a little surprised I didn't hear a motion to strike 4 yesterday. I recognize you haven't had much time with 5 this testimony and that is why I'm certainly going to 6 give you every leeway to make your objections now. 7 MR. ELLIS: I appreciate that. 8 JUDGE BRENNER: But you see this distinction I 9* am making, that is that it is testimony of Mr. Conran as 10 a witness which is pertinent, by its title at least -- 11 and you can establish by cross-examination that it is 12 really not pertinent -- but by its title to
- 13 classification of systems and components, which is what 14 we are litigating here.
15 And it is not somebody else's writing, that is 16 some other board, which is the partial problem in the 17 other attachment. He could have retyped the whole thing - 18 and put the Shoreham caption on it and I think it would 19 have been okay. That is what I'm saying. 20 HR. ELLIS: Yes, but I do think that -- and it 21 may just be a matter for cross-examination, but it does 22 import into this hearing, I think, the circumstances of 23 the TMI restart hearing. 24 JUDGE BRENNER: I can tell you, you've got two 25 out of four people up here who are not going to sit ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6366 () I through that hearing again. 2 MR. ELLISa Well, it may be necessary, in 3 fairness to this Applicant, to make certain factors of 4 that relevant here if that is to be a factor. And I 5 think the comments that you made Jucge Brenner, about 6 the reactor and everything else I agree with. I don't 7 see anything in there that talks about the reactor. But 8 nonetheless, I think that we may -- 9 HR. RAWSON Judge Prenner, perhaps I can to shorten this. The Staff and Mr. Conran in his rebuttal 11 testimony cited , particularly a t pages 4 through 6, 12 question and answer 5, 6 and 7, which are clearly of, if 13 I might use the term, generic applicability, and there /~) k_/ 14 are no specific relations to the circumstances of the 15 TMI restart proceeding. 16 We would be satisfied to withdraw the 17 remainder of that testimony and simply have in evidence 18 those particular questions, noting of course that the 19 remainder is there to the extent relevant to the 20 portions remaining in. 21 JUDGE BRENNER: Your last phrase hurts. 22 MR. RAWSON: No, sir. I meant for the purpose 23 of other cross-examination by the pa rties. 24 MR. ELLIS: Could I make a suggestion, maybe? 25 And again, the responsibility is mostly mine, but if we ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6367 () 1 could -- if I could talk to Mr. Rawson about this. I 2 don't think we need to resolve it right today. If we 3 could go on with the testimony, I'm sure he and I can (~} kJ 4 resolve it. 5 JUDGE BRENNER: All right. There are some 6 questions and answers that refer to TMI-1. Judge Morris 7 pointed one out to me just now. But it is not going to 8 be -- I don't think it is going to be any problem in 9 terms of the concerns you are raisino or that I think 10 you are raising, Mr. Ellis. 11 Why don't we just adopt your suggestion and 12 proceed then, if you want to do that, because that is 13 surely what I would like to do. 14 MR. ELLIS: It is what I would like to do, 15 too. 16 MR. RAWSON: That is fine with us, Judge. 17 JUDGE BRENNER: So it is admitted into 18 evidence, then, and bound in. And I will leave this 19 caveat: If after your discussions, Mr. Ellis, you want 20 to renew your motion to strike or focus it as to 21 particular portions, I will hear you again on it. And 22 again, I recognize that you have had relatively little 23 time with this compared to the usual sequence in which 24 we have had testimony and motions to strike and so on. 25 But I think that should make it okay for you. O i l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
I ) 6368 i i . L lO 1 n. aus, rheex ro , aud ereocer. 2 2 (The document referred to, attachment E-3 to l t 3 the Staff's rebuttal testimony, follovsa) l 4 I P 5 6 7 8 I 10 . 11 12 - 13 i 14 15 16 l l 17 - l 18 . 1 \ t . l 19 20 21 22 l 23 l 24 25 i O i ALDERSON REPORTING COMPANY. INC, I 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345 i
i
? 07/01/82 o
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L/ NUCLEAR REGULATORY COMMISSION. , BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,,
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In the Matter of ) .
) . e LONG ISLAND LIGHTING COMPANY ) ,
00cket No. 50-322
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NRC STAFF TESTii10NY OF JAMES H. CONRAN, SR. IN REBUTTAL TO APPLICANT'S TESTIMONY ON SAFETY CLASSIFICATION gs AND ANALYSIS OF, STRUCTURES, SYSTEMS AND COMPONENTS v l SC/S00'CYEtTION76 , 50lTCONTENTION19(% ! y: 4
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[ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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LONG ISLAND LIGHTING COMPAtlY Docket No. 50-322 (0L) (Shoreham Nuclear Power Station,
~-
Unit 1) l NRC STAFF TESTIMONY OF JAMES H. CONRAN, SR. IN REBUTTAL TO APPLICANT'S TESTIMONY ON SAFETY CLASSIFICATION AND ANALYSIS OF STRUCTURES, SYSTEMS AND COMP 0NENTS (SC/SOCCONTENTION78) ( I (SOC CONTENTION 19(b)) O Q 1. Mr. Conran, have you reviewed Applicant's prefiled testimony !? regarding safety classification of nuclear power plant structures, systems, and components; and have you compared that testimony with
- Staff's prefiled testimony on the same subject?
1 A. Yes, I have. Q.2. And have you heard and considered carefully Applicant's supple-mental testimony under cross-examination in this hearing on the same subject? A. Yes, I have. Q.3. Are there any aspects of Applicant's testimony regarding adequacy of safety classification of structures, systems, and components Oe at the Shoreham facility as to which the Staff disagrees? l 1
A. There appears to be close agreement between most important Iaspects of the respective positions and conclusions of Staff and Applicant regarding adequacy of safety classification of Shoreham plant features, particularly as to the substantive technical safety clas-sification considerations at issue. With regard to terminology employed in the safety classification of Shoreham structures, systems and components (i.e., which specific term should be applied to specific plant features, "important to safety" or " safety-related"), there is obvious disagreement between Applicant and the Staff. Q.4. Is there a specific portion of Applicant's prefiled testimony with which the Staff disagrees in this regard? A. Yes. The Staff disagrees with, and expresses concern regarding possible implications of, the following statement (and related footnote) th on p. 55 of Applicant's prefiled testimony: In summary, the Denton memorandum, uses the term "important to safety" in a manner inconsistent with historic industry and NRC practice. 5/ Q.5 Are you familiar with the "Denton memorandum" referred to in the above quote?
-5/ The Denton memorandum does not specify what s design and quality assurance treatment should be applied to structures, systems and components that are "important to safety" except by the definition "anything that contributes in an important way to safety."
This raises many questions particularly since the Denton memo clearly states there is no C) intent to develop or dictate new requirements. The fact that the Denton memorandum has raised many questions is demonstrated by recent correspondence of the Nuclear Power Committee of IEEE. (emphasisadded).
A. Yes. The document referred to is a memorandum dated 7 November 20, 1981 from Harold R. Denton, Director, Office of Nuclear Reactor Regulation (NRR) to All NRR Personnel, regarding " Standard p) L Definitions'for Comonly-Used Safety Classification Terms." I prepared that memorandum (and the associated concurrence package) and saw it through a lengthy process of internal review that resulted in approval by Mr. Denton. Q.6. Could you describe the background for and the scope of the overall effort leading up to issuance of the "Denton memorandum'? A. The origins of the "Denton memorandum" on safety classification terminology go back to late-Sumer and early-Fall of 1980 and my efforts in connection with preparation of testimony
- in response to Contention UCS-14 in the TMI-1 Restart Hearing. The overall effort O (iaciuaias preneret4ea eae er9# meat of testimoax besea oa the so-ceiiea
" standard definitions" in the TMI-1 Hearing) covered more than a year, and included review-and-concurrence by all senior technical management officials in NRR prior to approval of these definitions by Mr. Denton himself in the November 20, 1981 memo.
More specifically, the overall effort leading up to issuance of the Denton " memorandum" involved the following: (a) extensive review of those portions of the regulations in which safety classification terms are defined and safety classification concept", are established (i.e., 10 C.F.R. Parts 20, l */ A copy of the prefiled testimony is attached as Attachment R-1. See particularly pages 4-6. l l
50 and 100), as well as review of many associated implementing I regulatory guidance documents (e.g., Regulatory Guides, Standard Review Plans, NUREG Reports, etc.) in which those safety classifi-cation' terms and concepts are further interpreted, developed, and applied; (b) extensive discussions with senior NRC staff members cognizant or otherwise knowledgeable regarding the historical development of applicable regulations and regulatory guidance documents, and cognizant or otherwise knowledgeable regarding historical and current staff practice in the application of safety classification concepts and terms The views and insights provided by the individuals involved in these discussions reflected a wide variety of backgrounds and/or current assignments in standard O development ectivities. nrosect mene9emeat. techaicei review, technical management, and legal review; and (c) full discussion of the safety classification and safety 7 classification terminology issues addressed in the "Denton Memorandum" with the cognizant ACRS subcommittee, and subsequent consideration by the full ACRS as well. It should also be noted in the context of the preceding discussion, that interactions with knowledgeable, cognizant representatives of utility / vendor / architect-engineer organizations, and discussions with j them of the safety classification concepts and terminology set forth i l later in the "Danton Memorandum", occurred on several occasions during l O the course of the overall effort described here. ( An example of such interaction'and discussion was the presentation and discussion provided l
at the ACRS subcommittee meeting referred to above by the chairman of the 1
' IEEE P-827 standards group working on a control systems classification scheme). At no time that I can recall in any of these interactions and discussions with industry representatives was any indication given of fundamental disagreement with the " standard definitions" ultimately set forth in the "Denton Memorandum".
Q. . Were the definitions set forth in your TMI-1 timony and/or those set h in the "Denton memorandum" acce d by the Board in that hearing? A. Yes, they were. The Boar s treatment of the safety classification arguments bef t in that hearing, and their findings in that regard, are covere explicitly a aragraphs 981, 1003a,-1004, and in footnote 121 p. 201 of Partial Initia Decision dated December 1981. (Co
- s of the appropriate pages of t tial Initial Decision contdfingtheseparagraphsareattachedasattachm Q.8. What is Staff's conclusion, then, regarding the statements on
- p. 55 of Applicant's testimony, referred to earlier in the response to 0.4., about which the Staff expresses general concern?
A. The Staff considers the statements incorrect to the extent that they imply or mean that there has been a substantive difference among members of the Staff in the application of regulatory requirements. Although individual members of the Staff (much like individual members of utilities', vendors', and architect-engineers' organizations) have in the past used the terms "important to safety" and " safety-related" in-correctly and inconsistently (a language problem), Staff practice in classifying structures, systems, and components either " safety-related"
or "important to safety, not safety-related," and in specifying quality Istandards and quality assurance measures appropriate to those clas-sifications, has been consistent in accordance with the intent of the regulations'as set forth in the definitions of the "Denton memorandum." Q.9. Why does Staff feel that the different usage of these safety classification terms is significant? A. The Staff does not believe it is acceptable for the language differences indicated in the statements on p. 55 of Applicant's testimony to go unresolved because of certain unacceptable implications of the different usage of the safety classification language of the regulations. These implications obtain not only with regard to Shoreham licensing but also with regard to the efficacy of the Staff's approach and me! hods of srfety review in more general application. There are at least three such O 4=ni4cet4oos:
- 1. Because the Staff conducts an audit review, reliance must be placed on commitments by Applicants that all portions of the regulations are complied with (see, e.g., FSAR % 3.1.2.1). It is critical that these commitments mean what the Staff understands them to mean if the Staff's determination of " reasonable assurance" (which finding must be made in accordance with 10 C.F.R. 9 50.35(c) in order to license a facility) is to be meaningful in the sense intended in the regulations.
- 2. It is clear under the Staff's understanding of "important to safety" (but not under Applicant's) that there exists in the regulations a requirement under GOC 1 for a QA program for certain non-safety-related 0 -
structures, systems and components (i.e., those important to safety).
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- 3. Under Applicant's construction of "important to safety," the hbligations imposed by 10 C.F.R. Part 21 might be more narrowly construed than would be the case under the Staff's broader definition of that term.
These examples demonstrate why agreement on the safety classification definitions provided by the Denton definition is extremely significant. O O
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COPtilSSION I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD (3 y/ In the Matter of LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (Shoreham Nuclear Power Station, Unit 1) ) CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF TESTT"0NY OF JA'1ES H. CONRAN, SR. IN REBilTTAL Tn #PPLICANT'S TESTIMnNY ON SAFETY CLASSIFICATInN AND ANALYSIS OF STRUCTURES, SYSTE'4S AND COMP 0NENTS" in the above-captioned proceeding have been served on the following by deposit in the linited States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear 9egulatory Commission's internal mail system, this 1st day of July,1992: Lawrence Brenner, Esq.* Ralph Shapiro, Esq. Administrative Judge Camer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street (n l U.S. Nuclear Regulatory Comission Washington, D.C. 20555 New York, NY 10016 Dr. James L. Carpenter
- Administrative Judge Howard L. Blau, Esq.
Atomic Safety and Licensing Board 217 Newbridge Road U.S. Nuclear Regulatory Comission Hicksville, NY 11801 Washington, DC 20555 Dr. Peter A. Morris
- W. Taylor Reveley III, Esq.
Administrative Judge Hunton & Williams Atomic Safety and Licensing Board P.O. Box 1535 U.S. Nuclear Regulatory Comission Richmond, VA 23212 Washington, DC 20555 Matthew J. Kelly, Esq. Staff Counsel New York Public Service Comission 3 Rockefeller Plaza Albany, NY 12223 O
?
r"~ Stephen B. Latham, Esq. John F. Shea, III, Esq. Herbert H. Brown, Esq. Twomey, Latham & Shea Lawrence Coe Lanpher, Esq. Attorneys at Law Karla J. Letsche, Esq. P.O. Box 398 Kirkpatrick, Lockhart, Hill, 33 West Second Street Christopher & Phillips Riverhead, NY 11901 1900 M Street, N.W. 8th Floor Washington, D.C. 20036 Atomic Safety and Licensing Board Panel
- Docketing and Service Section*
U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel
- U.S. Nuclear Regulatory Commission Washington, DC 20555 O
(2: Dor 7Z-ichard J./Rawfod Counsel for NRC Staff O 1
I: COURTESY COPY LIST Edward M. Barrett, Esq. Mr. Jeff Smith General Counsel Shoreham Nuclear Power Station Long Island Lighting Compr.ny P.O. Box 618 250 Old County Road North Country Road Mineola, NY 11501 Wading River, NY 11792 Mr. Brian McCaffrey MHB Technical Associates Long Island Lighting Company 1723 Hamilton Avenue 175 East Old Coue',ry Road Suite K Hicksville, New York 11801 San Jose, CA 95125 Marc W. Goldsmith Hon. Peter Cohalan Energy Research Group, Inc. Suffolk County Executive , 400-1 Totten Pond Road County Executive / Legislative Bldg l Waltham, MA 02154 Veteran's Memorial Highway Hauppauge, NY 11788 David H. Gilmartin, Esq. Suffolk County Attorney Mr. Jay Dunkleberger i O County Executive / Legislative Bldg. New York State Energy Office Veteran's Memorial Highway Agency Building 2 Hauppauge, NY 11788 Empire State Plaza Albany, New York 12223 l l l O
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4 h /W3 # $d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1 BEFORE TH$ ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) METP.0POLITAN EDISON COMPANY, Docket No. 50-289 ET AL ) (Three Mile Island Nuclear ) Station Unit 1) ) NRC STAFF TESTIMONY OF JAMES H. CONRAN RELATIVE TO CLASSIFICATION.0F SYSTEP.S AND COMPONENTS AS IMPORTANT TO SAFETY (UCS CONTENTION 14) Q.1 Please state your name and your position with the NRC. Py name is James H. Conran. I am an employee of the U. S. Nuclear Regulatory A. Comission, assigned to the Systems Interaction Branch in the Division of Systems Integration, Office of Nuclear Regulatory Regulation. 0.2 Have you prepared a statement of professional cualifications? , A. Yes. A copy of that statement is attached to this testimony. Q.2 Please state the nature of the responsibilities that you have had with , respect to Three Mile Island Nuclear Station Unit 1 (TMI-1). A. Prior to the March 28, 1979 accident at Unit 2, I had no involvement with either of the TMI units. Following the accident at Unit 2, I was assi'gned for several months to the task of monitoring for NRR the ACRS proceedings related to the THI-2 accident and the status of recommendations made by the O Tf-/
- 2-Comittee in that regard. At the end of May 1979 I was assigned as a mer:ter of the Lessons Learned Task Force which was chartered to identify .O -
and evaluate safety concerns arising out of the THI-2 accident, and to recomend changes to licensing requirements and the licensing process for nuclear power plants based on lessons learned from that experience. In I connection with my Lessons Learned Task Force activity, I was also given lead responsibility for evaluating (and drafting the Comission's response to) the Report of the Ad Hot Comittee of the Illinois Comission on Atomic Energy regarding implications of the TMI-2 accident. After issuance of the Final Report of the Lessons Learned Task Force, I was assigned as a member of a small staff group charged with implementing approved Short Term Lessons Learned recomendation,s in the context of the so-called
,q Near Term Operating License plants, (which included Sequoyah Unit 1, North Anna Unit 2, Salem Unit 2 and Diablo Canyon Units 1 and 2), and I participatec in the preparation of Safety Evaluation Reports to support those proposec licensing actions. Currently, I am assigned to the Systems Interaction Franch, a new entity in the NRR organization. This branch and function was created at the time of the recent NRR reorganization, specifically in response to lessons learned from the TMI-2 accident; one of the principal functions of the new branch is consideration of the effects of interaction between safety and non-safety systems.
O i
= e e
- 3 Q.4 What is the purpose of your testimony?
A. The purpose of my testimony is to respond to UCS Contention #14, which states: l "The accident demonstrated that there are systems and canponents presently classified as non-safety-related which can have an adverse effect on the
- integrity of the core because they can directly or indirectly affect temperature, pressure, flow and/or reactivity. This issue is discussed at length in Section l
. 3.4, " System Design Requirements," Gf NUREG-0578, the TMI-2 Lessons Learned Task Force Report (Short Term). The following quote from page 18 of the report describes the problem:
'There is another perspective on this question provided by the TMI-2 accident. At TMI-2, operational problems with the condensate purification system led to a loss of feedwater and
' initiated the sequence of events that eventually resulted in damage to the core. Several nonsafety systems were used at various times in the mitigation of the accident in ways not considered in the safety analysis; for example, long-term O maintenance of core flow and cooling with the steam generators and the reactor coolant pumps. The present classification system does not adequately recognize either of these kinds of effects that nonsafety system can have on the safety of the pl a nt. Thus, requirements for nonsafety systems may be needed to reduce the frequency of occurrence of events.that initiate or adversely affect transients and accidents, and other require ,
l ments may be needed to improve the current capability for use of nonsafety systems during transient or accident situations. In its work in this area, the Task Force will include a more realistic assessment of the interaction between operators and , systems.' The Staff proposes to study the problem further. This is not a sufficient answer. All systems and components which can either cause or aggravate an accident or can be called upon to mitigate an accident must be identified and classified as components important to safety and required to meet all l l safety-grade design criteria." The Board l'imited the scope of this contention to the core cooling system. (First Special Prehearing Conference Order, December 18, 1979). l
0.5 How is the term "... components important to safety ..." defined in the y Commission's regulations? A. The term "... structures, systems, and components important to safety ..." is defined in the introductory paragraph to the General Design Criteria (Appendix A to 10 CFR Part 50) as those "... structures, systems, and ccmponents that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public." From this context, it is clear that the expression "... important to safety ..." is meant to apply generally to all structures, systems, and components addressed in the General Design Criteria (GDC). The term is used consistently in that sense throughout the GDC, and in other parts of the regulations as well (e.g., see dicussion below). 0.6 Is the term "... safety-grade ..." defined in the regulations? A. That tem is not defined explicitly in the regulations. 'The tem is l -.O The widely-used, however, in the context of the safety review process. meaning of the tem, as most comonly used by the staff in that context, l is inferreo from the language of the regulations, as_ follows: I (a) General Design Criterion 1 introduces the notion of different quality levels for plant features with differing safety roles and . varying degrees of importance to safety. Specifically, GDC-1 requires
- application of "... quality standards commensurate with the importance of the safety function to be performed ..." for structures , systems, and components important to safety.
(b) Appendix A to 10 CFR Part 100 implements the concept established in GDC-1 (i.e., gradations in quality levels corresponding to relative safety importance) by identifying explicitly a select
~ ~ ^ -
( . _ . _
5-sub-class of structures, systems, and components (out of the broad y class "important to safety") that are required for the perfomance of specific, critical safety functions (e.g., safe shutdown, accident prevention and consequence mitigation, etc.). Specifically, Sec. III.c of Appendix A to 10 CFR Part 100 defines the Safe Shutdown Earthquake (the most severe seismic event analyzed for a nuclear power plant), and requires that "... certain structures systems, and components (important to safety) ..." be designed to remain functional for that event. Those "certain" plant features, and the critical safety functions they must perfom, are further identified in Sec. Ill.c as:
" ... those necessary to assure:
(1) The integrity of the reactor coolant pressure boundary, l (2) The capability to shut down the reactor and maintain it in a safe shutdown condition, or (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite execsures comparable to the guideline exposures of this part."
- Very high quality standards must, of course, be applied to plant features required for such purposes, in order to assure their availability when .
called upon and very high reliability in service. Such considerations are the origin of the term " safety-grade"; and the staff applies that tem only to the structures, systems and components recuired to perfom the specific critical safety functions identified above. (Frequently, the term " safety-grade, systems or components" is shortened to " safety systems or components." Tnese two terms are used interchangeably in the following testimony).
. . . . _ _ . _.. =.
Q.7 Would you sumarize from the preceding, the relationship between I the terms "important to safety" and " safety-grade"? A. (1) The term "important to safety" app 11es' generally to the broad class of structures, systems, and components addressed in the General Design Criteria. (2) " Safety-grade" structures, systems and components are a sub-class of all those "important to safety." (2) All structures, systems, and components encompassed by the term "important to safety" (including the " safety-grade" sub-class) are necessary to meet the broad safety goal articulated in Appendix A to 10 CFR Part 50 of the regulations (i.e., provide reasonable assurance that a facility can be operated without undue risk to the health and safety of the public). (4) Only " safety-grade" structures, systems and components are recuired for the critical accident prevention, safe shutdown,' and accident consequence mitigation safety functions identified in Sec. III.c of Appendix A to 10 CFR Part 100. . Q.8 Has the staff identified those structures, systems and components which must be safety-grade? f l A. Yes. They are listed in detail in Regulatory Guide 1.29. The specific purpose of Reg. Guide 1.29 was to icentify all structures, systems and components of nuclear power plants that should be designed to withstand the effects of the Safe Shutdown Earthquake (designated Seismic Category .). Because of the manner in which the term safety-grade was derived in the preceding discussion, however, the list of Seismic Category 1 plant features identified in Reg. Guide 1.29 should also be the listing of all " safety-grade" structures, systems, and components in a plant. 4
Q.11 Do you have any clarifying or amplifying coments regarding the second paragraph of the contention, i.e., the quote excerpted from NUREG-05787 A. 'The staff acknowledges that non-safety systems and caponents were used in the mitigation of the THI-2 accident; but it is important to note and emphasize, in the discussion of this contention, that resort was made to use of non-safety systems and components in the accident miti-gation role, only after imorocer operation of installed safety systems had resulted in severe core damage and other outside-design-basis conditions (e.g., voiding in the primary coolant and hydrogen generation, which may have blocked natural circulation, thus creating the need for I forced cooling). Q.12 Referring now to the last sentence of the contention, what is the staff's position regarding the statement that "All , systems and cmponents which can either cause or aggravate an accident or can be called on to mitigate an accident must be identified and classified as components important to safety and required to meet all safety-grade design criteria"? A. We believe that, in the sense that the term "important to safety" is defined and used consistently in the regulations (see response to Q.5 above), such systems and components would already be regarded (i.e., classified) .
. as important to safety. But, as further established in the responses to 0.6 and Q.7 above, all components important to safety need not be safety-grade. Only components reovirao for the specific critical safety functions delineated explicitly in the response to 0.6 above need to .n meet safety-grade desigr. criteria.
l
Is the term "... core cooling system ..." defined in the regulations? 0;9 A. To my knowledge, that term is not defined explicitly in the regulations. Trom the context in which it is applied in the specification of thi,s contention, however, the staff considers that tem to encompass those
~
primary, secondary, and auxiliary systems used to remove heat from the core and transfer it to the heat sink, both in nomal operation and under accident conditions. Q.lt Feferring now to the first sentence of the contention, (a) Can non-safety systems and components directly or indirectly affect We temperature, pressure, flow and/or reactivity, and (b) Can non-safety systems and ccmponents, therefore, have an adverse effect on the integrity of the core? A. (a) The staff stipulates that non-safety systems and canponents can directly or indirectly affect core reactivity and primary coolant temperature, pressure and flow. It follows, therefore, that (at l least in general) failure or off-nomal operation of non-safety systems and components can cause or aggravate an accident, but , (b) That does not establish that failure or off-nomal operation of non-safety systems and canponents alone can have an adverse effect on the integrity of the core, as strongly implied by the wording of the contention. (In the TMI-2 accident sequence, f ailure of non-safety components, coupled with imorocer coeration of installed safety systems, led to core damage.) 6 e
" e
.g-1 .
Q.13 More specifically, if a given ~non-safety . system or component is known to have contributed to an accident, or is known to have been relied upon to recover from an accident (as was the case at TMI-2), how does the staff decide whether-or-not the safety classification of the system or component should be changed and whether-or-not that system or component should be made safety-grade? A. The test applied by the staff, in deciding whether a given non-safety system or component should be upgraded to safety-grade, is not just whether it cot Id cause or aggravate or be called upon to mitigate an accident. The final determination (regarding whether-or-not to upgrade) is based upon consider, tion of the following questions (decision criteria), dich derive directly from the definitions and discussions developed in the responses to Q.5 through 0 10: (a) will the failure or off-normal operation of the non-safety system or component in question, in and of itself, degrade the capability of installed safety systems such that those safety systems cannot mitigate accident consequences and assure adequate safety,* (b) will the effects of f ailure or off-normal operation of the non-safety system or component in question alone exceed the capability of installad safety systems to mitigate accident consequences and assure adequate safety, if installed safety systems are operated properly 'so that full credit can be taken for their functioning to design capability througtaut the accident sequence,*
' Assuming single failure in the installed safety systems in accordance with the Single Failure Criterion.
4 l
'?
(c) is a non-safety syst'em or camponent that may be called upon actually l reouired to mitigate accident consequences and assure adequate safety, if installed safety systems are operated properly so that full credit can be taken for their functioning to design capability throughout the accident sequence.* , If the staff determines, either by careful analysis or actual experience, that the answer to any of these questions, in all of its aspects, is yes, then: (1) the system or component in question would be upgraded to safety-grade, or (11) the design of the facility and/or the capability of the installed safety systems would be improved such that the answer is no to all three questions.
> In some instances (as has been the case for some of the non-safety componen s which were involved in the THI-2 accident sequence and recovery process),
even though none of the decision criteria above that would require upgrading are met, the staff may decide as a prudent measure to require upgrading of the system or component in question, but not to full safety-grade. This might be done, for example, in order to improve the availability and reliability of the component in question, and thereby provide increased safety margins or greater flexibility for dealing with potential future accident situations (either within the current design basis or like TMI-2, and irrespective of how such conditions might come about).
- Assuming single failure in the installed safety systems in accordance with the Single Failure Criterion.
[ ..
y Q.14 Were any of the decision criteria set forth in the answer to Q.13 (that would require upgrading to safety-grade) met for any of the non-safety systems or components which either contributed adversely to or had to be called upon to mitigate the TMI-2 accident? A. No. The severe effects produced in the THI-2 accident (e.g., serious core damage; voiding in the primary coolant and hydrogen gas generation which may have blocked natural circulation; dispersal of large amounts of radioactive fission products in the primary coolant; etc.) did not result I from non-safety system er emponent failure alone. If operator action
' had not interfered with the proper functioning of the installed safety systems to their design capability, the safety systems could have accom-modated the effects of the non-safety component failures that occurred, and still have prevented the serious core damage and other outside-design-And if the core damage and other outside basis effects that resulted.
design-basis effects which occurred had been prevented, it would not have been necessary to call upon non-safety components to assist in accident r-itigation and recovery (e.g., long tem maintenance of core flow and cooling with RCP's and steam generators). Q.15 1s there a need, then, for any of the non-safety systems or ccrnponents that contributed to the TMI-2 accident, or that were called upon in the accident recovery process, to be made safety-grade? ( A. Nc. Reliance can still be placed, in future TMI-l operations, on the capability of safety systems currently provided in the TMI-1 design to assure adequate safety, without resort to the general userading of non- . O safety systems and components which would be reovired by the contention,
.. .p.. .- .= , . .w
if proper operation of installed safety systems is assured such that full 1 credit can be taken for the functioning of those systems to design capability.'
#r #= th t <=>t ii e < tr t ar <48 '#ce d O o '5 "" t " 6 e systems will be operated properly at TMI-1, in view of what happened in that regard in the TMI-2 accident?
. A. The staff has specified a number of corrective measures (described in NUREG-0680, "TMI-1 Restart SER," and in a letter dated 8/28/80 from Director, ONRR, to All Power Reactor Applicants and Licensees) in the aftermath of TM1-2, to better assure that operators will not interfere with the proper functioning of installed safety systems in the future. These corrective measures f all into three general categories:
~
(a) improved analyses of anticipated transients and accidents, and l improved procedures for operators based on those analyses, l
' j-(See NUREG-0680 at Cl-12, C2-4, C2-9, C2-16, C2-17, C2-18, C2-47, and 02-1 for details)
(b) improved instrumentation (e.g., sub-cooling meter, improved indication of PORY and safety valve position, improved AFW flow indication, etc.), to better monitor and understand critical plant parameters, and to better recognize the need for safety system operation if the l occasion arises, (See NUREG-0680 at Cl-5, C8-11, C8-14, C8-38, and D3-1 for details
' AssuT,ing single failure in installed safety systems, in accordance with l
' the Single Failure Criterion. O 1 e , O
- 13
,(c) improved operator training to better cope with anticipated and unanticipated plant conditions, I (See NUREG-0680 at Cl-6, Cl-7, Cl-16, C2-4, C2-5, C2-9, C2-10, l
' C2-12, C2-16, C2-17 and C8-47 for details. Also see ltr, dated 3/28/80, Denton to All power Reactor Applicants and Licensees) l Tne staff believes that satisfactory compliance with these requirements will provide the improved assurance needed that installed safety l systems will be operated properly, so that full credit can be taken
' for their effective functioning as required to assure adequate safety.
0.17 Has the staff required upgrading of g of the systems or components that either contributed to the TM1-2 accident or were called upon in l the accident recovery process? Has upgrading to full safety-grade been j required? Explain the staff's rationale for whatever action was taken in each case. f A. Examples of non-safety systems or components for which the staff has specified upgrading, but not to full safety-grade, include: ! (1) emergency power supplies for pressurizer heaters l UCS l (See NUREG-0680 at CB-3; also see Testimony of Jensen re: i l Contention 3) ! (2) emergency power supply for PORV and block valves ! UCS (See NUREG-0580 at CB-8; also see Testimony of Jensen re: Contention 5)
'
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TECHNICAL QUALIFICATIONS INFORMATION JAMES H. CONRAN
# SYSTEMS INTERACTION BRANCH DIVISION' 0F SYSTEMS INTEGRATION OFFICE OF NUCLEAR REACTOR REGULATION Education: B. S. in Physics,1963. The Colorado College, Colorado Sprinos.
Col, ora do. Post-graduate and PNfe'ssional Courses in Ph'ysics and 1952-1953. So,1,id-Sta,te,'J1ectronic Engineerino;. University of Kansas Professional Courses in Fault-Tree Analysis 1972 and 1980. Experience: U. S. Nuclear Regulatory Comission/U. S. Atomic Energy Comission Washington, D. C. 1973 to Present
- Principal Systems Engineer, Systems Interaction Branch. Divisian t
of Systems Integration, Office of Nuclear Reactor Regulation. f Responsible for development of systems interaction analysis methods, systems integration review methods, and correspondinc regulatory guidance; systems integration review of operating l l license and construction permits; and review of operating experience for systems interaction effects. Senior Project Manaoer on special assignment for one year to -he Lessons Learned Task Force and follow-on implementation activities. Responsible for identification and evaluation of safety conce ns arising out of TMI-2 accident, and recorrendatior of c'.anges :o licensing requirements and stfety licensing process; liaison <ith h the Bulletins and Orders Task Force and ACRS on TMI-2 ac review matters, follow-on implementation of Lessons Learned Task Force recomendations to Near-Term Operating License Aoplications; e
. - r____ ...
- m. . . . ,, .. ., _ _ o_ __ .. .
development of Near-Term Construction Permit Lessons Learned
! licensing requirements; and participation in the formulation
< of the overall NRC TMI-2 Action P'lan (NUREG-0660).
.Og e
- Senior Project Manager, Standardization Branch, Division of Project Management, Office of !!uclear Reactor' Regulation.
Responsible for management and coordination of safety review of applications for standard design approvals, and development of standardization policy.
- Senior Nuclear Engineer, Reactor Systems Safety Branch, Division of Engineering Standards, Office of Standards Development.
Involvement in development of quality assurance standards and Regulatory Guides for nuclear material processing facilities, protection-of-informants policy studies, and special safeguards-({') related investigations and hearings.
- Systens Engineer and Senior Safeguards Analyst, Requirements Analysis Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards. Responsible for comprehensive studies of adequacy of safeguards for existing licensed nuclear facilities (including nuclear materials processing facilities and power reactors),
and development of applicable safeguards regulations and other regulatory guidance.
- Senior Safeguards Analyst, Special Safeguards Study Project, Office C of Special Studies. Responsible for management, coordination, and technical review and evaluation of contractor studies relatir.g to safeguards issues identified in GESMO (plutonium recycle) proceedings; development of recommendations regarding the Reference
l i i. Safeguards System concept! ] ] ? Senior Staff Assistant / Project Engineer, Advisory Comittee for l Senior project leader responsible for: Reactor Safeguards. l toordinating activities of ACR$ project subcomittees, ACRS consultants, Regulatory Staff, and applicants in support of ACRS licensing reviews; preparation of reports for ACRS use identifyin l ' areas requiring detailed evaluation or resolution of deficiencies. ' U,. S. Atomic Energy Comission, Albuquerque Operations Office 1970 - 1973 Reactor and Criticality Safety Engineer, Reactor and Criticality Responsible for: Safety Branch, Division of Operational Safety. inspection and evaluation for criticality safety of all the facilities within the ALOO complex (e.g., weapons design anc:
- plants, weapons test i research laboratories , weapons production sites) that support the U. S. Nuclear weapons program, and a l
pertinent activities therein (e.g., research reactor and crit i assembly operation, uranium and plutonium processing, weapons assembly, packaging and transportation of fissie materials i and safety review of reactor and critical assembly instrument ] control, protection, and electric power systems; includine prop modifications. f 1967 - 1970 San Francisco Bay Naval Shipyard, Vallejo, California, Nuclear power Engineer, Test Engineering Branch, Nuclear Po Qualified for Shift Test Engineer position; responsible Division. j for preparation of detailed test procedures and direction o board shift testing operations involved in the acceptance
' ,. 9
i (pre-operational flushing'and hydrostatic testing, systens
, s tests, initial criticality and power range testing, and sea trial) of naval nuclear propulsio'n systems (new construction, refuel and pA O overhaul).
4
- Electronic Engineer, Refueling Engineering Branch, Nuclear Power i
Division. Qualified for Assistant Refueling Director position; responsible for direction of dockside and on-board shif t refueling operations for naval nuclear propulsion systens (refuel and I overhaul) Western Electric Company, Kansas City Manufacturing Works, Lee's Summit, Missouri, 1960 - 1967
- product planning and Design Engineer, Test planning Engineer, and 1 ,_,
Test Equipment Design Engineer. Responsible for planning and dirc:t engineering support in the production and testing of radio and voice frequency telephone carrier systens; design of major production test' equipment; and trouble-shooting problems encountered i in the prodoction testing and field application of the telepnene communications equipment manufactured at the Kansas City Works. 6 (Y e . , . . , ,,,, ,
* * * * * * * * ==.
e _ _ _ _ _ - _ _ _ . _ _ _ _ _ . _ _ _ - . _ _ _ . _ . _ _ - _ _ _ _ _. - _. __.. _.m______-________
~
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- 205 - ~
m :. an st.icensee namely, different quality lev.els for p ant features vith
\ _
diffe g safety roles and varying degrees of,,i ortance to safety. (( . i 981. ~ he Board is of't.he opinion af r hearing avguments and. testimony ' Q-- i, on all sides r the question tiiat tM taff'S'interpretatioh,'dspecially
,/ ' . ,i f , ' ' '~i >
that of Mr. Con n, is the one 9 1cTe,;t to the syste9'actljally.used by the, -
, 7,/,, ,,
~~ Staff. It is also the system which the Board feel.s should
- be employed.-
t <
;. , o s To argue otherwise uld >in one aspect '
of the question argue against ,s - asc9 mpkingimprovementsi saatt whichwouldresyltigasefeh,sys' tem,without .,,,
~ *w .. , , s _
upgrading to;a fully "s fe y gr3da" . system.
- ,In ot g ords such-4 ,,,v-viewpoint-_
,. f
, might discourage safety rovements to existing systems. Ne, agree with Mr. Conran wh' e n'he st tes t at: "The language of regulations"/' typically ,
h .., is broadly drawn s
's not to be too prescriptive --/ to pe 11 4, /c'xi-bility in--the'im ementation o those requirements". Tr. 84?2:
. 1 . , .. ,
' l A'
> 2. .Ef eet Iof Nonsafety-Rela ed Systems on the Reactor Core "
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- ~
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98 C*.S Contention 14 states tha , ,
,T e accident demonstrated t, hat there are systems'and components resently class 1fied as nonsafety-rel ted which can have an df erst effect..,on the integrify of the, core because they can .
dir, . ectly or indirectly affect temperatu e, pressure, flow .
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arNor react.ivity<. e
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~
and that, . ' ' , ' ',.. - e~*< - ' (',,) ~ [ All systems and'ccmpo'nents which can either, ause or aggravate an accident ... muat be identified and class fied 7.s components imoortant to safety and reqdired to, "meet ' ' ' safe grade design '
, criteria.
t , , . , . ,
-48 s .r e y / ,
a p @
i
- 215 -
I reply fi ing S 13), we find Conran qualified to pres t the testimony on rq this subjec . See Technical Qualifications Informa ion attached to V stimony, ff. Tr 8372. Mr. Conr'an's
- 7. Findin on Systems Classificati n and Interactions 1003. The Board ma the followin findings on system classification and interventions:
- a. The Staff's defin' ions of " safety grade" and "important to safety" are accepted by the Boa d.
Limited imp ovements to ystems which are not safety grade
] b.
are acceptable to provid improved plant afety. These improvements need not necessar'ily be of uch extent that the ffected system becomes upgraded to safety grade, l
- c. N nsafety grade systems and compo ents car. directly or indirectly affe t core reactivity and primary cool nt temperature, pressure, and flow. Ho ever, we are unaware of any such syst s at TMI-1 which can 1 /
adversely affect the integrity of the core. I
- d. Improvements in nonsafety grade systems ich will signifi-v cantly reduce the rate of challenge of safety grade syste s should, in genefal,bemade.
- 216 -
?
- e. All nonsafety grade systems.which mi t conceivably be n
nt need not necessarily Q called on to mitigate the consequences of an acci be required o meet all safety grade criteria.
- f. T -1 shall be included by e Staff in generic reviews of systems interaction . Application of IR or IREP follow on studies could reasonably lead to an enhancemen of safety at TMI-1.
- g. The Common ealth pro osed finding 1 234 which suggests upgrading of the power supp ies t the pressurizer level instrumentation before reactor power operatio ove 5% is adopted as our own.
- h. Staff witnes Con n is qualified to present testimony on this subject.
- 8. Concludi a Remarks 1004. The Bpard would like to com ent that the discussion on this subject,which as prompted by UCS' cont ntions, was useful in better defining the xpressions "important to sa ty" and " safety grade" as these expre ions are used in the regulator process. In the Board's view the e ercise prompted by UCS Contention o. 14 yielded results which should b helpful tc the Commission and Staff current and future
. safety reviews.
1
/ . - 201 -
corresponding to relative safety i ortance) by identify-ing explicitly a select sub-class of structures, systems, p and components (out of the broad class "important to C safety") that are required for he performance of specific, critical safety functions (e. ., safe shutdown, accident prevention and consequence m1 igation,etc.). Specifically,
- c. III.c of Appendix A to O CFR Part 100 defines the Sa e Shutdown Earthquake ( e most severe seismic event ana zed for a nuclear pow r plant), and requires that
, "... ertain structures, ystems, and components [important to sa ty] ..." be desig ed to remain functional for that event. hose "certain" plant features, and the critical safety f ctions they ust perform, are further identified in Sec. II .c as: ".. . those necessary to assure: (1) The int rity o the reactor coolant pressure boundary, (2) The capabi it to shut down the eactor and maintain ' it in a saf hutdown condition, or (3) The capabil ty to prevent or mitigate the consequences of acciden s wh h could result in potential offsite exposures ompar le to the guideline exposures of this par ." Such conside ations are t origin of the term " safety grade"; and the Staf applies that erm only to the structures, systems, an components requ red to perform the specific critical s fety functions ireAtified above. Conran, ff. Tr. 837 , at 4-5. 976. Mr. C nran then summarized these de initions as follows:I21 i (1) The rm "important to safety" applies generally to the broa class of structures, systems, an components addressed in e General Design Criteria. 121/ In a m morandum for all NRR personnel dated Nove er 20, 1981 the Direc r of NRR, noting problems of consistency in the use of safety class fication terms in this proceeding, has direct NRR personnel to e loy interim standardized definitions of "Impor nt to Safety", hy "Saf ty-Related", and " Safety-Grade". The Director's tandardized defi itions are consistent with Mr. Conran's testimony. O r -
~
R-2612 hTl q cM mtw. - fo b onr%n r B p Chron (QAg yg'md IC8 RD ICB SUBJ. 3410 TASK NO. N/A JUN 3 01982 RES 001412 l'.r. R. E. Allen, Chairman - bec: R.B.Minogue A tiuclear Power Engineering Committee D.F.Ross U Institute of Electrical & Electronics Engineers. Inc. . R. Goll er W. M. Morri son c/o United Engineers & Constructors. Inc. l 20 South 17th St. J.Conran, NRR) P.O. Box 8223 D.Sullivan,~EEB S Philadelphia, Pennsylvania 19101 E n e
Dear Mr. Allen:
D.L.Basdekas This is in response to your letter of I',ay 10, 1982, regarding use of the term, "important to safety." In your letter you cite the fact that some inconsistencies in the use of the terms, "important to safety," " safety-related," and " nuclear-safety-related," with the attendant confusion in their meaning, have been observed in flRC documents. We recognized this probicm and, in order to provide for a consistent and meaningfuluuse of these terms, the flovember 20, 1931, menorandum from t'.r. Denton, which you referenced in your letter, gave guidance for the use of terms regarding safety classification of structures, systems and components. [ We agree with your suggestion that there is a need for a more clear definition of structures, systems, and components that are included in the term "important to safety" and we do have work underway to provide a more explic,it definition of items that fall within this classification. We do not consider it practicable, however, to avoid the use of this term pending the availability of more explicit definitions. The term "important to safety " has been defined in our regulations (10 CFR Part 50, Appendix A-- General Design Criteria) since 1971 and is used extensively in our regula-tory guides. As noted in the Denton memorandum dated !!avember 20, 1931, structures, systems, and components important to safety encompass the broad class of features dovered in the General Design Criteria. l With regard to your references to Regulatory Guide 1.105, the scope of
- this guide is limited to protection systems instrument set points and the title will be revised to reflect this scope.
I strongly encourage your continuation of work on the classification of systems as part of your standards project P 827 in which NRC representatives are participating. I appreciate your interest in this important subject. Sincerely, Original Signed by iote; For previous concurrences see attached sheet. Denwood F. Ross, Jr. Revis DD/DF0/RES Robert B.111nogue, Director
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6369 () 1 MR. RAWSON: Judge, at this point I think I 2 would like to have Dr. Speis give a brief summary of the 3 entire testimony, and then perhaps we could move to the 4 PRA question. 5 WITNESS SPEIS: The NRC Staf f 's testimony 6 basically addresses the issues raised by contention 7.B 7 and 19.B. Basically, the key points that are made in 8 the S ta f f's testimony are the f ollowing: 9 The principal terms used by the Staff in the 10 safety classification of structures, systems and . 11 components are "important to safety" and 12 " safety-related." 13 Number two, the structures, systems and 8 14 components which are important to safety have been 15 addressed by the Applicant in his safety analysis report 16 and by the Staff's review. 17 The third point to be made, or that has been 18 made, in the Staff's testimony is that structures, 19 systems and components which are safety-related receive 20 special attention via the application of a more 21 stringent design criteria and quality assurance 22 standards. In addition, they receive special Staff 23 review, more intensive Staff review, and also they are 24 explicitly identified in the safety analysis report by 25 the Applican t in section 3.2.1. b ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
6370 O) (, 1 We believe that a systematic methodology has 2 been used in addressing structures, systems and 3 components important to safety. 4 The next point that has been made is that the 5 water level monitoring system and the standby liquid 6 control system have specifically been analyzed and l 7 classified to ensure that they are in compliance with 8 the Commission's regulations and Staff p rac tice . 9 The next point addresses the turbine bypass 10 system, the level 8 trip, the rod block monitor, and the 11 reactor core isolation system, commonly referred to as 12 RCIC. The S taff has addressed all of these in our 13 testimony and the basis for classifying those four [) (_) 14 systems,is provided. 15 We believe that the alternative methodologies - 16 proposed by Intervenors are neither required by the . 17 regulations nor by Staff practice, and we believe that I 18 there is good reason for that. l 19 The next point to be made is that the Staff l 20 believes that it is acceptable to operate Shoreham, in l 21 spite of the two issues that are presently being studied ! 22 as unresolved safety issues, that is that issue A-17 l 23 which deals with systems interactions in nuclear power 24 plants and issue A-48 which deals with the safety 25 implications of control systems. l
?
l 'v l ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 \
6371 (/) 1 And the last point that involves the final 2 point or basically the conclusion, is that the safety (~ 3 classification of structures, systems and components at V} 4 the Shoreham plant and the measures that we believe have 5 been taken to assure their reliability are in compliance 6 with NRC regulations and Staff practice. 7 BY MR. RAWSDN: (Resuming) 8 0 Thank you, Dr. Speis. 9 Mr. Conran, could you briefly summarize for 10 the Board your position on the relation of systems 11 interaction and probabilistic risk assessment that is 12 expressed in the Dircks memo and the attachments 13 thereto? 14 MR. LANPHER: Judge Brenner, could I ask, is 15 this f urther rebuttal testimony now or is this a 16 summary? . 17 - JUDGE BRENNERs I will let Mr. Rawson respond, 18 but my understanding is this is a summary. Therefore, 19 it is not in evidence in the sense that it can be relied 20 on for findings. And in fact, remember we made that 21 ruling that when they are identified as summaries they 22 couldn't be relied on. And I thought I heard Mr. Rawson 23 say this was a summary. And in addition, it was a very 24 close paraphrase of the written outline of testimony. 25 MR. LANPHER: My inquiry was not to anything ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6372 () I tha t Mr. Speis just said, but it was the upcoming. I 2 have no objection to that. I thought that was the g- 3 summary, and now I hear something new. And I took some O] 4 notes and I'm wondering if this is f urther testimony or 5 a summary or what its status is going to be, so we know 6 whether to take a lot of notes or fewer or what. 7 JUDGE BRENNER: Okay, I'm with you now. I 8 didn't understand your first inquiry. 9 MR. RAWSON: Judge, it was my intention to 10 have Mr. Conran at this point simply summarize the 11 position as a summary as we all understand it' expressed 12 in the documents that were attached. I realize that we 13 have not in the past perhaps gotten into summaries of 8 14 documents. 15 If the Board would prefer, I can hold it and 16 do it as a question before turning the panel over for 17 the PRA examination. 18 JUDGE BRENNER: If you are going to want to 19 propose findings on it, you can't do it as a summary. I 20 would pref er tha t we just get a summary at this point. 21 If you have any need for additional rebuttal, that would 22 surprise me a little since we had asked that it be in 23 writing. HR. RAWSON: It was our intention simply to l (J x 24 25 summarize at this point, Judge. l O l ALDERSON REPORTING COMPANY,INC, l j 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6373 O (,) 1 JUDGE B9EUER: Mr. Conran, do you understand 2 this is just a s u :n.1 r y ? It wouldn't be any additional
~T 3 information and it won't be cited for findings. So you (b 4 should save those gems to respond to questions, if you t 5 will. But within those confines, feel free to include 6 anything in the summary that you think is a summary.
7 WITNESS CONRAN: Well, I'm happy the 8 discussion came down that way, because I wanted to 9 clarify a point in my previous answer to Mr. Rawson's 10 question about this memo. When I said tha t it is a 11 little too strong a statement to say tha t this 12 rspresents a Staff position, I had in mind the
,- 13 PRA-systems interactions relationship question.
U 14 JUDGE BRENNER: Let me just stop you for a 15 aoment. Please hold your thought if you can. 16 I don't think this is a summary, Mr. Rawson. 17 I'm not saying he's not going to be allowed to give it. 18 MR. RAWSON: If you would like, I don't think 19 so either, Judge. If we could hold that, I think Mr. 20 Conran wants to clarify a point that he made in the 21 course of testimony in relation to the identification of 22 the document. If you would like to do that separately, 23 either before or after the summary. 24 JUDGE BRENNER The reason I want to label it 25 right is that it is not to be picky, even though I'm O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l l l 6374 l l () 1 sure it seems that way. I wan t to, when we go back and 2 look at the transcript later, I want to know what is
~
3 citable and what is not citable. i 4 Well, let's take the cla rifica tion, and this 5 will be evidence at this point. And then when you've 6 completed that clarification, if the Staff still wants 7 to do a summary we will go back to that. 8 WITNESS CONRAN Well, the point I was trying 9 to make was that a summary of what is covered in the 10 document seemed like the perfect context to do the 11 clarification. If I could handle the summary first, I 12 think maybe that is the way I would like to do it. 13 JUDGE BRENNER: I'm sorry if we diverted you.
., 14 The djstinction may be important later in terms of what 15 would be citable in proposed findings that the Staff 16' might want to propose.and what might not be citable.
17 MR. LANPHER: Judge Brenner, I'm happy to t'a k e 18 careful notes now, and why don't we decide afterwards 19 whether it's summary or evidence. 20 WITNESS CONRAN: Mr. Dircks' memo addresses 21 two aspects of the systems interactions question in 22 general. One is whether or not what is currently in the 23 requirements and regulations of the Commission provides 24 adequate safety. If compliance is demonstrated with 25 existing requirements that supports a finding of O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6375 () 1 rea sona ble a ssurance with no undue risk , th e Staff is 2 reaffirming to the ACRS that position. So that is a 3 S ta f f position . And I should have mentioned that in 4 answer to Mr. Rawson's question before. 5 Coming off of our PRA-systems interactions 6 discussion just before, my mind set was such that I 7 answered Mr. Rawson's question about whether this 8 represents a Staff position in that sense. Again, in 9 that sense or where that part of the systems 10 interactions issue is addressed, that is how systems 11 interaction analyses that the Staff is planning fit in 12 with or interface with PRA's, what is that relationship. 13 That is what I wanted to be caref ul not to 14 represent as a Staff position. That is really more a 15 summary answer to ACRS. ' 16 The most important point made by this letter 17 was ACRS, as they do occasionally, had commented to the 18 S ta f f that, while studying the systems interactions 19 issue to complete the resolution of A-17, we should be 20 doing mo re. Don't just study, do more, was the 21 suggestion. 22 dr. Dircks' answer said: We understand your 23 suggestion, but we are not going to do more now. We
/ 24 believe our own words when we say that compliance with 25 existing requirements provides adequate safety, and so O
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6376 () 1 we are going to proceed on an orderly basis to complete 2 the program before we think about issuing any additional 3 requirements, if they are found to be even necessary. 4 MR. RAWSON: Judge, it seemed to me that that 5 was all summary. 6 JUDGE BRENNER: If I was you I would call it 7 the other, because you might want to use it someday. I 8 think it was -- let me just say what I think it was in 9 this discussion. I think it was helpful further
. 10 explanation of the context of this memo.
11 And you asked that one last question, which 12 maybe - Mr. Rawson -- maybe it was beyond what needed i 13 to be asked for my limited purpose then. But since the 14 question had been asked and answered, this helped 15 clarify that answer. And've will leave it in as 16 something that is in the record and citable, and ( 17 therefore open to be cross-examined on. And I suspect 18 we're going to have questions all over that field 19 regardless of our ruling on that particular matter. 20 But clarification is helpful, and I also 21 understood why Mr. Conran was oriented as he said he was 22 at the time he gave you the initial answer. There are 23 other things in the letter, as he indicated. So it is 24 in evidence. 25 Now we can go to the overall -- did you have O ALDERSON REPORTING COMPANY,INC, ! 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6377 O ' e= overe11 ====arr 91 a to= >RA seroaa taet? 2 MR. RAWSOS: No, sir, we did not have an n 3 overall summary for PRA. I am content to turn the panel () 4 over for cross-examination at this point. I understand 5 we're moving first to the subject of PRA and systems 6 interactions. 7 JUDGE BRENNER: Okay, cross-examination by the 8 County. p 9 MR. LANPHER: Judge Brenner, if I could get a 10 clarification. Is the request to go to PRA first and 11 then we will go to, I guess, Mr. Ellis' cross on ERA and 12 the Board questions, and try to finish PRA to the 13 maximum extent? Vi 14 JUDGE BRENNER: I hadn't considered that. 15 Tha t is beyond your questions and, since if we don't get
. 16 going we're not going to get very many of your questions 17 --
18 MB. LANPHER: We 're not going to complete my 19 questions today by 2:30 on PRA. 20 JUDGE BRENNER: I'm shocked. 21 (Laughter.) 22 JUDGE BRENNER: Youve got a whole 45 23 minutes. 24 (Laughter.) 25 JUDGE BRENNER: Well, we will all think about O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6378 () fs 1 that between now and Tuesday. And whatever the parties 2 propose, the way you just outlined it it made a lot of ("} 3 sense. We didn't get to that point in our previous V 4 discussion, and I will let you discuss it among the 5 parties and let the Board know on Tuesday. We are 6 amenable to either approach. 7 MR. LANPHER: For the Board's information, on 8 my cross plan I'm going to start on page 8, item E, just 9 briefly, and then go to page 35, Roman numeral VII. 10 CROSS-EXAMINATION ON BEHALF OF SUFFOLK COUNTY 11 BY NR. LANPHER: 12 0 First, Mr. Corran , you men tioned th a t -- 13 A (WITNESS CONRAN) I'm sorry, I've got two s;J 14 pieces of testimony. You're on page 8? 15 0 No. That was for the Board. That is my cross
. 16 plan, which I'm not going to give you right now.
17 (Lauch'ar.) t 18 JUDGE BRENNER: I 'm going to pick a piece of 19 testimony, maybe, in this hearing and have a written 20 cross plan and a written answer, and see if that's more 21 efficient. I have musings from time to time. We're 22 going to find a way to be efficient before the end of 23 this. 24 But for now, that is the cross plan, Mr. 25 Conran, and only the Board and the County has it. V(3 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
6379 () 1 BY MR. LANPHER: (Resuming) 2 0 Mr. Conran, you stated tha t you believed that 3 a key document on the relationship between PRA and
.O 4 systems interactions had just gone from the Str.ff to the 5 Com mission ; is tha t correct?
6 A (WITNESS CONRAN) Yes, sir. 7 0 What is that document? 8 A (WITNESS CONRAN) As nearly as I can remember 9 the title, it is the "St'aff's Action Plan on the 10 Implementation of the Safety Goal." It is referred to
' 11 in the Federal Register notice that was cited in earlier 12 testimony.
13 Q Is your understanding that it went to the ksq 14 Commission this week? 15 A (WITNESS CONRAN) That is my understanding, 16 yes, sir. 17 0 Mr. Conran , I have a few questions I would 18 like to direct to your statement of qualifications, 19 sir. On line 4 of that statement, you indicate that in 20 1972 and 1980 you have had courses in fault tree 21 analysis. Could you describe those courses, please? 22 A (WITNESS CONRAN) In 1972, while I was 23 employed at the Albuquerque operations office of the () 24 Atomic Energy Commission, I attended a two or three-week 25 course that was given by David Hassl and Norman Roberts, O ALCERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6300 l . 1 two recognized experts in the field of fault tree 2 analysis. 3 The course that I referred to in 1980 was in 4 September of 1980, I believe, after the formation of the 5 systems interactions branch, the branch chief undertook 6 a sort of survey, a week-long course in which various 7 elements of the Staf f and again Mr. Ha ssl brief ed the 8 systems interactions branch staff on what was going on 9 currently in the world of PRA, fault tree analysis, the 10 IREP studies that were currently under way. It was sort 11 of a refresher course. 12 0 Now, between 1972 and 1980 did you have 13 continuing involvement in fault tree or PRA matters? O bA 14 A (WITNESS CONRAN) No. 15 Q Since that course in 1980, which I believe you 18 described as a survey course, you have had no other 17 courses or formal courses in fault tree work or PRA 18 work; is that correct? 19 A (WITNESS CONRAN) No, sir. 20 0 Mr. Conran, you could help me with your resume 21 by providing some dates for the various jobs or 22 positions you've held at the NRC. You will see that you 23 were principal systems engineer, and then further down 24 on the first page you were senior project manager. If , 25 you could put this in context, dates, which years you O
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6381 () I were involved in the various work. 2 For example, the principal systens engineer. 3 A (WITNESS CONRAN) Do you mean just the 4 positions with the NBC or the AEC? 5 Q Well, I would like to go back to 1973. I was 6 going to stop you there. 7 A (WITNESS CONRAN) Is it all right if I go back 8 to '73 and come f orward, since that's the way I think 9 about it? 10 Q Any way which is easiest for you. So you are 11 going to sta rt at the top of page 37 12 A (WITNESS CONRAN) Yes. 13 Q Okay. , 14 A (WITNESS CONRAN) February of 1973, I joined 15 the staff of the Advisory Committee for Reactor 16 Safeguards, and I was with the Committee staff until 17 June of 1975, at which time I volunteered for service in 18 the special safeguards study project. That involvement 19 in the saf eguards included work on the special 20 saf eguards study project and then later in the division 21 of safeguards. 22 I was in the division of safeguards until July 23 of 1977, a t which time I was r~eassigned to the office of 24 standards development. I was with the office of , 25 standards development until August of 1978, when I O 6 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6382 O 1 beceme e creaect meneoer in the etenderd12 tion brench 2 of NBB. p 3 After the TMI accident, in about May of 1979, b 4 I was assigned as a member of the lessons learned task 5 force and, either in the capacity of acting with the 6 task force or follow-up implementation activities, I was 7 involved in the lessons lea rned task force work and 8 implementation of the lessons learned task force 9 recommendations until April of 1980, when the systems 10 interactions branch was formed and I became a member of 11 that branch. 12 In April of 1981, the branch was reorganized 13 out from under us and we became a part of the
! 1 L/^ 14 reliability and risk assessment branch in another 15 division, the division of safety technology. And that 16 is where I have been until now.
17 0 Thank you very much, Mr. Conran. l 18 Let's start at the present again. In your l 19 present job, does this job include a review of 20 utilities' cla ssification of systems, structures and 21 components? Do you actually review the equivaldnt of 22 Table 3.1 or 3.2.1-1 that is in the Shoreham FSAR? l 23 A (WITNESS CONRAN) No. 24 0 That is not one of your jobs? , 1 " 1 25 A (WITNESS CONRAN) No. O l - ALDERSoN REPORTING COMPANY,INC, ! 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6383 () 1 Q Do you assess utilities' compliance with the 2 QA requirements, with the NRC regulations? 3 A (WIINESS CONRAN) No. 4 0 In any of your jobs have you been involved in 5 the review of utilities' classification of systems, 6 s tr u c'tu r es , or components, whether they classify things 7 correctly or not? 8 A (WITNESS CONRAN) No, sir. 9 MR. LANPHER: Judge Brenner, there are going 10 to be some items that, just for your information, some 11 things that I'm going to come back to on Mr. Conran. 12 But I'm going to try to narrow it for now, so we can get 13 on to PRA satters as promptly as possible. b/' 14 JUDGE BRENNER: Okay. I want to make sure you 15 and also the Board has a correct handle on which 16 witnesses would be the ones on PRA matters, other than 17 Mr. Conran. 18 MR. LANPHER: Well, let me ask that question. 19 BY MR. LANPHER: (Resuming) 20 0 Mr. Conran, from the authorship sheet, which I 21 don't know if it is in evidence but was distributed to 22 us, you are listed as the author of section 8 of the 23 testimony, which starts on page 31, or the other 24 methodologies section of the te,stimony; is that 25 correct? O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
6384 () 1 MR. RAWSON: Judge Erenner, excuse me. I 2 don't know that Mr. Conran has that sheet in front of 3 him, but I would note that the sheet that was 4 distributed and to which Mr. Lanpher is referring 5 indicates primary rasponsibility as its heading, rather 6 than authorship. 7 BY MR. LANPHER: (Resuming) 8 Q. Well, let me ask this, Mr. Conran. Were you 9 the author of this section? 10 A (WITNESS CONRAN) I was not the primary author 11 of this section. I was responsible for the coordination 12 of the preparation of the testimony. I understand it to 13 the extent that it goes into PRA, and of course I f
\ /h 14 understand it from an expert's viewpoint from the i
l 15 systems interactions side of the question. 16 I understand the testimony and talked to the 17 individual who was the primary author, and understand it , 18 and have discussed it to the point that I adopt it as my l 19 own and am able to discuss it to that extent. 1
- 20 0 Who was the prima ry author, Mr. Conran?
21 A (WITNESS CONRAN) Mr. Israel of the 22 reliability and risk assessment branch. 23 (Pause.) 24 0 Focusing just on that section, what I call the 25 alternative methodologies section starting at page 31, l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
6385 l l () 1 Mr. Israel of tha risk assessment branch prepared the 2 draft and then you reviewed that draft with him? 3 A (WITNESS CONRAN) Tha t 's righ t. And also saw 4 it through the management review process and the comment 5 collecting and incorporatino process, and approval by 6 the management. 7 0 Did anyone else on this panel have 8 r es pon sibili ty for review of this portion of the 9 testimony? 10 A (WITNESS ROSSI) I believe I prepared a draft 11 of questions 36 and 37. Yes, 36 and 37; I prepared a 12 draft of those two questions and answers, with 13 consultation with other members of the pa ne l. f~ ~ 14 0 So Mr. Israel was not the primary author on 15 those two questions? 16 A (WITNESS ROSSI) No. 17 Q Mr. Israel was the primary author? 18 A (WITNESS ROSSI) Just a minute. I'm checking 19 one thing here. 20 I prepared 36 and 37 with consultation with 21 other membars of the' panel and other members of the 22 S ta f f , a nd it did include, I believe, on 37 in 23 particular, input from Mr. Israel via Mr. Conran. 24 A (WITNESS CONRAN) In case there is some 25 misunderstanding, my function was not just purely O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
l l 6386 () 1 coordination. I also reviewed and commented and made 2 changes where I thought they were appropriate from the 3 viewpoint of the systems interactions analyst. 4 0 Dr. Rossi, I would like to turn your attention 5 to page 2 of the prefiled testimony, answer number 2, 6 the first sentence up to the semi-colon. It says you 7 were jointly responsible for sections III, V, VI, VII, 8 and responsible for a portion of section IX. 9 A (WITNESS ROSSI) Yes. And I also participated 10 in the preparation of all of the testimony, and I 11 believe that in relation to section VIII it was 12 undoubtedly listed the way it is in answer 2 because I 13 think question 38 was considered to be the meat of . 14 section 8. 15 0 You thought that that sentence in answer 2 was 16 an accurate reflection, however, of your participation? 17 Don 't you think it is more accurate to say that you were 18 responsible for portions of section VIII? 19 A (WITNESS ROSSI) That could be more accurate, 20 yes. Keep in mind that when I prepared the questions 21 and answers'there that I did have consultation, 22 significant consulta tion with other members of the panel. 23 25 O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554-2345
6387 {]} 1 Q What other members of the panel participated 2 on questions 36 through 387 l 3 A (WITNESS SPEIS) I participa ted in the re vie w (s \
'~') 4 of the testimony even though I was not the primary 5 author. I provided comments for clarity and consistency 6 of the Staff position, particularly on the PRA question 7 38.
8 0 I missed the last couple of words of that
. 9 answer, sir.
10 A (WITNESS SPEIS) I said I participated in the 11 review of the testimony even though I was not the 12 primary author. I reviewed it f or consistency and p 13 cla rity , and I think I might have had some more input to (,) 14 the question 38 from a policy standpoint, which deals 15 with the Shoreham PR A. 16 A (WITNESS ROSSI) Could I add something else to 17 my involvement on 36 and 377 My involvement.in 36 and 18 37 was from the standpoint of how we do the safety 19 classifications of structures, systems, and components, 20 and not in any way as an expert on PRA. I don't know 21 whether that helps you or not. In o ther words, I was 22 coming at those questions and answers from the j 23 s ta nd point of the way I do it in the Instrumenta tion and ( 3 24 Control Systems Branch in our review and not from the 25 standpoint of somebody that does PRA. g-k- l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6388 () 1 Q Mr. Rossi, this section is not limited. While 2 we have talked, we have given it a code name of "PRA. 3 There is discussion of systems interaction analyses, 4 dependency analyses, and other things. Now, does the 5 answer you just gave also apply to those other 6 methodologies, too, in addition to PRA? 7 A (WITNESS ROSSI) PRA moreso than the others, 8 failure-modes-and-effects analyses, a little bit less. 9 I would say that I get involved more in systems 10 interaction analyses and dependency analyses in the work . 11 that I do than either of those first two. 12 0 Er. Hodges, did you have any participation in 13 this section of the testimony besides review? b'\ L/ 14 A (WITNESS HODGES) I believe my participation 15 in section 8 was limited to review. 16 0 Er. Hsass, answer 2 on page 2 does not 17 indicate that you reviewed this section or participated 18 in this sections is that true? 19 A (WITNESS HAASS) That is a fair statement. 20 0 And, Mr. Kirkwood, likewise, answer 2 does not 21 indicate that you reviewed or participated in this in 22 any way; is that correct? 23 A (WITNESS KIRKWOOD) That is correct. I 24 MR. LANPHER: Judge Brenner, I would like to 25 mak e an inquiry before the close of today, if there are O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6389 () I any -- I as a little bit surprised by some of the 2 answers that I got. A general review I expected, but 3 authorship of questions, I did not. And I am wondering 4 if there are other areas in the testimony, since we are 5 going to have a break over the weekend, for focusing it 6 would be helpful if there are other areas where 7 clarification could be made available. 8 I do not need it on the record today, but I 9 would like it on Monday morning if there are any 10 additions, I would appreciate a phone call. . 11 JUDGE BRENNER: You did not make a very 12 specific request as to what you want, but I think I know 13 what you want. Let me phrase it. You want to know if i 14 anybody else participated in other than just a review 15 fashion in the collegial process of drafting these 16 questions and answers, either other members of'the panel 17 or whether there are other people whose involvement in 18 f act would be enough to have them considered as 19 co-authors. 20 MR. LANPHER: That is righ t. I f rankly was 21 relying on the June 17th submission that said primary 22 responsibility. Maybe I read it wrong, but I thought 23 that meant who did the first draft and basically managed f.. 24 the stuff. And I am a little surprised. And I do not 25 want to make a big deal of it beyond tha t right now, but O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6390 1 O) (, 1 I would like to know on Monday or whenever it is 2 convenient from the Staff, so that the proper rs
\s 3 preparation and focus of questioning can continue.
I v 4 MR. RAWSON: Judge Brenner, may I interject a 5 comment? As you stated, this is a collegial process. 6 The process of preparation and review of this testimony 7 has been extremely complex. We have done our best in 8 two different ways to try to provide information with 9 respect to the attribution. There may well be areas 10 where we could have been clearer. I have no. difficulty 11 with trying further to track down those areas and, 12 consulting with Mr. Lanpher. ' 13 ,uld point out again, this is a collevial (~) .(' 14 process. Dr..Rossi was involved at a very early stage 15 and may have a broader development and broader - 16 involvement in a couple of the areas 'than we were able . 17 to track down when we put down the attribution 18 statements. 19 JUDGE BRENNER4 Well, I should have thought- ; 20 Mr. Conran wrote tha t section too after looking at it, 21 and tha t is the focal point. After reading it, I think s 22 any reasonable person would have thought that, or else I 23 am unreasonable, one or the other. The subject of the 24 reasonable man test, you have failed on that section i 25 because I was misled. s ( ALDERSON REPORTING CostPANY, INC, y 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6391 l () 1 I want to know who the -- I do not want to get 2 too hung up on terms because I am afraid the answer is ! 3 going to be too ar tf ul to be frank -- but you know what 4 is being sought here, and I think it is a reasonable 5 request. Sufficient involvement to be considered an 6 author or co-author. The Board -- and, yes, you have 7 made it complicated, test money, and there are a lot of 8 people involved, and we appreciate the efforts we have 9 gotten so far, and we are certainly not belaboring 10 tha t. . 11 But I think in light of this one questiona and 12 answer, take a look and see whether we can get some 13 f urther information. 14 MR. REIS: We will look at it from that point 15 of view. But let me just say that this testimony was 16 very extensively reviewed at'all levels, within NRR, 17 particularly, and in what Mr. Lanpher said, that means 18 -- I do not know whether it would require that we have 19 everyone who ever reviews testimony here. 20 We did have it reviewed. There are many 21 policy statements in this testimony, and we had to have 22 them cleared. So they were, in that sense, reviewed. 23 However, we will attempt to tell who the 1 24 principal authors of each nection are. It is just that 25 I am a little concerned that Mr. lanpher's request was O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 553 2345
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- 6392
() 1 considerably bruader than ;that. And.I do not want to -- 2 JUDGE BRENNER[ Look, l'Ido no't like these side 3 diversions. They are just taking too long. He did not 4 ask for everything you asked for in terms of anyone who 5 reviewed it. And at least as I phrased it, that is 1 C clearly not what we asked for. 7 However, on the other hand , I did not limit it 8 to principal author, because I do not want to get hung 9 up on what you may mean by tha t term and what I may mean 10 by that term and so on and.so forth. You can judge what 11 sufficient involvement was to have been considered a 12 co-author. And wha t I hesrd so far, Mr. Israel's name 13 would have been listed on those questions and answers, 14 for example, and Mr. Rossi's. That is all. We 15 understand their collegial involvement.- 16 However,'in anticipation of these kinds of i 17 problems in one of our early orders here we asked for 18 identification just to avoid, frankly, vastino time on 19 the record ferreting these matters out. 20 In addition, at some point soon -- the reason 21 why it is particularly important on this aspect, since 22 we are focusing on the other methodologies, including 23 PRA first, there have been statements, including () 24 sta tements by counsel, by you, Mr. Reis, as to Staff ( j\ 25 position. And I said then we cannot take statements of ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6393 () I counsel. To that extent, that is pa rt of the purpose of 2 the testimony is to explore that. 3 And I want to know if there is a witness here 4 who is sufficiently involved in PRA-type techniques for 5 the Staff to be able to come in here and say it is 6 useless to look at the PRA work done for Shoreham from 7 the point of view of systems interaction and systems 8 classification, which is close to what you said, I 9 think. If it is not, we can have that same witness 10 explain that. But so far, what I have gotten is, I do 11 not know yet if there is such a witness here, and that 12 may be a problem. 13 HR. REIS Mr. Chairman, I can state right off 14 we state in the testimony we did not review the Shoreham 15 PRA. And if you say, is there a witness here who can 16 testify as to our review of the Shoreham PRA -- I do not
- 17 want to cake extra time --~but your statement to me 18 reflected that you expect someone on this panel to say, 19 I reviewed the Shoreham PRA and it is useless or not l
20 useless. We have indicated we did not say -- we said we 21 did not review it. I 22 JUDGE BRENNEP: I guess -- ny apologies, it 23 must be late in the day for me if I said that. That is 24 not what I meant to say. f 25 What I meant to say is you are going to have
/3 V
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6394 m 1 to have, if you are in favor of a finding that there 2 would be no benefit from looking at the Shoreham PPA n 3 work done from the point of view of systems L.) 4 interactions, and that is why it was not looked at -- I 5 understand well the Staff did not look at it. What I 6 vant to get at is the reason, the basis as to why it was 7 not looked at if it exists. And that is the kind of 8 witness I am talking about. That is another way of 9 saying support for some of the statements in these 10 memos. .It is not precisely that, but it is related to 11' that. 12 WITNESS ROSSIs Could I add something on 13 questions 36 and 37? 14 , JUDGE BRENNER: Do you mean about the 15 authorship? - 16 WITNESS ROSSIs. Yes. Well, about the content 17 of them, in particular, and also, I think , in 18 explanation perhaps of the authorship of them. 19 JUDGE BRENNER: Dr. Rossi, I will allow you to 20 ' do it if you bear our context in mind now; tha t is, we 21 are not just going to get additional testimony without l 22 questions. But you think it would be helpful in the l l 23 context of the discussion that has just taken place; 24 correct? 25 WITNESS ROSSIs I hope so. If not, stop me.
~T (O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6395 (M And I am sure you will. (,) 1 2 But questions 36 and 37, as I read them, are (~; 3 particularly directed at the use of certain methodology
\_) '
4 in the safety classification of structures, systems, and 5 components. And in tha t limited sense, I was invc1ved 6 deeply in the original authorship of the questions and 7 answers to those questions, again, with discussion from 8 other Staff members. 9 And keep in mind that the comments on some of 10 . these questions and answers through the discussion and 11 review process that we had did result in changes and f a 12 some cases in both questions and the answers and in 13 moving particular points f rom one, answer -- f rom one (_s) A'#' 14 question or one answer to another. 15 So in some cases, the original authorship, I 16 think, may be S little mudd y. Does that help or not? 17 JUDGE BRENNER: Yes, it does. And I'think 18 anybody who has been involved in the proceeding is 19 familiar with the process of drafting testimony. And 20 you have given a very good description of it. 21 And that would be another reason as to why I 22 think Mr. lanpher's request was reasonable, to see if we 23 can get a better handle on it without having to waste a 24 lot of record time going through it, so we know who to 25 ask questions of and who to expect supplemental answers (~)N u ALDERSON REPORTING COMPANY,INC, ! 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
6396 () 1 from on the panel. And I think it will help everybody. 2 Did I cut you off, Dr. Rossi? 3 WITNESS ROSSI. No. 4 BY F.R. LANPHER: (Resuming) 5 Q 'r. Conran, when was the first time you did 6 work on the Shoreham license application ? 7 A (WIINESS CONRAN) To the best of my 8 recollection, I have not worked on the Shoreham 9 application review. I may have reviewed a draft of the
. 10 A-17 unresolved safety issues because I typically do 11 tha t sort of thing for all 5ER sections that come 12 through our branch for a look or review to see if there 13 is some sort of an updat,e because of progress we have O 14 made, that sort of thing.
15 - But I don't remember that specifically. 16 Otherwise, no involvement at all until the assignment to 17 address this Contention from the syst' ems interaction j 18 analysis viewpoint. 19 0 Is the A-17 portion of the Staff SER the only l 20 portion of the SER that you have reviewed? 21 A (WITNESS CONRAN) You don't mean as the 22 responsible reviewer? 23 0 No. I understand the only thing that you may l ( 24 have had actual personal involvement in in the draf ting l 25 in the SER is A-17. I am wondering -- ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
~ 6397 O ' ^ (v1rness cosaan) so- 1 n ve revie ea e === der 2 of sections of th? Shoreham SER since I got this 3 assignment. And specifically, I have looked and 4 reviewed the sections that are referred to as systems 5 interaction-type of requirements: the 6 high-energy-line-break section, flooding, fire 7 protection, that sort of thing. 8 0 Did you review the sections of the SER 9 regarding classification of systems, structures, and 10 components; for instance, section 3.1 or 3.2 of the 11 SER ? 12 A (WITNESS CONRAN) Yes. Not as carefully, but, 13 yes, I have reviewed those sections. 14 0 Have you reviewed any portions of the FSAR, 15 sir? 36 A (WITNESS CONRAN) In the same con text, yess 17 the same sections of the FSAR, I believe, as of the 18 SER. 19 0 So that would be sections dealing with systems 20 interaction and a less thorough review of sections 3.1 21 and 3.27 22 A (WITNESS CONRAN) Tha t 's righ t, the 23 cla ssifica tion tables, also the section on -- well, O cj 24 that's right, the classification table that lists the 25 classification of structures, systems, and components. O ALDERSON REPORTING COMPANY,INC, 400 VIRG. fila AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6398 () 1 Q Did you review Chapter 17 relating to quality 2 assurance?
, 3 A (WITNESS CONRAN) I believe not.
4 Q Is it correct that you have not reviewed the 5 draft Shoreham PRA? 6 A (WITNESS CONRAN) No, I have not. 7 Q Let me ask the whole panel so that we can get 8 it on the records Has any member of the panel reviewed 9 the draf t Shoreham PRA? 10 A (WITNESS SPEIS) No. 11 A (WITNESS BOSSI) No. 12 A (WITNESS HODGES) No. 13 A (WITNESS HAASS) No. (h
'~ 14 A (WITNESS KIRKWOOD) No.
15 JUDGE BRENNER: Do you mean reviewed again in
. 16 the loose sense; that is, have they read it?
17 MR. LANPNER: I was going to follow that up. 18 BY MR. LANPHER: (Resuming) 19 Q M aybe on some of these questions, Mr. Speis, 20 if you are going to be the spokesman sort of for the 21 panel and anyone else should add comments or whatever. 22 But have any of you read the Shoreham PRA? r 23 A (WITNESS SPEIS) It has never been read or 24 reviewed. It has neither been read or reviewed -- if 25 that is the more appropria te answer -- by these panel ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6399 i () 1 members. 2 0 Dr. Rossi? 3 A (WITNESS ROSSI) I was just going to clarify 4 why we added "by these panel members." It is not 5 because we think someone else did; it is because we do 6 not know whether anyone else did. 7 0 You have had a copy of the PRA since late 8 March; correct? March 18, 19827 9 A (WITNESS SPEIS) I am not aware. 10 A (WITNESS CONRAN) Since I was with the 11 Reliability and Risk Assessment Branch, I thought I I 12 could add a comment on that. When it was evident that 13 the Board wished to discuss aspects of the PRA, Shoreham O 14 PRA, in this Contention, and when assiquments were being 15 made to address this Contention, I heard Mr. Thadani, 16 our branch chief, remark that he was not aware of the 17 Shoreham PRA in draft or in final to that point, which 18 was probably 2 months ago. 19 MR. RAWSON: Judge Brenner, the Staf f is happy 20 to stipulate that we have had a copy of the draft PRA 21 tha t was produced in this case since on or about March 22 18th of this year. 23 WITNESS SPEIS: I would like to add one more 24 comments that we don't intend to review the draft PRA. 25 If it is finalized whenever it becomes a complete O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6400 () 1 product, then va will request that it be submitted for 2 review. But we have no plans to review a draft PRA, 3 because we don't know what is the quality of it or what
! 4 is the status of it or whatever.
5 We don't review draft PRAs. If it is 6 submitted officially and it has the approval and the
! 7 stamp of the people who did it or the Applicant or the 8 Licensee, then th a t is another matter. .
9 JUDGE BRENNER: Well, in making that kind of 10 decision, does the Staff take into account the proposed 11 schedule for licensing and licensing hearing and issues 12 admitted into litigation by a board? 13 WITNESS SPEISs The PRA is not going to be
) 14 used as a basis for licensing, as far as the Office of 15 Nuclear Reactor Regulation is concerned and, I think, as 16 far as the Commission itself is concerned. We will 17 ' review it, and if we find that it will provide some
- 18 additional information that would enhance the safety of I
{ 19 the plant, then we will decide what will ba done at tha t 20 time.
- 21 But as far as a review of Shoreham, it plays 22 no role at this point in time.
! 23 JUDGE BRENNER: It is too late in the week now
,f 24 for me to follow up on that point. ,
25 ER. LANPHER: I just wanted to note that I am r O i ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6401 () I going to follow up on this next week. But it is going 2 to be a reasonably lonc line of questions, I think. And 3 rather than start now on that aspect, I do not want you 4 to think that I am not going to follow it up. 5 JUDGE BRENNER: I intend to start one weekend 8 in A relaxed state, so I will let you proceed for now. 7 (Laughter.) 8 WITNESS SPEIS: I would like to request the 9 Board, if they have any questions about the review of 10 the PRA as far as it fits into the lirensing process, to 11 give us some indic'ation now so we can discuss this 12 further with our management on Monday so we can have 13 some reasonable answers on Tuesday. - O 14 JUDGE BRENNERa Well, you have been here for 1 15 the entire litgation, as I have been, or at least had i 18 the transcript available, and you can see where the l 17 issue is going. And I will leave it at that for now. l 18 MR. REIS: Mr. Chairman, I think the Staff has 19 taken, and I think it is evident from the testimony, we , 20 have taken a position that there are other bases to 21 license the plant, and the Staff says we did not review 22 it, we will not review it unless there is some 23 overriding matter that arises. 24 Since then, we say that under Part 50 of t,he 25 regulations there is a regulatory base -- this is te O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 i l
6402 () 1 legal argusant that we are making that underlies our 2 testimony -- that there is a regulatory base to license 3 the plant. And it is just as looking at another diesel 4 generator that is not required for safety, whether that 5 will start in all situations when you know you have six 6 that will start in all situations and all that is 7 required fit rafety. We look in a similar context to 8 that. 9 JUDGE BRENNER: ' Jell, we are just going to 10 proceed with the litigation here. I am not going to 11 respond now. 12 Mr. Reis, I do not know if you have ever read
; 13 our order admitting these' issues, but you might want to 14 take a look at them and subsequent orders. And if there 15 is an issue admittd in litigation, you as a party have 16 to decide whether or not that action is fully consistent
. 17 with what you as a party might have wanted to do
{ 18 originally and whether any adjustments should be made in 19 your approach in the context of the litigation. i 20 And also, we intend to explore through ! 21 witnesses as opposed to legal argument what basis 'here t i 22 is for stating in view of all the work done to date that l 23 nothing would be gained or no purpose would be served by ( 24 examining that material to one extent or another -- 25 obviously, that is a vague pr) position -- but to one ALDERGON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6403 () 1 extent or another, combined with all of the other work 2 that you have done that you are testifying about. 3 MR. REISs Your Honor, we have read your order 4 in this context. We know that there were originally 5 three Contentions along this line admitted. 6 JUDGE BRENNER4 I do not want to go into it 7 too f ar because we are taking up record time, and we 8 only have 5 minutes left. I do not know wh at happened 9 today, but we spent much less time on testimony than I 10 like to spend. If you have been here on other days of 11 the proceeding, you will know that. 12 You have only got 5 minutes, and we do have to 13 stop promptly. Maybe you could continue along the O 14 qualifications line a little more, and then we will 15 stop. 16 Let me add one more thing because Dr. S pe is ' 17 request was fair. It is just difficult to respond to, l 18 particularly in the few minutes we have lef t, and that 1 19 is why I referred to the 3 weeks or 4 weeks or whatever
- 20 it has been of testimony -- and it was not a flippant 21 answer, Dr. Speis -- that there is a lot 'in there, and 22 you should see where it is going.
23 But there is an inference that I have drawn N 24 from the statements of Staff counsel as well as the 25 prefiled tes timony and maybe some of the memos more than ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
f 6404 () 1 the actual testimony. And perhaps I as drawing the 2 wrong inference. Is it the Staff's belief -- 3 WITNESS SPEIS: I would like to say something 4 if -- 0 JUDGE BRENNER: Let me just finish my 6 thought. Is it the Staff 's belief that there would be 7 very little help to the Staff in looking at the PRA at 8 all, as I say, to some extent, because it would not have 9 treated systems interactions very well, if at all? 10 And that is certainly very contrary to tha 11 testimony of LILCO's witnesses, who are, rela tive to the 12 people on this panel, very familiar with what is in the 13 PRA. And it occurs to me that it might lend more weight O 14 to your position if you knew a little bit of what was in t 15 the PRA without necessarily whether or not it is a legal i 16 requirement. That is in the context of joining issue on 17 this Contention in this proceeding. 18 And I throw that out now in response to your 19 request that maybe you would like something to chew on. 20 WITNESS SPEIS: Let me respond to your i i 21 specific question. We will reviev the PRA when it is 22 final, when it has been CA'd by the Licensee. I don 't 23 know when they will be ready to send it to us to give it N 24 to us. I think that question has been raised the last 25 few days or weeks, when it will be docketed. I don't O ALDERSON REPORTING CO'APANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6405 () 1 remember if I heard an answer to that. 2 JUDGE BRENNER: " Jell, my point is we have got 3 a litigation that has been going on and is going on, and 4 sometimes the normal procedure that the Staff might like 5 to apply does not fit when it is also going on in the 6 litigation. 7 And if you are going to assist us in resolving 8 .this issue here today -- and tha t "toda y" is in the 9 broad sense -- it may be too late by the time you 10 normally would have been prepared to do it. And there 11 may be a difference between looking at it preliminarily 12 as a preliminary document to assist in joining issue on 13 what we are litigating as distinguished from a more * (~h
'~#
14 thorough review later. And, of course, some support for 15 the position th a t you would look a t it later, which in 18 the absence of any view of the Staff that the plant 17 should not be licensed until then would, in your view, 18 be after licensing. 19 We vill be exploring through the questions on 20 your testimony as to why it is okay to totally put off 21 any examination until then from the standpoint of 22 systems interaction and classification of systems and l 23 the Staff's methodology. There are a lot of other
/~T 24
(_J' things that PRA,might be related to, but we are not 25 dealing with that. O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6406 () 1 I do not know if that helps at all. I thought 2 your question was a fair one, Dr. Speis. A nd that is
^
- 3 why I tried to give some quick answer. It might be that 4 after there is time to consider it, somebody with the 5 technical background of the other Board members and 6 Judge Jordan could have given you better guidance. But 7 I think it is late in the day for us to be giving you 8 that kind of guidance on it. And that is part of my 9 point.
10 WITNESS SPEISa The only thing I can tell you 11 is that in reviewing a draf t PR A, it takes resources, l 12 and I am not in a position to tell you righ t now if we j 13 should review the draft PRA or not. I will have , 14 something to say to that on this subject next Tuesday, 1 15 because I am not in a position to assign resources. So 16 I had better check with my management. l 17 JUDGE BRENNER: What I tried to make clear is 1 18 there are reviews and then there are reviews, and what 19 might be a sufficient inquiry to assist us in deciding 20 this issue might be different than' the conduct of a 21 full-blown re iew you would do otherwise. 22 And I was afraid -- and one inference I drew 23 was that it had to be an all-or-nothing situation, from ~ 24 commen,ts I have heard from different people over the
! 25 week. And I do not k'now if that is the case. And I O , ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
6407 () 1 would add that I sm somewha t surprised that none of the 2 panel members has even read the PR A a little. I mean 3 even I got a little curious and took a peek. ("] V 4 WITNESS SPEIS Jim Conran will add a few more 5 comments to what I have said. 6 WITNESS CONR AN s To avoid the appearsnce of 7 being totally unresponsive, Judge Brenner, I think f rom 8 another viewpoint the Staff is sort of a victim of 9 circumstances in this regard. s 10 As a matter of po. icy, the management of our 11 oroanization has emphasized that there being no 12 requirement for PR A -- and I was prepared to discuss at 13 some length some investigations that we 1,n systems. (~)
'~" 14 interaction have done regarding the PRA systems 15 interaction interface, which we believe would further 16 indicate the lack of usefulness of a PRA in this sort of 17 a licensing proceeding.
18 We were and are willing and ready to talk 19 about that aspect of things. But having the management 20 having made these decisions, the allocation of resources 21 is such tha t the Shoreham PBA simply wasn't scheduled 22 for review. 23 Having become aware of the Contention in this 24 hearing, the organization responded that they would, of 25 course, review it, but we point out in our testimony l ALDERSON REPORTING COMP /NY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6408 () 1 that to do justice to a PRA takes such a long interval 2 of time and expenditure of resources that it is probably 3 not compatible with the schedule of the hearing anyway. 4 But the idea was to the extent that we could 5 help, to the extent that we have explored the interface 6 between PRA and systems interaction, we were willing to 7 try to offer testimony and whatever insights we could 8 help the Board with in that regard. 9 JUDGE BRENNER Well, that kind of testimony 10 certainly will be very helpful, and I am sure we will be 11 exploring that also. But it is a matter of when we go 12 back later and go back through the record, sometimes you 13 have conflicting views and we have to determine what O 14 weight to give to the different views. I 15 And I would just suggest the possibility that 16 when you are comparing views of people who are very 17 familiar with what is in the PB A as distinguished f rom 18 views of people who may be able to talk about PRA 19 approaches in general or in past years or other PRAs, l l 20 but cannot say what is in the PRA under litigation, then 21 tha t might affect the weight. 22 And it was in that context that I made some of 23 my remarks. And I have no idea technically if it is ( ), 24 feasible to do enough of a quick look, so to speak, to 25 determine whether or not based on that look you continue O l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
6409 (,) (_ 1 to disagree with LILCO's witnesses that systems 2 interaction is treated in an approved fashion and it has 3 worked to date or in a good f ashion that complements the ('} 9 4 other approach or is not treated any better or sny 5 differently or at all. 6 And it seemc to me one possibility perhaps -- 7 not the exclusive one, certainly not the exclusive one 8 -- but one possibility to support that view and 9 complement the other testimony that you just in dica ted 10 you were prepared to give would be that sort of 11 preliminary look. 12 And it has been available for a number of 13 months. And that is all. I am.certainly not telling i~'# 14 the Staff what to do. And we have to put the record 15 together later. 16 WITNEiS CONRANs May I add a couple of 17 comments in that regard, Judge Brenner? Having listened 18 to the testimony and the very detailed description by 19 Applicant's witnesses for the last couple of weeks, I 20 naturally have been concerned about what the Board's 21 reaction would be when push finslly came to shove like 22 this and we were expected to talk about the FRA and were 23 not prepared to do so. 24 And so I have talked to my management about 25 this and described to them the considerable amount of O ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
6410 (_) 1 detail in which the PRA was being discussed here in a 2 very expert fashion. My very strong impression is that 3 the, judgment was that any quick look that the Staff 4 could take with however qualified a PBA expert on that 5 Staff just couldn't add much from the positive 6 viewpoint. 7 On the other hand, the explorations of the PB A 8 systems interaction interfaces we have done and the 9 Staff position which is forming now on that question, 10 how useful the PRA is in the licensing process, includes 11 as a critical element the judgment that current PRAs do 12 r4 ot adequately treat the dependent failures, that there 13 are very large uncertainties. 14 And that as bad as it may sound in a hearing 15 like th i s , it seemed like the only way that we could 16 contribute to the Board's perspective on the question 17 tha t they were obviously interested in was in a negative
. 18 fashion.
19 But we couldn 't do much in a positive f ashion 20 because we couldn't hope to compete with the sort of 21 individuals who are here testifying on behalf of the 22 merits of the FRA, the Shoreham PRA. 23 On the other hand, the results of
) 24 investications that started out from a different 25 viewpoint have almost reached the culmination that one ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
6411 () 1 resson that we introduced the letter of the ACRS was 2 that the Staff's views, when they finally do hit the 3 street, so to speak, it is not likely that they will be 4 much different than that. 5 And so from that viewpoint, we were prepared 6 to offer testimony to help the Board sort out whatever 7 questions it had in its mind, whatever interest it had 8 in this regard. , 9 MR. REISs Mr. Chairman. 10 JUDGE BRENNER We do need to adjourn quickly, 11 because we do have a severe time problem ge tting 12 somewhere. 13 MR..REIS: The only thing I would add to that k 14 is one sentences that in taking that position and 15 looking at i t, we felt that our SER was supported and 16 thst there was another basis to license the plant. , l 17 JUDGE BRENNER: I do not have anything to 18 add. You can see where findings may have to be written 19 and where there might be furtherr support or there might 20 be a difference in the way to d escribe the support for 21 the view that PRA-type analyses do not treat 22 dependencies very well, whether that is based on looking i 23 at other things or also includes some look at the PRA 24 under consideration here, particularly in view of the l 25 testimony by witnesses familiar wi th the other work, who l O ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 t
6412 O i to eome extent recogni=e defects in other work end 2 testified quite strongly, I would submit, as to what 3 they think is in their work on that score. 4 I will leave it a t that, and we can use all of 5 the help we can get. And in some stess we have gotten 6 more help and in some areas we have gotten less help. 7 And if the Staf f would like to see its view supported in 8 s decision and would not like to see the other view 9 supported in a decision, it should consider where it '. 10 thinks we need more help in support of its view. 11 WITNESS CONRAN That wa s precisely the intent 12 or the thrust of our intended testimony, Judge Brenner.
, 13 -
JUDGE BRENNER: We are going to have to Q 14 adjourn in order to get going. We will reconvene at 15 10:30 on Tuesday in this room. 16 (Thereupon, at 2s40 p.m., the hearing in the 17 above-entitled matter was adjourned, to reconvene at 18 10:30 a.m. on Tuesday, July 13, 1982.) 19 20 21 22 23 O) Q 24 25 O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
l l l NUCLEAR REGULATORT COMMISSICN This is to certify that the attached proceedings before che BEFORE THE ATOMIC SAFETY & LICENSING BOARD
- in the :: atter of:. Long Island Lighting Company (Shoreham Nuclear Power station)
Da.te of Proceeding: <Tulv 9. 1982 i Docket s llu::ther: 50-322 OL Place of Proceeding: Riverhead, New York were held as herein appears, and that this is che original transcript thereof for the file of the Commission., - l Ray Heer i Official Esporter (Typed) e 8
- no
'Officia M eporter (Signature) 1 i
l - t v I o. _}}