ML20078L618
| ML20078L618 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/11/1983 |
| From: | Birch M DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240014 | |
| Download: ML20078L618 (126) | |
Text
e 7
i UNITED STATES OF AMERICA NUCLEAR REGULATORY CO!GIISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN RE: )
)
PUKE POUER COMPANY, et al. ) Docket Numbers l[ Catawba Nuclear Station, ) 50-413 Units 1 and 23 ) 50-414
. May 11, 1983 9:00 A.M.
I 1
DEPOSITION OF: l l
MARY BIRCH l l
kojo Ofjl4830810 l AHLERS83-434 PDR 1
Eveli n llerger Associates #%
STENOTYPE REPORTING SERVICE P. O. B OX 19444 CHARLOTTE. NORTH CAROLIN A 28259
L A W Y E R'S NOTES 7 ,
Page Line I
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0
I 2
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APPEATGNCES:
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2 p;3337 ogyng, ggggyng Charlec on, South Ccrolina 3 .
Counsel on Bchalf of Intervenor Palmetto Alliance, 4 Incorporated 5
DEBEVOISE & LIBER'AN, ESQUIRES Washington, D. C.
By: J. MICHAEL McGARRY, III, ESOUIRE, and 6 ;RNE W. COTTINGHAM 7 ALBERT V. CARR, JR., ESOUIRE RONALD L. GIBSON, ESQUIRE 8 Charlotte, North Carolina g . Counsel on Behcif of Applicant Duke Power Company 10 11 ALSO PRESENT:
12 Roger W. Ouellette
, Duke Power Cor.pany 2'
13 Michael F. Lowo Director I4 '
Palmetto Alliance, Incorporated 15 Lee Ann Kornegay Electronic Recordor 16 Palmetto Alliance, Incorporated 17 Id ILDEX 19 Witness Direct Croce Redirect Rec ro is 20 Mary Birch 9 -- -- --
21 22 23 h
24 25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING $ERVCE. CHARLOTTE. NORTH CAROUNA
< 3 3 'The Dcposition of Mary Lirch is taken at the offices 2 cf Duke Pctrer Cenpany, Charlotte,IIorth Carolina, on this the 3 lith day of !'.cy, ,1983, in the presence of Robert Guild, I.ttorner 4 for the Interven Fairctto Alliance, Incorporated; J. Michael 5 I'cGarry, Anne W. Cottinghan, Albert V. Carr, and Ronald L. Gibso n, 6 Attorneys on Behalf of the ApplicEnt Duke Power Conpany.
7 It is agreed that Lynn B. Gillian, I!otary Public in 3 and for the State of !!crth Carolina, at large, nay take said 9 Deposition in nachine shorthand and tranceribe the sane to type-in writing.
s 13 MR. GUILD: I! allo, Tirs. Birch. !!y nane is Robert Guild ,
12 G-U-I-L-D. I an Councol for Palnctto Alliance, the Intervenor 33 in this licensing procedure for.the Catawba Station.
14 I underctand you have been designo.ted by Duke Pouer 15 Cenpany as the persen recponding to Discovery requests by ny 16 client and the percen who hat subject natter knowledge of a 17 Centention we have filed in the case. Is that right?
me 18 MRS. BIRCH: Which Contention?
ig MR. GUILD: Are you the person they have asked to be 20 availabic for questioning this norning?
21 ! IRS. BIRCH: Yes.
22 MR. GUILD: D e Contention has been numbered 27, and "
23 ycu have recponded to conc Interrop,ateries and requente for pro-24 duction with recrect to that Contention.
25 IC. Mc0ARRY: I would like to diccuss first the EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOfrTM CAROUNA 1
4 1 Stipulatien that I would like to reLd into the Record, the Etip-1 2 ulation which uill be signcd at a later date. This is s. Stipule-a tion as to the ne.thcd of taking and use of Depocitiens purcuant 4 to the Ectrd's cbcervs.tions with : espect to Depositiens by non-5 stenographic neans.
6 A nencrEndun and order of Februtry 2,1983, Page 12, 7 Duke Power Conpany, et al. , Applicants ; the :iuclear Regulatory 8 Concission Staff, and Palnetto A111cnce, hereby reach the follow -
9 ing cgreencnt with respect to the nanner and nethod by which 10 Palnetto Alliance will proceed with the taking of Depositions 11 frcm certain of Applicants' enployees in this proceeding:
12 "One, The parties agree thLt Palnetto Alliance n.ay reccrd 13 the Deposition of certain of Applicants' enployees by use of a 14 ts.pe recorder. Painetto Alliance will lodge the original tape 15 recording with the preciding Atonic Safety and Licensing Botrd."
16 "ParagrLph Two, The parties understand that Palmetto 17 Alliance desires to take the referenced Depositions for Discovery 18 purposes only. Therefore, the pc.rties agree thct Palmetto Alliance-19 is not obligated to furnish a transcript of such Depositions 20 either to the Staff or to the presiding Atonic Sa.foty and Licenc ing 21 Board."
22 "Three,1:otwithstEnding the feregoing Paragrcph Two, th e 23 parties agree that, should Pcinctto I.llitnco deciro to use any 24 Deposition, or part thereof, of any cnployce of Applict.nt for 25 cny evidenc iary purpose in this proceeding, the following steps EVELYN BE RGER ASSOCIATES. STENOTYPE REPO8tTING $ERVICE. CMARLOTTE. NOprTM CAROLfMA
- 5 1 aill apply: (A) Palmetto Alliance will provide the Applicants 2 ,
rith timely Notice of its intent to use any Euch Depositions 3 {but in no event Iater than li5 days prior to the scheduled 4 semmencement of Hearings in this procedure); (3) The parties 5 c . gree that the tianscript of the Deposition taken stenographically G by Applicants should represent the official transcript of the 7 Deposition."
8 And this is the footnote, "In the event Palmetto 9 Alliance chooses to utilice a transcript of its tape recording 10 of the Deposition for any evidentiary purpose in lieu of the 11 cfficial transcript, as provided for in Paragraph 3(B), the 12 folicwing steps would be taken:
13
"(a) Prior to the Nctice in Paragraph 3(A) of the text, 14 ?almetto Alliance will cause to be transcribed, at its sole 15 expense, the relevant Deposition in its entirety.-
16
"(b) At the time of the Notice in Paragraph 3(A),of 17 the text, Palmetto Alliance will forward such transcription to 18 Counsel for Applicants;'
19
"(c) Counsel for Applicants will forward such trans-20 The Deponent will review the transcript cription to the Deponent.
21 md, after making any necessary changes, will certify that the 22 :ranscription is a true and correct ecpy of his or her Depcoitic:t."
23 Now going back to the text we have Item "C", and "C" 24 reads as follows: " Palmetto Alliance will file, at its sole 25 expense , a copy of the Deposition with the Board." And that is EVELYN BE RGER ASSOCIATES. STENOTYPE REPORTING SE RytCE. CHARLOTTE. NORTM CAROLINA
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6 I :he end of "C".
2 Nou coing back into the main body, continuing in the 3 <
- ain body: "The parties agree that, unless Palmatto Alliance 4 :ceplies with this Paragraph Palmetto Alliance will be barred 5 Tr0m using any or all of any Deposit 1cns for evidentiary purpose 6 in this proceeding.
7 " Paragraph Four, the parties agree ths.t Applicants will 8 have present at cach Deposition of its employees taken by Palmetto 9 Alliance a certified Court Reporter, who will euear the Deponent 10 and transcribe the Deposition. It is understood by the parties 11 that Applier.nts will bear the entire cost of such Court Reportere 12 " Paragraph Five, It is Applicants position that Palmetto 13 Alliance, if it desires any or all of such Depositions transcribed 14 by the Court Reporter, should take arrangements to obtain such 15 :iirectly from the Court Reporter; and that Palmetto Alliance has 16 ao other right to request under applicable Discovery regulations 17 af the NRC, a copy of any or all of any pa:-t of any Deposition 18 branscribed at Applicants' er. pense. Palmetto Alliance disagrees <
19 " Paragraph bi* , the parties agree that should there be 20
- t conflict betucen any or all of any Deposition recorded by Palmetto 21 Alliance, whether or not transcribed by Palnetto Allitnce, and ar.y 22 or all of any Depositiens transcribed by the Court Reportcr, the 23 .crsion transcribed by the Court Reporter shall centrol.
24 " Paragraph Sven, the parties agree that upcn its execu-25 Sion this Stipulation shall be submitted promptly to the Licensir,g r
EVELYN BENGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAmouNA
7 1 Board with a joint notion urging its adoption by the Board. n 2 That is the end of the Stipulation.
3 For the -Record, this Stipulation will be typed and 4 signed today. I would note for the Record in this Deposition 5 this Stipulation will apply to all Depositions taken by Palmetto 6 Alliance with respect to Applicants' witnesses.
7 I have three other comments I would like to make for 8 the Record. I would like the Record to reflect that Notice 9 of Deposition was served upon Mary Birch. However, the Applicants 10 did receive a telephone communication from Mr. Guild asking that 11 Duke Power Company and the Applicants make available one knew-12 ledgabic witness with respect to Contention 27 13 As an accommodation to Palmetto Alliance we have made 14 Mary Birch available.
15 One last item, in telephone communications with Mr.
16 Guild, Applicants were asked that Mary Birch bring to the Deposi -
17 tion Documents that relate to Contention 27 The Documents that 18 relate to Contention 27 are held in the Discovery Room which is 19 about 20 paces from the office that we are now taking this 20 Deposition in.
21 It is Applicants' position that if Palmetto Alliance 22 wishes to have those Documents which are available to them todaf, 23 they merely have to Go those 20 steps, cet those Documents they 24 believe are relevant to this Deposition, bring them to this roen 25 and inquire of those Documents to Mrs . Mary Birch.
EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE, CHARLOTTE. NORTM CAROLINA
8 1 MR. GUILD: If we can note for the Record, the identities 2 and affiliatio:1s of all of the rest of those present in the room; 3 My name is Robert Guild, Counsel for Palmetto Alliance.
4 MR. McGARRY: I am Michael McGarry, I an serving as 5 Counsel with Applicants Duke Power Company, et al.
6 MR. CARR: I am Albert Carr, serving as Counsel for the 7 Applicants Duke Power, et al.
8 MR. GIBSO!!: I an Ron Gibsen, serving as Counsel for 9 the Applicants Duke Pcwer, et al. -
4 10 MS. COF2INGHAM: I am Anne Cottingham, serving as Coun: el 11 for the Applicants, Duke Power Company, et al.
12 ER. OUELLETTE: Roger Ouellette, I am an employee of 13 Duke Power in their Licensing Section.
14 MR. McGARRY: One thing, I would like the Record to 15 reflect Palmetto Alliance's agreement as to the Stipulation that 16 uns read into the Record.
17 MR. GUILD: Yes, that's correct. Ms. Birch, would 18 you identify yourself again?
19 MS. BIRCH: My name is Mary Birch, employee of Duke 20 Power Company.
21 MS. KORNEGAY: I an Lee Ann Kornegay, Recording for 22 Palmetto Alliance.
23 MR. LOWE: I an Michael Lowe, Director of Palmetto 24 Alliance.
2T)
EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTH CAROUNA
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Birch - Direct - 9 1
MARY BIRCH,
\
2 having been first duly sworn to tell the truth, was examined 3 and testified as follows:
4 5 DIRECT EXAMINATION 6 BY MR. GUILD:
7 4 Ms. Birch, I show you a copy of a letter so we have a clear the nature of the discussions leading to this letter, thin 9 recites essentially the information that you just related concern-10 ing the agreement as 'to the holding of this Deposition as offered; 11 and if ycu would, I would ask that a copy of this be appended tc 12 this Depositien either as an Exhibit or Attachment.
13 MR. McGARRY: I would note that the letter that 14 you make reference to is, indeed, a copy of a letter 15 that I sent you on May 5, 1983, which does indeed refle ct 16 the nature of cur telephone conversaticns, copies of wh ich 17 were furnished to the Board and on the parties.
18 MR. GUILD: Yes.
la MR. McGARRY: I would make one further observatior .,
20 there have been some changes in the changes ref: cted 21 on Page Two, and we can get into the particulars of 22 those matters when we take the Depositions of those 23 individuals.
24 MR. GUILD: Yes, I don't see any need to go into 25 that detail if we are ready to proceed. Anything else, EVELYN BERGER ASSOCMTES. STENOTYPE REPORTING SE RylCE. CHARLOTTE, NORTM CAROUNA
Birch - Direct 10 I preliminary matters, Counsel?
2 MR. McGARRY: No.
3 -
4 EY MR. GUILD:
5 Q Ms. Eirch, the purpose of this Zepositicn is te cather 6 infcrmation of interest to Palmetto Alliance concerning its 7 Cententien Number 27 as indicated in this proceeding, and as a I asked you before we diccussed these other Stipulations, you 9 have been responsible for preparink scme of Duke Power Company's io responses to Discovery Requests on that subject; is that correct ?
11 A That's correct.
12 4 I want to show you a Document that is entitled "Applicsntsi 13 Responses to Palnetto Alliance's Second Sst of Interrogatories 14 and Request to Produce," dated September 22, 1982. I would ask 15 you to examine that Document. On Page Five, at first, Counsel, le we agree thic is the recument, we can ask if it be anthenticated?
17 MR. McGARRY: Yes, this is the Response to the 18 Second Set of Interrogatories dated September 22, 1982.
19 20 EY MR. GUILD:
21 C Mrs. Eirch, I ask you to turn ycur attention to Page Five, 22 and there beginning at the bottem is set fcrth in ycur Response 23 the text of Contention 27, tnd I would ash if you would, for the 24 Record, read that Contention out loud, please, Ma'am.
25 A "The Applicr.nts should be required to place real time EVELYN bERGE R .SOCIATES. STENOTYPE PEPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
r Birch - Diract v 11 I monitors capable of reading gamma radiation levels around the 2 site in order to provide emergency cperations personnel with 3 the information required to make decisions necessary to reasonably 4 assure the health and safety of the public under nenditionn of 5 radiological release to the environment."
6 Q And read this Centention also, please.
7 A "Thermoluminescent dosimeters are only accurate within 8 plus or minus 30 percents and only provide a post-hoc assessment 9 of conditiens."
10 4 You were aware of that text before today?
11 A Yes.
12 4 You have seen that before?
13 A Yes.
14 4 Now at the back of that Response is a Document that 15 is entitled " Affidavit" and it appears to be your Affidavit 16 (indicating). Can you identify that signature?
17 A That is my signature.
18 MR. GUILD: Counsel, can I ask, I have two other
! 19 Responses and if we could Stipulate that Mrs. Birch 20 likewise participated in the preparation of both those, 21 and if I show them her Rosponse would be the sano?
t 22 MR. Mc0ARRY: Yes, February 28, 1983; and March 23 25, 1983; and ue would so acknowledge that Mary Birch, 24 indeed, did provide answers to Interrogatories and that 25 an Affidavit to that effect signed by her is containe' i
l EvrLvm esRosR Associares. sTrNorvra MacORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Birch - Direct 12 1 in those two Documents.
2 3 BY MR. GUILD: ..
4 4 Mc. Birch, if at any point I spcak too quickly plence 5 stop ce. I nean we can relax a little bit and be a little less 6 fornal about thic. I will ask you a series of questions and if you don't understand any of the words I use or I an not speak-7 8 ing clearly, please stop and ask for clarificaticn. Otherwise 9 I will presume that you do understand the question.
10 Would you please identify the nature of your werk for 11 Duke Power COnpany?
12 A At the present time I an responsible for Radioactive 13 Waste Management, Radwaste.
14 4 Would you cpell that?
15 A R-A-D-W-A-S-T-E.
16 4 Thic includes being responsibic for leading and direct -
17 ing Statiens in the operation of Radweste equipment to do volume 18 induction effr.:ent releases, radiation nonitoring; and Uhat is 19 your fornal title 7 20 A Assistant Radwaste Enginecr.
21 4 Hou icng have you held that pecitien?
22 L Since August of last year, 23 4 Tnat vould be August, 19827 24 4 ye3, 25 4 And to what office of the Conpany are ycu accicned; EbELYN BERGER ASSOCIATES, STENOTYPE RE PORTING SERvert. CMARLOTTE NORTM CAROUNA
Birch - Diract ,
13 1 do you ucrk here in Charlotte?
2 A Yes, in the General Officer.
3 4 If you c.ould, Mrs. Birch, briefly give us a resume' 4 of your job er.perience in the relevant field before and includirg 5 your po:itions with Duke Power.
6 A Prior to being As 1stant Radwnste Engineer I was the 7 Henith Physicist re:ponsible for Radioactive Waste Management, 8 clightly different.enphasis. Prior to that I was a Health 9 Physicist in charge of the Programs.and Procedure Functions.
10 Prior to that I was Assistant Ecalth Physicist with .
11 no particular ascignment function. That takes me from 1972 12 through the present. Prior to that in 1968 to '72 I werked for 13 the State of Wisconsin Radiation Protection Section as a Chemisf 14 responcible for performing analysis for the Nucienr Power Plant, 15 Prior to that I was in school.
16 4 Mrs. Birch would you briefly relate your professional' 17 training, academic training?
18 A I have an Undergraduate Degree frcm the University 19 of Wisconsin, Bachelor of Science and Chemistry, received in i
i 20 '78, January. I have a Degree from the University of Wisconsin 21 and I am a Beard Certified Health Physicist and I am also a i
22 Registered Professicnal Engineer. -
23 Q Uho with Duke Power Cc=pany, Mrc. Birch, is primarily 24 renpensible for designing and impicmonting a system for radiati on 25 monitoring fer its Nuclear Pouer Plants?
EWELYN SERGER AS$0CIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
Birch - Dirset 14 1
A Emerccncy Response would be the responsibility of our 2 Crisis Management Coordinator. But there a number of peopic that 3 are involved. ..
4 MR. McGARRY: May I interupt, I'm not sure the 5 Witness understood the question. Was the question who 6 was responsible for designing the system at Duke Power 7 Company?
g MR. GUILD: Yes, let r.e rephrase, Mrs. Birch.
9 I
10 SY MR. GUILD:
11 Q Part of the system that you have deceribed in Response 12 to your Interrogatories involved menitoring radiation releases 13 in the event of a serious accident at one of the Company's 14 facilities; is that correct?
15 A W.at's correct.
16 Q And someone with the Company designs and is responsible 17 for implementation of procedures for the use of that monitoring is equipment. I am trying to understand who that person would be.
19 A Procedures for the use of the equipment?
20 Q First of all, who is responsible for having designed 21 the system of monitoring; and secondly, who was responsiblo for 22 the implenentation of the system for using those r.onitors?
23 A Okay, we have a department which does do design work.
24 Criteria to establich what they design is catablished by the 2a Operating Department.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE. NORTM CAROLINA
Birch - Direc0 . 15 1 C Phat has ycur role been in that decision, Ms. E.irch?
2 A I may go ahsad and cr.tablich the criteria, I am one 3 cf severn1 indivi. duals who har input into establishing the 4 criteria.
5 Q Who are the others?
6 A Lionel Lewis, L-E-W-I-S.
7 4 Does he work for you or do you work for him?
8 A I did work for him until last August.
9 4 Who clso, Ms. Birch? -
10 A I'm not sure of the individuals in the Design Departmer,t 11 who might have input.
12 4 How would "r. Lewis's role and yours differ with respect
. 13 to designing the systems to be enployed at the Catsuba facility?
14 A Differences in different types of Radiation Monitoring 15 Systems.
16 4 Explain that.
17 A Effluents , Release Monitors and some of the Process 18 Monitors arc my re::ponsibility. Area Radiation Monitoring Systems 19 are in his area of responsibility.
20 4 And can you help us understand what tha differences 21 between those respective areas ~are?
22 A What do the conitors do? >
23 4 Yes.
24 A Area Radiation Monitors would be the monitors within 25 the plant that determine dulcinetric locations within the aur.11 atry EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERYlCE. CHAR.OTTE. NORTH CAROLINA
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Birch - Direct 16 I b'uildings and container buildings. The cffluent ronitorc are 2 en relcare ocints frcn the Station Precers Monitors. Endiation 3 -Monitors arc en particultr ctreats where you wish to control 4 the procots.
5 4 Cive ne an extmple of a Process Monitor.
6 A. Reactor Coolant Monitor.
7 4 Give me an example of a Release Monitor.
s A Licuid Discharge Monitor.
9 4 Typically. fcr Catawba where would that be?
10 A On the Release Pipe from the Station to the Discharge 11 Area.
12 4 Can you be more precise about its location?
13 A Nct without looking at a drawing.
14 Q At that point, Ms. Dirch, let's see where we might i
15 look to find that. Would it be decided in the final release j 16 point for the Station?
17 A Yes, and it would have a column designation for location 18 where that is located.
19 4 Can I show you this Interrogatory? Would that help you?
l 20 A I don't believe that was identified in the Interrogatory.
l 21 4 Do you know then?
22 A If I had the FSAR I could show you.
l 23 MR. GUILD: Counsel will help the Witncsc, if he 24 would.
25 THE WITNESS: It is in Section 11.
EbFLYN SERGER ASSOCIATE S. STENOTYPE REPORTING $ERylCE, CHARLOTTE. NORTH CAROUNA L _.
Birch ~ Direct .. 17
. 1.
I BY !!R. GUILD:
2 4 I'm htnding the Witness the Responses dated March 25, 3 1983 .-
4 A Uc did not address liquids.
5 4 Uculd that same Document, the final Safety Analysis ,
6 reflect those liquid and airborne' release Doints?
7 A Yes.
8 MR. GUILD: Ccunsel, I would like to obtain a 9
pcrtien of that part of the FSAS so that the Witness 10 can respond to it.
11 MR. McGARRY: The FSAR is in the Discovery Rocm, 12 and I think we stated our position at the beginning 13 of this Deposition that. you are welcome to go to that 14 Discovery Room, get the Docunents that you wish to 15 pursue further and ask the Witness questions.
16 MR. GUILD: Then it will be necessary for us to 17 Adjourn the Deposition in order to do that. Could I 18 ask if one of my associates can go to that Discovery 19 Room and I can ask that they retrieve that portion, if 20 we can have a time now, what time we e.re Adjourning the 21 Deposition?
22 It is five to ten and the Deposition will be 23 Adjourned.
24 (Whereupon the Depcsitien was Adjourned for a brie f 3 Recess,after which the following proceedings were had:)
EVELYN BERGER ASSOCIATES. STE'v0 TYPE REPORTING SERYtCE. CHARLOTTE. NORTH CAROLINA x
- ni mh - Divect 18 1 MR. Ik,0ARRY: We are back on the Record; I uould 2 likc the Record to reflect the tir.e, what time is it?
3 THE UITNESS: Ten o' clock.
4 MR. McGARRY: Just so uc are all clear on how much
.5 tine was involved, it took Palmetto to go to the Discovery 6 Roca, that was a minute and a-half. Palnetto Alliance 7 did come back with the Documents which did appear to 8 be all those Documents that pertained to Contention 27.
9 In lieu of the Applicants producing
. MR. GUILD:
10 for the Witness these Docur.ents, I have gone to the 11 Decument Rocn and retrieved all of the Documents that 12 are indicated by the Applicants pii,- as reflective cf their responces to our' Discovery on Contention 27 I3 I4 I would ack the Witness to go through the stack 15 and identify what has been nade avc11able.
16 MR. McGARRY: I would like the Record to reflect II cnc more thing, abcent the Notice of the Deposition 18 uhich did not identify, by virtue there was no Notice, 19 uhat Docunents that the Witness should bring,we.did ^
acknowledge to Mr. Guild the Documents would be avail-oo 91 able. They are available in the Dopocition Room and v a 22 would htye anticipated that Mr. Guild uculd have gone 93
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through and examined that ctack as to d.-tcrnine the o4 Documents that he uished to Depoce the Witncsc upon.
25 If it ends up that he uiches to Depose the Witnes 3 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROLINA i
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Birch - Direct .. 19 I with rerpect to every Docurent that the Witness will 2-identify, cobeit.
3 ..
4 3Y MR. GUILD:
5 C So we h. ave a clear understanding of what is available, 6 ?ead the Documents.
7 A I have a Catawba FSAR Final Safety Analysis Peport, g 'olumes I One and Tec1ve. I have FEMA-Rep-2, " Guidance on Off-9 Site Enercency Padiation Measurenent. Systens, Phase One --
in Airbcrne Release."
I have " Branch Technical Position," Revision One, 11 12
?ievenber 1079, en Regulatory Guide !!.8, Environnental Technical Specifications for Muclear Power Plants. A Table and Laboratory 33 14 Equipment, McGuire FSAR; Crisis Management Plan, Implementing 15 Procedures, 5 3 14 93 Q Can I ack you to relate to that a specific Station?
I
- 17 A That is systen-wide in a ten-mile radius of McGuire
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I n3 Nuclear Station. Centention 27, ONS Energency Plan, " Procedure i 19 for Environnental Surv'e111ance Following a Large Unplanned Release 20 of Gaseous Radioactivity."
21 Q Does that relate to a specific Station?
I "cGuire's Health Physics Manuni Section re-22 A Oconee.
23 lating to environnental tenitorinc for energency conditions; i
24 Cricis Management Plan, Inplenentation Procedure 3 15, Duke Powe r y; Company; Energency Plan for Performance, Testing and Procedural EVELYN BERGE R ASSvCIATES. STENOTYPE REPORTING SERVICE, CMARLOTTE. NORTM CAROUNA
Birch - Diract 20 1
Specifications for Ther=oluminescent Dosimstry, Environmental 2 Applications of Gaseous Activity. This is the Catawba Nuclear 3 Station Emergency. Plan dated August 1980, Revision of December 4 '81, NCREG.
5 4 Excuse.ne, I believe there is a note attached; is there 6 a more recent Revision?
7 MR. McGARRY: The note is superceded by the Revision 8 on 2/22/83 9
10 BY MR. GUILD:
11 Q Is that Revision in front of you, Ms. Birch; can you 12 tell?
13 A. No.
14 4 Will you proceed then?
15 A NUREG/CR2644, an Assessment of Off-Site, Real-time I
16 Dose Measurement Systems for Emergency Situations, Oconee. ,
I 17 Next is instrumentation and health physics, " Safety Evaluation is By The Directorate of Licensing, U. S. Atomic Energy Commission ,
19 in the matter of Duke Power Company, Oconee Nacicar Station, 20 Units 2 and 3."
l 21 MR. McGARRY: I would like the Record to reflect 22 the date of that Document in December 29, 1970. .
23 THE WITNESS: AIF/NESP-023, " Evaluation of an 24 Environs Exposure Rate Monitoring Systen for Pont-Acci -
25 dont Assessment." It is a NESP Study Guide.
l tvrtvm eracun associares. sTruorrer nape =Timo stavice. cHaatoTTs. no=Tw camouma
Birch - D2 rect . 21 1
BY MR. GUILD:
2 4 What does that stand for?
3 A National Environmental Studies Proj ect. " Safety 4 Evaluation by the Directorate in the' matter of Duke Power Cenpa:ty, 5 Oconee Nuclear Station, Units 2 and 3, Docket numbers 50-270/281 ;
6 July 6, 1973 NUREG 0654, " Criteria for Preparatien and Evalua-7 tion of Radiological Emergency Response Plans and Preparedness g in Support of Nuclear Power Plants."
9 Regulatory Guide 4.13, " Performance, Testing and Pro-to cedural Specifications for Thermo3nminescent- Dosimetry: Envircn-11 mental Applications . " Regulatory Guide 1.97, Rev 2, I didn't 12 notice the Rev en that; that one was Rev 1.
13 Q The last is Rev 17 14 A Yes. Regulatory Guide 1 97, " Instrumentation for Licht -
15 Water-Cooled Nuclear Power Plants to Assess Plant and Environs 16 Condition during and Following an Accident." This in an update 17 of the Blue covered Docurents.
18 ANSI H545-1975, American national Standard, Performance ,
19 Testing and Procedural Specifications for Thermoluminescence 20 Dosimetry (Envircnmental Applications).
21 Q Is ths.t all the Documents?
22 A Ho, Duke Power Ccmpany 's Crisis Manacement Plan, McCuire 23 Emergency Plan, Duke Power Comp'any, Ocenee Nuclear Station 24 Energency Plan.
25 MR. McGARRY: I would like the Record to reflect EVELYN BIRGE R ASSOCIATES. STENOTYPE REPORTING SERvlCE. CMARLOTTE. NORTH CAROUNA
Birch - Direct 22 i
there is a note on the Duke Power Company Crisis Plan, 2
" Returned to R. Sharp. Available on request. "
3 MR., GUILD: And I understand it will be made 4
availabic; it is on the way?
MR. McGARRY: That's correct.
6 7 BY MR. GUILD:
g 4 Mrs. Birch, before we Adjourned the Peposition and 9 brought the Documents in, I asked you a question about menitorir g to equipment and specifically to refer to the final Safety Analysit 11 Report for the Catawba Station with respect to release point 12 monitors. Do you have that Document available to you now?
13 A Yes, y 4 Can you give us a reference, please?
15 A Section '11.5 1.2.1.8.
is 4 And what is the title of that?
17 A Raised Licuid Discharge Monitor.
18 4 With reference to that Document can you tell me where 19 that liquid effluent menitor is located for the Catawba Station" 20 A It menitors the low level radioactive liquid waste dis -
21 charge into the low pressure surface water discharge.
22 4 What is the location of that discharge point?
23 L I could show you on a map. It goes into a cove and it 24 is identified on maps. I am not sure if there is a map in this 25 Section.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROUNA
Birch - Direct ,
23 1 4 Does it go into Lake Wylie?
2 A Yes.
3 4 And from there beyond what, the plent site boundary?
4 A That's correct.
5 4 What is the nature of the nonitor that is located at 6 that location, Ms. Birch?
7 A I'm not sure I understand what you mean.
8 4 What kind of equipment is located at that monitor?
9 A That is a Gamma Sensing Device. There are two monitors, 10 a high range and a low rance at that location.
11 4 Can you identify the equipment by manufacturer and node 17 12 A I believe it is a General Atomics, I can't give you a 13 model number. It is a Sodium silide for the low range. Typica:
14 sencitivities are listed in the FSAR.
15 4 Can you give me the reference for that?
16 A It is Table 11.5.1-1, Page 2.
17 4 Are there any other liquid release point monitoring 18 stations at the facility?
19 A There are other liquid radiation monitors on various 20 othef complements.
21 4 But not effluent release points?
22 A They are potential release points, but it goes into -
23 the low pressure service water'line.
24 What other potential release lines?
4 25 A Ventilation Unit condensate drain lines.
EVELYN BE RGER ASSOCIATES. STENOTTPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA 3 I
Birch - Direct 24 1
4 Turning cur attention, if we can, to atmospheric releas e 2
points, are there effluent nonitors that arc designed to menitor 3 at=cspheric relen,ses of radiation from the facility?
4 A Yes.
v.
5 4 Can you direct ny attention, are they referenced?
6 A They are in Section 11 3, I believe is the waste cas 7
system; the monitors are in 11.5, depending upon the monitor, 8
they are located in 11.5.1.2, 9 4 Can you identify the monitor release points?
io A Each unit vent, there are two units. Those are the 11 major release points. There are other tenitors but nost of the 12 releases go through those vents.
33 4 Where are they located?
~
34 A Adjacent to the Containment Buildings.
l 15 4 Are those stacks --
16 A They are referred to as a stack; they are more a vent.
17 4 What elevation are those release points located?
ig A I don't know, ig 4 Can you give us a rough idea; are they higher than the 20 top of the Containment?
21 A I don't know.
22 4 If I ack you to refer to the FSAR uculd that previde 23 the information as to their elevation and location?
24 A I would doubt it would be in this Fection of it. I 25 inngine it would be in the Secticn on Meteorology.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOMTM CAROUNA l
Bfrch - Dirnet -
25 _
1 4 Do you know what Section that is, Ms. Birch?
2 A I believe it is in Chapter 2, but I'm not sure.
3 MR. GUILD: Counsel, can we have Chapter 2 or 4 that reference made available?
5 MR. McGARRY: Chapter 2 of the FSAR?
6 MR. GUILD: If that is the Chapter for the infor-7 mation that would assist the Witness in answering the 8 questien.
9 MR. Mc0ARRY: That Document is available in the 10 Discovery Room. That is available if you wish to get 11 it.
12 MR. GUILD: Would you require us to Adjeurn the 13 Deposition to get the Document?
14 MR. Mc0ARRY: Yes.
15 MR. GUILD: All right , if we could ask that the 16 Deposition be Adjourned, could we have a time?
17 It is 10:15 18 (Whereupon, the Deposition was Adjourned for a 19 brief Recess, after which the following Proceedings 20 were had:)
21 MR. McGARRY: I would like the Record ce reflect -
22 23 that the time we are restarting, what time is that, 24 please?
25 THE WITNESS: 10:20.
EVELYN BERGE R ASSocaATE S. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTH CAROUNA
Birch - Direct 26 1 MR. McGARFY: I would like the Record also to 2 reflect that the Catawba Emergency Plan has now been 3 furnished and I would like to make one other observation 4 in the event that -- let me preface thic observation 5 with an inquiry -- Mr. Guild, to the best of your know- -
6 ledge the management that we have now identified, the i
7 Documents that relate to Contention 27 --
g MR. QUILD: Mr. McGarry, the last reference was 2
9 prompted by the Witness saying she did not know the 10 answer to the last quentien. I can't say what informa- -
11 tien she has available to her.
] 12 With reference to whether the Document relates to 13 a specific questien, I -can't say what that will be.
14 MR. Mc0ARRY: To the best of your knowledge the 15 Documents that we have now present consistent to the 16 Documents that relate to Contention 27 --
, 17 MR. GUILD: We have now brought into the Room 18 everything that the Company has that relates to Conten-i 19 tion 27 to my knowledge. If we need another reference i 20 to the FSAR that is not here, I presume in the absence 21 of your agreccent to furnish the FSAR --
MR. McGARRY:
22 I believe if another reference is t .
23 made Mr. Lowe is here, he kncus where the Document
, 24 Room is and we can continue with the Depositien while 25 Mr. Lowe gets such Documents.
a
Birch - Direct . 27 1 MR. GUILD: Of course , Mr. McGarry, there are four 2 Counsel available to the Applicants and I have one per-3 son to assist me. In the event that we need to fetch 4 a Document and your Assistants will not help me, I will 5 not have any assistance.
6 MR. McGARRY: That is your chofee and we have made 7 our position clear.
8 MR. GIBSON: Mr. Guild, we are not denying to make 9 Documents available to the Witness absent a specific 10 request on your part, any Documents that relate to the 11 Case are in the Document Room. You may Eet them now, 12 Adjourn the Deposition, or get them prior to beginning 13 the Deposition. So any reference to our declining to 14 make anything available is not accurate.
15 MR. GUILD: There are many Counsel here for Duke 16 Power. It would be convenient for the Wftness, and 17 just as a matter of obstinance and difficulty, the 18 Applicant declines to make the Documents available in 19 this Room and instead requires Palmetto to Adjourn the 20 Deposition, fetch the Documents that may or may not be 21 responsive to their questions.
22 That is caused solely by the choice of the Appli-23 cants. I have made a request that all the Documents 24 identified in response to Discovery be made available 25 to the Witness.
EVELYt* BERGER ASSOCIATES. STENOTYPE REPORTING SE RviCE. CHARLOTTE. NORTM CAROLINA
Birch - Diract 28 3
MR. CARR: fir. Guild, the last Volume that you 2 went down there for was not identified in Contentien 3 27. If ,you would identify for us the Documents that 4 you want, if you want the whole FSAR here, if you do 5 Mr. Lowe can carry them down.
6 MR. GUILD: I don't think there is need for further 7 colloquy on the subject.
8 9 BY MR. GUILD:
in 4 Ms. Birch, do you now have the portions of the FSAR 11 that are responsive to the question concerning the location and 12 elevation of the atmocpheric release points?
13 A I have Chapter 2 available. I don't see the actual 14 height of the discharge point. I can give you elevations of 15 buildings.
16 4 Let me ask this as a general matter, we will get into 17 more detail about monitoring atmospheric releases particularly
- is under accidental conditions, you would agree, would you not, l
l ig that the elevation with which that release occurs is significant ?
20 A The point of elevation is important, but it is considered l
l 21 a ground point release by the NRC ground level.
f 22 C But ne don't know whether that is ground level from the l
l 03 information available1 l
l' 24 A It docen't matter, they require it at ground level.
n 4 Uouldn't you agree as a matter of ccience it is a l
I EVELYN BERGER ASSOC 8ATES. STENOTYPE REPORT 4NG SERVICE. CHARLOTTE. NORTM CAROUNA
Birch - Direct ,. 29
- relevant concern, the actual height above ground level at which 2 the release occurs?
3 A Yes, you will have to tLke that up with a Meteorologist .
4 4 And you couldn't determine that?
5 A No, I can give you the building height. It is a roof 6 vent, it is a vent, not a stack.
7 Q Is there some other portion of this Document or another 8 Document to your knowledge, Ms. Birch, that would provide that 9 information? -
10 A I'm sure that information is someuhere in the PSAR.
11 I don't know where it is.
12 4 Ms. Birch, I would like to get the response to these la questions as complete and accurate as we can. If there is some 14 guidance that you can give us to further search the FSAR, let's 15 do that now.
16 A Right now I don't know where it is; I can give you the 17 roof elevations for the buildings.
18 4 If I provided you with the Index would that assist you "
19 A There is one in that Chapter, I have already looked at 20 it. As far as I know in the information I have is roof elevation; 21 I don't have the stack heights at this point.
22 4 What other subjects night we refer to in the FSAR? -
23 A I don't know.
24 4 Counsel, can I ask if we can provide the Witness with 25 an Index?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA
Birch - Direct 30 1 THE WITNESS: It is provided in each Volume.
2 3 BY MR. GUILD: --
4 4 It is not in that Volume?
5 A There is a general review of all of it in here. I 6 believe it goes through all the Chapters.
7 MR. GUILD: Can Counsel help the Witness?
8 THE WITNESS: There is a Table of Contents for 9 the entire FSAR in each Volume.
10 MR. GUILD: Does Counsel know or perhaps Mr. Que13ette-11 I would ask you to facilitate this by providing informa -
12 tion to the Witness at this time.
13 MR. McGARRY: We don't know.
14 15 BY MR. GUILD:
16 Q Now Ms. Birch, can you identify the equipment that is 17 used to monitor that release point?
18 A Yes, it is identified in Table 11.5 1-2A, Plastic Beta 19 scintillator,and a GM2, it is a three prong monitor.
20 4 Plastic Beta Scintillator and --
21 A GMT Geiger-Mueller.
22 What are the ranges of the instrumentation?
4 23 A It does not give it as a range. The range is counts 24 per minute, ten to the one and ten to the seventh.
25 Can you translate that into --
4 EVELYN BE RGER A550CIATEh. STENOTYPE REPORTING SE*VICE. CHARLOTTE. NORTH CAROUNA
Birch - Diroct . 31 3
A I can give you the sensitivity of the monitor, ten.to 2 the minus, nine micro curies per niloliter of iodine,131.
I'm sorry, that's incorrect.
3 It is ten to the minus of crypten 4 85.
5 4 That is the Geiger-Mueller?
6 A No, Plastic Beta Scintillator.
7 4 Is that designed to measure that radionuclide?
g A It is designed to measure radionuclides; it does not 9 specifically look for a particular load. Would you like the to sensitivity? '
n 4 Yes.
12 A Ten to the minus five micro curies per miloliter.
13 4 Is the Plastic Beta Scintillator a monitor that is 14 post offective for gases?
15 A It will detect Beta emitters in gases.
16 4 Now then, you made a reference to iodine 131.
17 A I'm sorry, that was an incorrect monitor.
18 4 Is there a stack monitor at that point that is capable 19 of measuring iodine?
20 A There is a monitor, not really a monitor, we have a 21 :
?equirement-to have a stapler, we also have micro curies per 22 miloliter.
23 4 What is the nature of that monitor?
24 A It is a scintillator, a sodium iodine scintillator.
25 f.t is ten to the minus eighth. .
EVELYN SERGER ASSOC 4ATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA
Birch - Direct .
32 1
4 Radio-iodine?
2 g yes, 3
4 Is that h real-time monitor e Ms. Birch?
4 A How do you mean that?
5
~
4 Do you understand the term?
6 A It gives a dose rate or counts per minute rather than 7
instantaneously. It reads out in counts 1er minute and it is 8
dependant upon build-up of activity upon filter. ' is a 8
. direct response from a monitor.
10 Q How is that responso monitored?
11 There is a strip chart in-the7 Control Room. There;is A
12 also a computer point for the Control Room computer.
13 4 Any other way?
I4 A Not that I'm aware of.
15 4 Can you identify the manufacturer and model of that?
16 A Model number, no; the manufacturer is General Atomics.
17 4 Does it have a common trade name or-a name in which yot.
I8 identify it more precisely?
l A. No.
20 4 Now is there a reference that you are aware of that 91
~
would set out the description of the Control Room hardware that I
no
~~
you have referred to that monitors this release point?
93
~
A I'm not sure I understand what you want.
94
~
Q I'm looking for, you said there was a strip chart in 25 the Control Room.
t i Evstvm ermorn associaTas. stamoTves arrontimo senvics. cuantoTTE. NonTH camouNa
- _ m Birch - Direct 33 A Yes.
1 2 4 Is that strip chart described in the FSAR to your know- ,
3 ledge? ,.
4 A The information on the radioactive monitors is 11 5 5 4 That is a section of the FSAE?
6 THE WITNESS: Could we pause here?
7 !!R. GUILD: Ms. Birch, do you want to say somethir g?
8 Do you have that Section of the FSAR in front of you or 9 available to you, 11.5 if'that is the referenec?
10 THE WITNESS: Yes.
11 12 SY MR. GUILD:
. 13 4 Nou referring to the FSAR, IG. Birch, would you describe 14 the equipment and operation of the monitors that you have referred 15 to or located in the Control Roem that is present?
16 A The output is the strip chart recorders, and the com-17 puter points, the output is in the Control Ecom.
18 4 Hou, is the information that would be provided by that 19 monitor in the event of an accidental release from the facility?
20 A YCs.
21 4 As you understand that information, how would that 22 information be available to Duke Pouer persennel tnd others in .
23 an emergency circunstanco, and -what would they do with that 24 information?
25 A That infornation is available in the Control Roca to t: 1e EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERveCE. CHARLOTTE. NORTH CA RouNA
,_- . . . . , - . ~ . . . , , . . . _ - .
.r Birch - Direct -
1 Control Operators. It is always available on the computer and 2 the Technical Support Center. That infornation is also taken 3 fron that cenputer and through scme type of computer link which 4 . I am not aware of, is made available to our Crisis Managenent I
5 Team.
6 4 Let's take this one step at a tine because this is un-7 familiar territcry to me, Ms. Eirch. If the plant is operatinE g under normal conditions it is on linc; and if there were an 9 accidental release through this point, this release point, pleal:e 10 describ'e as best you can your understanding of what sequence 11 of events would occur e.nd how the infornation would be available 12 to the people involved and what they would do uith that informa-13 tion.
14 A There are set points on each monitor which are estab11thed 15 by Station procedures. Any time those set points are exceeded 16 you have an alert and an alarm mechanism which indicates some-17 thing unusual is happening.
18 4 Tirst an alert --
19 A There are two different alarm points on the monitor, 20 and the first is callcd an alert and the second is an alarm.
21 4 How do they differ?
22 A The levels at which you set the point.
23 4 The lower level is the alert?
24 A Yes.
25 4 What is the information that would come and to whom if EVEL*N SERGER ASSOCIATES. STENOTYPF REPORTING SERVICE, CMARLOTTE. NORTH CAROLINA
Birch - Direct -
oh I .htt t alert set point were reached 7 1
2' A It would altrm in the Control Roc = and it is available 3 to Control Roon Operators.
4 4 What is the nature of the alarn, audio visual?
5 A It prints out on the ecmputer as an indication of an 6 alarm, and it also is indicated on a light.
7 Q Uhere is the light located, Ms. Eirch?
8 A I can't tell you specifically.
9 4 Uould that light be an annunciator?
10 A 'les, there it an annunciator light.
11 4 Is that on the Control Panel for the reactor?
12 A It is in the Control Econ, I can't tell you where, 13 specifically, in the Control Rocn.
14 Q Who would be responsible fer noting and responding to 15 the annunciator signal?
16 A The operators.
17 4 Is there anything designated specifically?
18 A I am not faniliar with that.
The corputer printout , where is that available, Ms.
~
19 Q 20 Birch?
21 A As I said, it is available in the Control Room. It is 22 in the Technical Support Conter and I believe the ecmputer lead -
23 ing to our Crisis Management Center.
L 24 Q Are you identifying three separate location centers?
25 A That's correct.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERyaCE. CHARLOTTE. NORTH CAROUNA
32rch - Direct ,
36 i Q Where in the Control Room is .he print-out?
t 2 A I don't know specifically, but it is in the Control 3 Room in the horse, shoe area.
4 4 The horscchoe that you are referring to is uhere the 5 consoles are?
6 A That's correct.
7 4 All right, and the second location for the print-out?
8 A It is in the Technical Support Center.
9 Q Where is that, Ms. Birch? -
to A Adjacent to the Control Roon.
11 4 Who would be responsible for noting the cceputer print 7 12 out responses in the Technical Support Center?
13 A I'm not sure that I understand. The Technical Support 14 Center is not normally manned.
15 4 When is it manned?
16 A If there is any condition that indicates a concern where 17 they would need to respond to an emergency.
18 Q Is it fair to conclude, Ms. Birch, in the event of the l
19 first alert point or alarm point were reached, the stack monitor ,
l 20 that it would not be noted in the Technical Support Center since 21 the Technical Support Center would not be nanned?
22 A In this particular case, no.
23 4 Now the third locatien,fer a print-out was where?
24 A Crisis Management Center.
25 4 Where is that located?
EVELYN BE RGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE, NORTH CAROLINA
Birch - Direct 37 1 A I don't know where it is at Catawba. I believe it is 2 here in the General Office.
3 Q Is there core thtn enc Crisis Management Center for the 4 Conpany?
5 A Yes.
6 4 One for each pitnt?
7 A Yes.
8 4 Are the ones for Oconee and licGuire located here in the 9 General Offices?
10 A There is one here in the General Office as a back-up 11 to each of those.
12 4 I'm sorry, I don't understand.
. 13 A There is a back-up center as well as the primary center.
14, 4 h'here are the prinary centers located?
15 A Training at McGuire.
16 4 Is that in proxinity to the facility?
i 17 A Yes.
18 4 How about Oconee?
19 A It is the Training Center.
l 20 4 Proximity to the Plant?
21 A Yes.
22 4 And you believe for Catauba it is here in the General 23 Offices in Charlotte?
24 A There is probably cne at the Station, I don't know. I 25 don't go to it.
! .veu~ ..aoa. . soci rus. ste~onra arroama saavica camaans acam c^awa^
Birch - D2 rect . 38 3
C All right now, is the Crisis IIanagement Center for .
I 2 the Catawba facility normally manned?
3 L No. ,.
4 4 Is it fair to conclude then that the print-out that 5 indicated that an alert or an alarm point had been reached for 6 this stack nonitor would not be noted in either then the Technical 7 Support Center or the Crisis Management Center?
g A That's correct.
9 Q It would then be noted solely in the Control Room at in the facility?
11 A That's correct.
12 4 Fcr clarification, Ms. Eirch, we have been talking about 13 print-outs and an annunciator that would provide an indication 14 that a predetermined set point had been reached for this stack 15 monitor.
16 A [The Witness nodded her head affirmatively.]
p Q Now we are referring both to the monitor that you have 18 referred to as a Plastic Beta Scintillator as well as the Geiger?
19 A They cover different ranges.
l l 20 4 Would you cover that?
21 A The monitor needs to go more than six decades. '
22 4 Explain that in lay terns. -
23 A You would, to go from the lower level of detection to 24 a higher level, as I said, the range of the monitor is from ten 25 to cero to ten to the seventh, and therefore you can't cover that EVELYN BERGER ASSOCIATES. STENOTYPE FEPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
- . - . - . - ,. -. , - - . - - w - . - - . - --
I~
Birch - Direct 39 i 'meny ranges. It 10 a logarithmic read-out, so you have two 4
2 detector and they both --
3 4 Which ccycrs the lower range?
4 A The Plastic Beta Scint111ator.
5 4 The Plastic Beta Scintillater, and the Geiger-Mueller, 6 the higher range?
7 A That's correct.
8 4 Now, if you could, Ms. Birch, relate those ranges in 9 lay terms to the expected release values during normal Operatior is 10 as compared to release values under emergency conditions.
11 A The release range can vary, I would cay we are talking 12 about being at the lower limit of detcetion.
13 4 For the lower of those.two ranges?
14 L For the lower, for the lowect relence point, the lowest j 15 sensitivity and possibly one or two decades above that.
16 4 For the lowest range, the lower range?
l
! 17 A [The Witness nodded her head affirmatively.]
[
18 4 And is it then fair to conclude that it is the Geiger-I 19 Mueller that would be used exclusively under serious accident 20 conditions ?
l 21 A That is correct.
22 3 Does the FSAR describe the sensitivity of both of thes e-l
! 23 instruments?
24 A That 's correct.
25 4 Are there any redundant features for the inctruments l
l EVELYN BERGER ASSOCIATES. CTENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
r Birch - Direct ,
40 1 'that would be used to monitor under accident conditions the 2 Geiger-Mueller instrument in this instance?
3 A I am not sure about redundancy.
4 4 You don't know whether there is more than one?
5 A No.
6 4 Now the instrument, it is fair to say, is not in place 7 at the Catawba Station or not operational since the facility is 8 not complete and not producing an effluent?
9 A I have been out and looked at several of the monitors.
10 They are in place but they are not operating.
11 Q There is nothing to monitor, we are talking about an 12 effluent stream and there is no effluent?
13 A Correct.
14 Q They are, however, monitoring ecuipment and systems in 15 place at the Company's other facilities; are they not?
16 A That's correct.
17 4 At the Oconee facility and at McGuire?
l 18 A That is correct.
1 19 4 Is it a fairly general observation with respect to the 20 system used at Catawba to be monitored under accident conditiont ,
l 21 the Company has said it is general planning to utili-e the system l
22 either identical or very similar to the ones in place at Oconec l
23 and McGuire?
24 A The syster.s at Oconee and McGuire are not similar, they M are not made by the same manufacturer, for example.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
~ -
- 41 Eirch - Direct 4 Let's tske !'cGuire , would the sycten be ver;' similar?
A YOU' 2
4 Ey the care nanufacturer, we agree it is Westinghouse 3
facility and the monitoring systema that are planncd for Catawbe.
4 5
would be similar to McGuire?
6 A The monitoring systems would be similar, but it has 7
nothing to do with it being a Westinghouse product.
g 4 Similarity --
A That wits not purchaced frem Westinghouse; the similarity 9
10 is in the state of the arts.
4 I see, and why is it less sinilar to Oconee?
33 A A difference in age, improvemente. in the system --
12
. 4 I'm sorry, complete your answer.
33 14 A !!o, that is all right.
15 4 How long has the McGuire monitoring system roughly been 16 operational? How long have there been effluents to monitor?
17 A Ohe system was operational before the plant received 18 a license to operate, and I cen't give you the exact date, but 19 it was about two years ago.
4 Is it fair to say that two years ago roughly represent a 20 21 an actual operational experience that Duke has had with the I
22 system similar to the one to be used at the Catawba Station?
23 A Yes.
24 4 Are you familiar with that operational experience at 25 McGuire, Ms. Birch?
EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Birch - Direct 42 1
A Reintively familiar uith it.
2 4 And are you familiar with the experience of the monito: ?-
3 ing systems at Oconee? ,
4 A Yes.
5 Q Do you know whether there are cny redundancies in the 6 Stack monitors at either McGuire or Oconee?
7 A I believe there are no duplicate nenitors at Oconce or 8 McGuire at this time.
9 Q Can you explain a little tit?
io A The high rance =cnitor is a reccamendation, I know 11 personally that we do this, although it is not a requirement and 12 I trould have to verify whether that had been done or not, t.t
, 33 this time I don't knew.
34 Q Who nade ths.t recctmendatien?
15 A An internal Task Force composed of an internal group 16 following TMI.
37 Q Are ycu a renber of that Task Force?
i 18 A Yes.
1 19 Q Who else was a nonber of the Task Force?
20 A Vernon Wardell,-W-A-R-D-E-L-L, Robert Hall.
l l 21 Q If you could, what are the titics or basic jobs of 22 thece people?
23 A At th*c point I don't knou.
24 4 Uhat area does "r. Wardell work in?
l 25 A In Franklin Jackson's group, but I can't tell you l
i
( EVELYN SERGER AS$0CIATES. STkNOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROLINA 1
n19eh - n$ rent 43 1 'specifically -- Mechanical Design.
2 4 And Mr. Hall?
3 A I can't answer that.
4 4 It he design or construction?
5 A' He is in design.
6 Others, please?
4 7 A I'm not sure I can renember everyone, L. A. BPae.
8 4 His or Her area of work?
9 A Health Physics.
10 At one of the Stations?
4 11 A He is enployed at another plant at this point.
12 4 Formerly with the Company?
- 13 A Yes; I can't recall the other team members.
14 Yourself?
4 15 A. Yes, there are others, Frank Heywood.
16 Kr. Heywood!s arca of work?
4 17 A Nuclear Operations, I'm not sure that that is where 18 l
he is now.
19 4 Can you tell te the na=e of this Task Force, how it i
20 has been referred to?
21 l A Ho, I can't.
22 How have you referred to it?
4 23 A The THI review group.
24 4 What was this Task Force's crea of responsibility?
f M A To review all cf our cystcar, the incident that occurred EVELYN SERGER ASSOCIATES. STENOTYPE REPORTtNG SERvlCE. CHAR 6CTTE. NORTM CAROUNA L.
Birch - Direct 1;f:
I at TMI and to try to determine those creat that we chculd improva 2 based on the incident that occurred at TMI.
3 Q Did the Tack Force make recernendations including the 4 one you hr.ve referred to with respect to monitoring under accident 5 conditions?
6 A Radiation monitoring, yes.
7 Q What were those recommendatiens?
8 L To put in a high range redundant monitor.
9 Q And the others? ,
10 A Improve sampling.
11 Q Uculd you explain that, please?
12 L Ability to obtain containment gas liquid ser.ples , react
- 13 to coolente under accident conditions.
14 4 Uhat kinds of improvemente did the Task Force recommend?
15 A They left that open.
16 Q Uhat kind of improvements do you believe Eheuld be madO7 17 L The type of things that had been done to complete NU - ~
l _
18 REG 0737 Uc have added in monitoring systems to obtain samplen I 19 of gases undcr accident SituatiCnS.
! 20 Q Where would those gases be sampled from, Ms. Birch?
21 L The containment atmosphere.
22 Q Did you sarple fer hydrogen? ,
23 L It is outside of my area, I rr. cnly invcived with the 24 radioactivity.
l 25 Q Do you know whether that was included?
i EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERytCE. CHARLOTTE. NORTH CAROUNA L
Birch - Direct 45 i A Yes, thtt is included.
2 4 Have these sampling recemmendations toen implemented?
A Yes.
3 ,
4 What was the basis for your decision that these items 4
5 were open?
A ur Task Force left it open to inprove it. We did not 6
give specific recoemendations. The Task Force was responsible 7
for identifying areas for improvement. It did not necessarily 3
g recommend how to improve it.
10 4 But subsequently someone made rocc=mendations about 11 specific irprovements and sampling?
12 A Yes.
33 4 Was that the Task Force's work?
34 A Yes.
15 4 What did you recommend?
16 A We reconmended improvements.
17 4 Can you be more specific?
l . _
l l ig A That was the inprovenents, an area of a problem' identi "ied<
ig 4 And you were open about how to do that initially?
go A That is correct.
21 4 And then you were asked to make specific reconmendatiens?
i 22 A !!o, the Task Force was not asked to mako specific l
23 reconmendations.
24 4 Eut someone did?
25 A That 's correct.
avitv~ es=ce= *ssoci.ru . sr ~orvar as=oari~a sa=vice. c~ = tom. ~onr~ c.=ou~.
m Birch - Direct -
46~
~
1 4 Can you tell ne who did?
2 A In the case of contain=ent gas samples, I was involved 3 in that. There were a number of individuals involved.
4 4 Let me see if I can understand this. Do these recommend-5 ations bear on the ability to monitor actual or potential releases 6 in the event of an accident?
7 A It would be very beneficial to knew the concentration, 8 d'egree of gases and waters inside containment.
9 4 Why is that, Ms. Birch? Would you explain it, please?
10 A That is the activity that you are going to be concerned 11 about being potentially released on site.
12 Q What are the short comings or inadequacies 1'n the 13 current ability to monitor the containment atmosphere?
14 A At the present time we do not have any that I as aware 15 of.
16 Q What were the inadequacies or deficiencies?
l l 17 A Radiation levels would be such that it world be difficttlt 18 to obtain samples without receiving higher than a normal r&diation 19 exposure to the person collecting the sample.
20 4 I see, is it fair to conclude the pre-existing system 21 required soncono to go take, grab samples of the actual radiation?
i
! 22 A No, there was a two inch line to the gas strean going 23 to the monitor. The exposure was to a two inch line source of
'4 radioactivity.
l l
25 4 Yes, where did that tuo inch line source run from the l
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Eirch - Direct 47 I container?
2 A It rtn from the containment, there were three points 3 to which that was centained.
4 4 Where would they run to?
5 A To the monitor console on the generatien area adjacent 6 to the containment building.
7 C And those had been released by what?
8 A Post accident sampling panels; well, they haven't been 9 released. They have been added to.'
10 Q How do they differ in design or function from the 11 original system?
12 A Well, the original system concentrates activity, if 13 possible, because of the levels, for example, in the case of 14 iodine, you must concentrate the iodine to defect it. In the 15 case of the sampling system, post accident, you are trying to 16 dilute the cample,to reduce the amount of activity actually 17 being handled by an individual.
18 4 Uhich system will be in place at Catawba?
l 19 A Both, l
i 20 How then will the personnel avoid the exposure that Q
21 yru are trying to alleviate?
22 A They use the post accident sampling panel, and under -
23 other conditions they use the nornal panel or slightly abnormal, 24 it depends upon the activity.
i How does one switch from one system to the other7 25 i 4 l
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA
r' Eirch - Direct ,. 48 1 A They are both capable of being used at the same time.
2 4 Must One shut dcwn the original system?
3 A There would be come 1.cint under accident conditions 4 where the initial cystem will be isolated because of containment 5 isolation.
6 4 Are there any other recommendations that this Task Force 7 made or have been implemented to your knowledge or considered 8 for implementation to your knowledge, Ms. Birch, that relate to 9 monitoring under accident conditions?
to A The Document we are talking about is an inch thick, 11 and I haven't looked at it recently. There were other recommend-12 ations made which I can't recall.
13 4 The Document that you refer to is what, can you describe 14 that?
15 A It was a report of the Task Force, i 16 4 To whom was that report made, Ms. Birch?
17 A I'm not sure.
18 4 Can you give me an estimate of the approximation of 19 the time When that report was published or issued?
20 A Late 1979 21 4 Do you know whether that report was provided to the 22 Nuc1 car Regulatory Commission?
23 A I do not.
24 4 Ms. Birch, referring back te this Task Force that you 25 were a member of and we were talking about,do you have a copy of EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
. Birch - D2 rect 14 9 that report 9 1
A In my office.
2 3
4 You don't. have that available to you at this time?
4 A No.
5 4 Now, I.was a little bit concerned about an earlier response On this same subject. Perhaps you can help me clarify, 6
I believe you stated that you were not certain whether or not 7
8 the Task Force's recommendation for redundant monitors had been g
actually implemented. Is that true?
10 A That is correct, I was not responsible for implementing all the requirements of the Task Force.
g g Q Do you know whether or not redundant stack monitors are to be installed at the Catawba facility?
g A I do not.
Q Do you know whether or not the technical specifications 15 16 g A I do not.
4 We have talked about one particular effluent stream 3g 3g monitor with respect to atmospheric releases, and that has been 20 what is called a stack monitor?
g A Yes.
22 4 Are there other effluent steam releases that monitor ,
23 actual r potentici relcaccc to the Etnosphere other than the '
vent?
24 g5 A YeG.
EVELYN BE RGE R ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE. NORTH CAROUNA
Birch - Direct -
50 1
4 What are those?
2 A Steam. Relief Valve Monitors.
3 4 Where is-that located, are those located?
4 A They are in an area prior to the main steam lines, 5 prior to entering the turbine building. They are in an area 6
called the dog-house.
7 And under accident conditions could atmospheric release s 4
8 of radiation come from this point?
9 A If you have a primary or sscondary release in addition 10 to the accident, yes.
Il 4 Under what circumstances would these steam relief valve s 12 emit an effluent?
13 A Shutting a unit down or taking a turbine off line.
I4 4 What happens?
15 A They are pressure relief valves; they are designed to 16 release the steam instead of sending it to the turbine.
I 4 Uould they be used for that purpose under non-accident I8 conditions?
19 A Yes.
20 4 So they are routinely used as a steam relief point?
01
~
L Steam relief monitor. There are monitors that are on 22 '
release points that go into the unit vent.
23 Q I don't understand you, could you explain it, please?
04
~
A Air ejectors from the secondary site, there are monitors 25 on the air ej ectors , and that would be the normal way to keep EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTH CAROLINA
Birch - Direct 51 1 ' track of relences.
2 C By normal you mean non-accident circunstances?
3 A That it. correct.
. 4 4 What kind of monitors are they?
5 A They are basically a gas monitor, to it would probably 6 be a Beta Scintillator like the others. I could check, if you 7 like.
8 4 Uould your answer be generally the same as for the vent 9 menitor system 7 '
(
10 A Yes, they are very similar.
11 Q They would be a low icycl, low range Plastic Eeta Scin-12 tillator?
. 13 A I believe so.
14 Q All richt , and is this the high range monitor, the 15 Geiger-Mueller; is it wired similarly to the vent monitor that 16 you have described earlier?
17 A Yes.
18 4 Go to a print-out, sane three locations, annunciator 19 in the Control Room --
20 L Yes.
21 Q Uculd it be a separate annunciator frem the stack monit or 22 annunciator?
23 A There are ceparate pan ~cle in the Centrol Room for each 24 of the monitors, and they have individual alarm lights. The 25 annunciator may be the cane annunciator, I can't answer that.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA
Birch - Direct 52 i 4 Perhaps I don't understand the terminology.
1 ,
2 A There are lights above the Control Ecom horse-shoe, 3
and there nay be.cne liE ht that lights up to indicate a general 4
indication, and ecch one of the individual monitors has lights.
5 4 The menitors that night relate to the common annunciator, 6 are they gauges?
7 A Gauges.
g 4 IIow do they read, what scale do they show? Are they 9 simply a flashing light?
10 A The light on the panel is just that, a light; and an 11 alarm, an audibic sound. The actual individual panels would 12 have the individual read out or there would be a strip chart
. 13 recorder.
14 C Do you know if the design for the Catawba Control Room 15 panel would include an annunciator and monitors that you have 16 referred to? Is it available in place, published, do you know?
17 L I am not sure I know what you want.
IS Q Is there a Document that I could reference, that I could i
! 19 say if We turn our attention to it to Gay where this annunciator i
20 is and what the equipment is for the Catawba Station?
21 A I'm sure there is sc=e type of Document, but I don't i 22 3 ave it. -
23 4 Do you 1:nou if it has , 'in fact, been designed?
04 L Yes.
25 4 And you have seen it?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORT'4 CARCUNA
Birch - Direct .- 53 i A I look at three Centrol Rooms, I don't know the differ-2 cnces between them; I can't recall.
3 Q Ic it cicar in your nind, though, Ms. Birch, this is 4 not one of the horse-choe: of a Centrol Ecom that has yet to 5 be finalized or designcd; thic has been decigned?
6 A As far as I an aware of, yes.
7 Q ' hat other effluent release points have nonitors at 8 the facility?
9 A All the other release points go through the unit vent.
to The unit vent is the release point with the exception of the 11 Etean Valves.
12 4 There are three then, the unit vent and the only other 13 one would be the atmospheric release for the steam dump valves?
14 L That I an aware of, yes.
15 4 Uhat other point at the facility could the atmospheric 16 releases occur under accident conditions?
17 A I'm not aware of any.
18 Q Uhat conitoring systen would be used to monitor a i
19 release if there were a breach of containncnt accidcnt?
i 20 A You have coniters inside containment.
21 4 Ubich of those are ycu referring to?
l 22 A Eich rance and low range that we have discussed.
23 Q These are the centainment atmocpheric nodels that you l
24 are referring to that were the reconnendations by the Task Force?
25 A lio, that was the canpling systen.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHAR l OTTE NORTM CAROLINA
, , Birch - Direct 54 1
Q I see, there are monitoring instrumentations that mon-2 itor containment atmocphere?
3 A Right. .-
4 Q Are they similar?
5 A Similar to the stack.
6 4 I'm sorry?
A Similar to the stack in design.
g 4 Do you know where these are located in the Catawba g Station?
io A They are located as I mentioned before, in the ventila-11 tion equipment area adjacent to the containment building.
12 4 These are the sampling lines that you are talking about?
33 A The gas monitors, the sampling devices are in the same 14 location.
15 4 The same location as what, as each other?
16 A Yes.
q 4 Where do they sacple from, Ms. Birch?
is A Multiple places inside containment, lower, upper con-ig tainment.
2o Q Is there a discreet indication of the specific source 21 of the release?
i 22 A You can valve a particular location or you can leave al l 23 open.
24 4 What is the normal mode of operation?
l 25 A Open.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Eirch - Eirect . 55 1
Q Are there redundant features to this containment 2 atmosphere monitoring system?
3 L I believe there are two monitorc, but I ',:ould have to 4 verify that. There is cnly a requirement for one.
5 Sy "requirchent" uhat are you referring to?
Q 6
L The Ecculatory guidance given.in REG-Guide 1.97 7
4 If th re is a Documsnt could you refer to it if you 8 can determine whether or not there is a redundancy on that syste m, 9 please?
19 I don't believe it is going to say that.
L Il Q You couldn't tell?
10 It does not say.
~
L 13 G Cive me that reference?
14 Table 11.5.1-2, L
15 C Would your Task Force's recommendations have included 16 redundancy en this monitoring system as well?
17 L I don't remember.
Mm I8 4 Again, turning your attention to a release that does I9 not go through either the stack vent or the stean dunp, and 00 instead is relea:ed from containment otherwise because of a 91
~
serious tr:ach of contain=cnt accident other than the contain-l oo
~~
ment atmospheric model that ycu were just talking about, is there
! 03
~
another at= sphoric table thtt would provide you with informati on t
94 l
~
under that release?
i I
o"- Installed monitoring system?
( L l
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
, 71rch - Direct 56 1 Q Yes.
2 L Mo.
3 Q Ms. Birch, now changing cubjects briefly, give me a 4 general understcnding of your duties, not specifically with 5 reference to the monitoring we have talked about or the accident ,
6 the emergency opera; ions we have talked about, what other work 7 do you do? What is the nature of your ucrk, please?
8 L Selection of equipment, recommendations on equipment, 9 actually. I an involved in day tc day operations and any pro-10 blems that night be had in operc. ting any particular piece of 11 equipment. I an not suro I know exactly uhr.t you want.
12 4 Let me back up, I would like to ask a question: You 13 are responsibic for the Company's Radioactive Waste Hanagement?
14 L Low level Radioactive Wasto Management.
15 4 Monitoring is only a small portien of your responsibil-16 ites; is that true?
! 17 L That is correct.
~
18 4 You are primarily responsible for work at Oconee?
19 L I have syctcm wide respencibilitict for nuclear plants.
20 Q Are there persens who work under your supervisien?
21 L That's correct.
22 Q Hcu many pccple work fcr ycu, Mr. Eirch?
23 L Ecclly, it it c'ependent ; I have ci.v. with onc on loan.
24 Q Would ycu tell mc who there people tc:e7 I don't esan 25 by name, but what are their functionc?
EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROLINA
, . - - - - , , n -, - . . . , - - , -,, - - - . - - . - , ~ , . - -. - - . . - - - - - - -
O Eirch - Direct ,. 57 1 A I have a group recronsible for Regulatory Support of 2 Redwaste Oper:tiens.
3 4 Slou dcup, Ecculatcry Support for Radvaste, and how 4 niny people?
5 L Tuo, there ic cn open slet in that grcup.
6 Q All riEht, continue if you would.
7 A enci neering Support to Radwaste Ecuipnent.
8 Q Ecu rany is that?
9 A Three individuals. Process Centrol er Process Enginee r-
- n. ing, two. There is an opening in that group.
11 Q Any others?
12 A [The Witness shock her head negatively.]
+
13 Q Uho of those pecple, if any, are primarily responsible 14 for radiation of monitoring under accident conditions, Ms. Birch?
15 A One of the individuals in the Retulatory Support Area.
16 4 And who in that person?
l l 17 A Chang Tuh/Ltn.
18 Q Spell that for the Record.
19 A C-E-A-I!-G F-U-E L-A-N.
20 C What is that person's title?
l 21 L Es is an Assistant Health Physicist.
l 22 C Any of the other individuals ths.t ucrk for you have i
i
! 03 responsibilitier in the crercency area?
I r
l 24 L Yor.
25 0 Uho nr0 they?
.. u~ .. as. ...ocian s. .r orr . .iro.ri~a se vice. c .. tone. ~onr~ ca.ou~.
l i
Birch - Direct 58 3
A All the personnel.
2 4 Is it fair to say that is not their prinary day to 3
day responsibility?
4 A That is correct.
5 Q Where would they be involved in emergencies?
6 A It depends upon what type of emergency.
7 4 Are they designated to respond in the event of a radio-g logical emergency?
g A Yeu, and they are identified as the Crisis Management 10 Team.
11 4 Is it fair to say their primary work is in low level 32 waste management, Radwaste Management?
13 A That is correct.
14 4 The Conpany has underway programs at Oconee to upgrade 15 low level waste management facilities?
16 at is conect.
17 4 Arc any of your people involved in work on that?
18 A Two of the people are responsible for keeping up with 19 that project, and myself, on occasions,obviously.
[
20 4 Which two of those people?
21 IG. McGARRY: I will Object to this line of ques-22 tioning. It is beycnd the scope of the Contentions we ,
23 are talking about, low icyc1 waste programs at Oconee.
24 MR. GUILD: I don't expect to go into detail. I 25 am trying to understand Ms. Birch's work and the work EVELYN SE RGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE. NORTM CAROUNA
Birch - Diract .. 59 1
of the people that work for her and particularly to the 2
extent that the work is not in the area of cmergencies, 3 I want 1.t clearly understood what their primary work 4 is. .
5 IIR. McGARRY: I have no Objection to that, but yet 6 inquire into low level programs --
7 MR. GUILD: I don't want any particular detail 8 about it. I want to understand what these people do.
9 10 BY MR. GUILD:
11 Q You say two Engineers are working on the Oconee Project?
12 A Yes.
13 4 What about the balance.of the staff?
14 A Any of the nodifications nade to a Station, computer 15 programs that are used in developing releases, standardizing 16 calculations, processing, selections of iron exchance to best 17 process wastes, reduce activity in various waste streams, we 18 are involved in the day to day operations of the waste treatmen';
19 systems, the liquid steam systens in the Station and the solid 20 Station systems.
21 We have been respencible for things such as the post 22 accident gas sampling pancis, relieving monitors and their oper i-23 tions because they are on effluent streams.
24 4 I'm sorry,because they are on effluent streams?
25 A That's correct. I'm not sure what else, I'm sure there EVELYN SE RGER ASSOCIATES. STENOTYPE REPORTING SERWCE. CHARLOTTE. NORTH CAROUNA
Eirch - Direct 60 I [rcotherthings.
2 4 Who for the Comptny, Ms. Birch, in primarily responsibl e 3 : hen for concerning themselvec with nenitoring under accident 4 conditions?
5 A My group, actually, it is under Doctor'Haller, but we 6 report to him.
7 4 I'm corry, I don't know the centleman's nane, his full 8 nane.
9 A Willian H. Haller, H-A-L-L-E-R.
10 4 What is Doctor Haller's title?
11 A Manager, Nuclear Technical Services.
12 4 You report to Doctor Haller; is that right?
13 A Yes.
14 4 Ms. Birch, explain, please, your understanding of the 15 relationship between the nonitors we have discussed that are 16 fixed and in place nonitor effluent release points and the II nonitoring of radiation under accident conditions for the pur-18 poses of energency response.
19 A It is a rather broad questien. The purpoce of radiation 20 nonitors are to give you an idea of the quality of effluents 21 leaving the ctation. First in the case of airborne releases, 22 containment nonitors, if there should be a release of activity ,
23 those would indicate a decrease reading and the nonitors in th'a 24 stack indicate anything going through the stack, so that is the 25 release fron the station.
EVELYN BE RGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
m Birch - Direct .. 61 1
4 In your opinion do these monitors provide sufficient 2 information in order to take the prcductive action required 3 under cmcrgency gonditions?
4 A That is your first indication' of activity; and yes ,
5 activity in containment could be a point at which actions wculd
~
6 Le taken without release to the environment.
7 4 Prior to release to the environment?
3 A I'm saying that actions could be taken withcut a relea se 9 to the environment based on activity inside containment.
10 4 I understand. Would you describe these, the information 11 that you believe is necessary, in order to take appropriate 12 protective action in the event of a serious accident?
13 A I feel you need the source material, basically the y activity inside containment.
15 4 Define that term, " Source raterial."
16 A You need an idea of the known gas contributions and 17 the radio iodine contained in the atmosphere inside containment, is You need to know whether or not that is being released from the 19 site.
20 4 Are there other constituents that you want to know 21 about?
22 A Those are the two I would be concerned with, gases and '
l 23 radio iodines, and I would want~ to knew if that was being re-l 24 leased from the site; and if so, what that concentration were.
25 That would be provided by stack nonitors or decrease in the EVELYN BERGER ASSOCIATES. STENCTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROLINA I . _. . . _ . . _ _ _ - _ -
_ - - _ _ . ~ -
Birch - D2 rect 62 1
monitor reading inside containment if you ha.ve a breach of cen-2 tainment. There are analysis monitors incide containment.
3 4 Explain,that.
4 A They are between the concrete shell and the building.
5 4 Is that in the ice condenscr?
6 A No, that is inside containment. The ice condenser, thf.s 7
is between the steel building and the concrete.
8 4 And again, are these monitors that are in additien to 9 the monitors that we have discussed?
10 A [The Witness nodded her head affirmatively.]
11 4 Are they similar in design?
12 A Yes.
33 4 And the way they are wired, wired to the Control Room?
A Yes.
14 4 High icvel, high range and low range?
A I believe they are high range.
16 4 I'm sorry, continue.
g A Where was I?
i g
4 You were telling me about how you get the information g which you have described so far as being the source material.
g A Okay, release from the Station monitors, you have monitor indications of a release. Then you will need to couple ,
g that informatien with meteorological data to get an idea what '
g that concentration will be as it leaves the site. You will want
,a. to confirm that with monitorinC teams.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLO7E. NORTH CAROUh4
. -,- . ~ . . , - , . - . . , , _ . , , , , . , _ . , , - - , , , , _ - , , - , . - , - - - - - - - , - -
Birch - Direct .. 63 1 4 Your Innt ansucr again, if you would?
2 A Meteorological data coupled with the magnitude of the 3 release to determine the concentration offset, and you would 4 unnt to confirm that with field monitoring teams.
5 4 Vould you believe it prudent to rely on the field monit or-6 ing teams to establish the primary information concerning source 7 term and concentration?
8 A No. The monitor team does not provide that information .
9 That information is available in the Control Room.
10 Q How do you mean the term " confirm," as you use it, Ms.
11 Birch?
12 A Using the source term information and the meteorological i
13 conditions, you will be able to calculate what the conditions 14 should be by confirming it. You want to go out there and see 15 what it is.
16 4 Why would you want to confirm it? Why would you want i
17 to Confirm that information?
18 A I wouldn't want to trust one number for all information, 19 talking about moving persons, possibly, and the environment.
20 4 Are you referring to an earthquake situation possibly?
21 A That is a potential.
22 4 So without the field monitoring you would be forced 23 to trust the efflucnt stecn monitoring cources we have discusseii 24 as the cources for that infomation?
25 A I wculd trust the ccntainment monitor with confirmation EVELYN BERGER ASSOCIATE S. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA
m Birch - D2 rect 64
'of that with the stack monitor.
1 You ma'/ cr may not have a read-2 ing on the stack monitors. You could have activity in contain-3 ment without having it released. If I have releace, I will rely 4 on the stack monitors to give to an indication of that.
5 4 Yes, so you have more than ene cource?
6 A That's correct, of information.
7 4 But you have more than one source if you have a contain-8 ment atmosphere monitor and a vent monitor?
9 A That is correct, but I would still want to confirm it 10 because I'm doing a calculation test on the activity.
11 Q Uhat are you trying to arrive at, Ms. Birch; when you 12 do the calculations you have referred to?
13 A Will the activity centribute significant exposure to 14 individuals if they were to remain at that site; and if so,
[ 15 protective actions need to be taken.
16 4 All riEht, what is the function then of the field 17 menitoring?
18 A Field monitoring teams determine the dose rate at various
! 19 points in the vicinity of the Plant and will take particulate 20 and iodino samples.
21 I'm sorry.
Q 22 A Particulate and iodine samplec and analyce them for t
23 concentrations of iodine, radio iodines.
24 And that product will be uced to confirm the calculated
, 4 25 exposures that were based on the releases monitored from the plant, EVELYN SERGE 84 ASSOCIAYES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROLINA
Birch - Direct .. 65 1 itself?
2 A That's correct.
3 Q How long- WOuld it take you to establish such confirmatyons 4 under accident conditions, Ms. Birch?
5 A The dose rate readings, once the team is in place whict 6 will be in place, once it is identified that there is a potentia l 7 for a release, the dose rate readings are almost instantaneous.
8 The radio iodine concentrations can be determined in 9 20 to 30 minutes. That includes collection of the sample and 10 analysis.
~
11 Q Is that all the information they would be confirming?
12 A Yes , at various locations , of course , but yes.
13 Q Doesn't your field monitoring rely on collection and 14 analysis of Thermoluminescent dosimeters?
15 A That is part of the environmental surveillance program ,
16 4 What is the environmental surveillance program?
17 A That was in place several years prior to the installa-18 tion of the facilities and concinues to determine background 19 and radiation levels in the area; and as part of that, you sample 20 independent doses of TLD's, water, airborne particulates, milk, 21 vegetation, various environmental media.
22 In an accident situation that can be used to deternine -
23 contanination cf those and indicate integrated dose during the 24 time of an accident.
25 4 Would you rely en it f.?r purposes of taking protective EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA
Eirch - Direct 66 d
1 action?
2 L No.
3 4 Let's go back, if we can, Ms . Pirch: How long would 4 it take to get the field tenitoring tears in place such as they 5 could perform adequately the functicns that you have deceribed?
6 L I'm not sure how long it ttkes to mobilize the team.
7 There is a requirencnt, the sequence of cvents in an incident 8 are such that there is adequate time that there is release to 9 the environment for the team to be -in place in the field.
10 4 How nuch tire is that?
u L I-can't give you a specific time.
12 4 Give ne your understanding of what that time is.
13 L Several hours. -
14 4 Now several hours from what point to whnt point?
15 L Frcm the time that you have an indication of an alert 16 cituation to the time that you nicht nich to take seme energene:r 17 action.
18 4 Give no an example of what that might be.
19 L Fire.
20 Q All right, until several hours frcm the initiating i
l 21 cvent until --
22 L Until you would have a cituation there you may or cny ,
l 23 not have c.ctivity, you can have a fire without having activity.
That would be a problen of offsite release. It is dcpcndent 24 25 upon location, the tino it takes to get it out if it doesn't go out i
EVELYN BERGER ASSOCI ATES. STENOTYPE REPORTING SERV 8CE. CHARLOTTE. hCRTM CAROUNA 1 - - -- - - -. - - - , - _ _ _ _ _ _ _ _ _ _ _
Birch - Direct 67 1 Q What is your underttanding of the chort test time for 2 which the Cc=pany plans the ability to be able to take tdequate 3 protective action between the initiating events and the exposur e 4 of affected off site personnel?
5 A 1 don't know what that time is.
6 Q Could you describe the general terms of the accident 7 scenario which in your understanding, Ms. Birch, would represent 8 the short test, initiating short test tine between the initiatir,g 9 event and the need to take protective action in the event of a to serious accident?
11 A I can't give you a scenario or accident. We regularly 12 plan cricis drills or however you want to call it. This is a 13 regular thing, and any drill, it has been several hours fron the 14 initiating event until there has been an offsite release.
15 These are considered realistic based on my experience 16 Vith dril18. That is what I would say.
17 4 Hypothetically, Ms. Birch, if the time between the 18 initiating event and the offsite release were not several hours, 19 but let's say one hour --
c' 20 A I think the teams could be in place in that time.
21 Q Could they perform the function that you have outlined 22 adequately such that adequate protective action could be taken?
23 A I don't think I uculd rely totally on field nonitoring 24 teams for protective action. I would rely on activity in conta$n-25 ment, meteorological conditions and calculations to determine EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SEnvlCE. CHARLOTTE. NORTH CAROLINA
Eirch - Direct 68 1
'whether protcetive action should be taken.
2 O Let to u rderctcnd this , Ms. Birch: Is there a level 1
3 of serioutness of. the nenitoring of the containment atnosphere 1 4 of the vent, steek vent of the steam dunp of the in place syster.s 5 that you htye described -- is there a level of seriousness ct 6 which you understcr.d protective actions would be taken without 7 cny reliance on nobile teams or --
8 A Yes, it is given in the procedures that were listed 9 carlier. '
10 Q Could you describe what that level is?
11 A Not without referring to the procedures; it is going 12 to vary by station.
13 4 Let's talk about the Catauba Station.
14 A That procedure has not been written for the Catauba 15 Station at this point.
16 Q All right.
17 A That, I am aware of, I haven't seen it.
, 18 4 Does it enist for McGuire av.d Oconee to your Pnowledge?
19 A Yes.
20 4 Let's take McGuire since we have c. creed thtt the Catawba 21 systen will be most sinilar to McGuire.
l 22 A I don't think there is a good wcy to do thtt bectuce 23 the nctcorolocical conditions tre coing to diffcr.
24 4 Hold those aside, and pletse tell ne if the.t has an j 25 inpact at the point uhcre I'm acking the question; but ngr.in, TVELYN SERGE R ASSOCIATES. STENOTYPE REPORTING SERytCE. CHARLOTTE. h0RTH C AmouNA
m i Birch - Direct 60 i
- ith respect to McGuire, let's lock at the Documents if ycu need 2 to and --
3 A They are,not procedures that I no: nally ute. My ' unction 4 is not to calculate offsite doses. Mine is to ca.lculate che 5 source material..
6 Q With respect te your responcibility of your level of 7 knowledge, whnt is the source materie.1 which in your opinion 8
would initiate the protective action?
9 A That is going to depend on.cxtenuating circunstances.
10 It is not going to be a yes or no answer at a particular level.
11 4 Is there a point at which we etn agree that all other 12 things held conctant, protective action would be the appropriate 13 response?
14 A Yes.
15 Q What is that level?
16 A Tne effsite doses are such that wo will not exceed some 17 certain dose, that if entire contents of the building were 18 released, whctever rate is deternined now, that would de' pend 19 upon the circunstances of the incident. I can't give you a 20 number.
21 4 Let 's take a nonent , if we ccn , and find it . 1.' hat is 22 the Document that you had reference to that would be available 23 for McGuire?
24 A I don't think that number will help you. The doses 25 tre dependent upon the effsite docos at which protective action s EVELYN BE RGER ASSOCI ATE S. STENOTYPE PEPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
_ _ ~ _ _ . _ _ - , _ _ . . - --___
Birch - Direct 70 1 'are goint to be taken are dependent en, and-those levels are 2 identified in the Catauba EmerCency Plan.
3 4 Yes , but, we are talking cf your responsibility and your 4 knowledge, !:s. Birch; and I believe your concern was the scurce 5 naterial?
6 A I identified the number of curict of activity inSide 7 containment or to the building to be a potentici point of releat e 8 to the envircnnent. .
4 9 Q h'ith respect to tha.t source material, what is the icvel 10 in which, in your judcenent , it is appropriate?
11 A I don't nake that judgetent.
12 4 Uho docs?
13 A The offcite dose coordinator.
14 Q Yno is that?
15 A Lionel Lewis.
16 4 Enat was the D.ce':.nent that you had reference to that 17 vould relate to this iscue for McGuire?
18 A There is a procedure which was identified. I can to 19 through that.
20 4 Yes, let's take a tenent and go through that.
< 21 A It is not a proccduro that I use. There are two Docu-22 nonts.
23 Q Uculd ycu identify those, ricasc?
24 A "Envircnnental !*cnitoring fcr Energency Conditicns,"
25 at the tine, H calth p hyticir1: Manual and the implementing procedure EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SE RwCE, CHARLOTTE. NORTH CAROUNA
m m
Birch - Direct ,.
71 1
within a ten mile radius of McGuire !!uclear Station.
2 Q Ecth of these crc for McGuire?
3 L That's correct.
4 Do those plans exist for Catawba to your knowledge?
4 5 A I am not aware that they do at thic time. If they don' t, 6 they will.
7 Yes, and we do agree, don't we, that you have already Q
8 responded that these plans, as they apply to Catawba, will be 9 similar to those for McGuire?
10 A I said they would differ based on the facts that the 11 conditions are different, different meteorology and site topog-12 raphy.
13 Other than that they would be similar?
4 14 A Yes.
15 Q If you would help ne with what you were referring to 16 earlier, a set of procedures that identified set points, if you 17 will, for these, for source term value, shall we say?
18 These reference the survey teams and going out and act.
A -
19 I do not have all of the procedures that ually confirming it.
20 are used by the offsite dose calculations team.
- 1
~
Let me direct your attention, I am not concerned about Q
1 22 the offsite or the field tcan at this point; but directing your 93 attention to what the peopic do at the Station as a result of I
24 the read outs fron the menitoring equipment that you talked about -c o3 l
~
A I don't have the Station procedures here, okay?
EVELYN BERGE R AS*OCIATES. STENOTYPE REPORTING SE RvlCE. CMARLOTTE. NORTH CAROUNA
Birch - Direct 72 1 4 So that infernation is not contained in thcse two 2 Documents?
3 f., no. --
4 4 Ms. Eirch, let ce see if I can understand this and 5 naybe over simplify, and if I do please tell me I tm over 6 simplifying: Is there a point at which things are so serious 7 on the basis of information from the nonitoring equipment at the 8 Station that in your judgement Station personnel or other Duke 9 personnel would either advise or instruct or to the extent that 10 they have the authority, call for protective action in the form 11 of let's say an evaluation of persons offsite?
12 L Would you repeat the question, please?
13 4 Do ycu think there is a point at which things are 14 serious enough on the basis of what you knew is happening in 15 containment or through the effluent monitors that you have 16 available to you that you or Duke would call for an evacuation 17 without reliance on implementing the field monitoring?
i l
18 A Yes, that is uhat I've said.
t 19 4 Help ne understand what kind of Oonditions; I am not trying l
20 -- to the extent that you have already teld me they vary --
l l
21 help me under tand what kind of conditions.
22 L That uculd depend on the situaticn and the kinds of 23 thinCs that we could have. For enanple, you would have different l
l 24 kinds of notecrological capabilitics, clatscs, depending on what 25 kind of at=c phoric conditions you have. Material could leave EVELYN BE RGER ASSOCIATES. STENOTYPE REPORTING SERytCE. CH ARLOTTE. NORTH CAROUNA
Eirch - Direct .. 73 3
the site if it were released and remain cicee to the site or it
(
could mix very cuickly offsite, so you have various dose rates 2
3 depending upon hoy it mixes as an example of something thtt is 4
going to affect it.
4 S an I understanding correctly there is no level of 5
6 Seriousness where you would --
A It is a potential for dose offsite, and that is dependent 7
8 upon the cource material and meteorological conditions and the 9
topography. ,
10 Q Yes, well, so you would have to rely in your judgement 11 on informatien beyond the information available from the monitor-13 ing systems in place at the plant or in order to make any judge-13 ment about the emergency response?
A You must do calculations using the information from 34 15 those monitors to make a judgement, and then it is a judgement 16 based on the conditions. You have all of the perameters avail-17 able to you to nake that judgement.
18 4 Don't we understand now you aloc have to have additional 19 information beycnd simply the read out from those monitors? In 20 other words, you have to have meteorological --
21 A Yes , tenitors only call infornation, it doesn't assume l
22 you do net have that.
23 Q Yes, but you h2ve to bnve coreti-inc. besides the read 24 cuts on the Ccntrol Room from the centefr.ent meniter, the stack 25 nenitor or the steam dump?
EVELTN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
m Birch - Direct 74 i
A That's correct.
2 4 Now let's turn about a little bit. How did you get 3 the additional information? Lay aside the radittien monitoring; 4 how did you get the additional information needed to regulate 5
the dose projecticn?
6 A The meteorological calculation?
7 4 Yes, if that is one, I want to know, Ms. Birch, how 8 you get the additional information that you need beyond the g results from the monitors, the radiation monitors in place at 10 the plant in order to take adequate protective action in the 33 event of an accident?
32 A There is meteorological equipment en site; that informa-33 tion is provided in the Control Room.
y 4 Where does that information come from?
15 A From the meteorological sensors in the tower, but I 16 don't know how it is done specifically.
3- 4 There is a tower?
jg A There is a meteorological tower, yes. Details of the 39 meteorological equipment should go with somecne r. ore familiar 20 with it.
21 4 You are not a meteorologist? Is there not a meteorolo-22 gist e= ployed by Duke Power, to your knowledge?
23 A YCD*
24 4 Who is that?
25 A I believe we have more than one; Steve Apple, and I don 't EVELYN BERGER ASSOCIATES. STENOTYPE RE PORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Birch - Direct ,,
75 i mon the other fellow's nane.
2 Q t.ll richt, is thct infor- ation that you need to do the 3 Or.lculations -- ,.
4 A Yes.
5 C I would.like to ask you that your area, is it fair to 6
cay your training is in Radiation Protection, Health Physics, 7
<?inclear Engineering and not Meteorology?
g A That's right.
9 4 And you rely en soneone with expertise in that area 10 to' interface with you?
11 A That's correct.
12 4 To the extent that you know, and if it is beycnd the 13 area known- to you please say so; but what meteorological 34 infernatien do you know is necessary in order to take protective >
15 action?
16 1 h'ind speed, Wind direction, delta temperature; and I 17 Guess you uculd like to know if it is raining or not snowing, 18 whatever.
l 19 Q Precipitation?
20 A YC E, .
21 Q What do you mean by delta tenperature, please?
22 l- Difference between a hirh and a lcw reccing on the ,
23 tower, itcelf.
24 4 Mich, lew, in what direction?
25 A There are different elevations, but I can't tell ycu EVELYN BERGER ASSOCIATES. STENOTYPE REPOMTING SE RylCE. CHARLOTTE. NORTM CAROUNA
- , . . _ _ _ _ _ _ .-. _ . _ _ . . . . . , . . , . , . . _ _ . . - . . - , , - , _ . _ _ _ _ . . . _ = . . . _ . - _ . . , _ _ . _ _ _ _ . _ _
Birch - Direct 76 1 'uhat they are .
2 4 Chere are tenportture readings taken at differEnt ele-1 3 vaticns on the me.tcorological tower, and that difference you
. 4 refer to is delta change?
4 5 L Yec . delta neaning. chsnge in tenperature.
.6 4 What do you understand the significance of the delta l
7 temperature information to be, Ms. Birch?
8 A In varying conditions?
l 4 9 4 What is the significance of delta tenperature change 10 in varying conditions?
- 11 A It netnc that the caterial will remain on the ground.
9 12 4 It will fall to the ground?
13 L Yes, or retain, I said.rentin. We are assuning these 14 are ground roles.ses.
I i 15 4 I see. Well, none of these are, in fact, ground re-d
. 16 leases; they are all at sene levol above ground, are they not?
17 A Yes, at roof or stack elevations.
4 18 4 What other source wculd neteorological information, L
f
'; , ; 19 beyond the n:teorological tower en cite is relied upon by the k
l- 20 Cenptny to take protective acticn?
l .tv
, .?, . - 21 A They htve the availability of the local :neteorological
$ 's 22 conditions in general cuch as thc airport.
l l 23 4 Uhat in at the airport , !'r . nirch?
! ,' 24 L Tne United States Ueather Service, isn't it, with their l
l 25 - wenther infernatien.
i
- j. EWELYN BE RGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE. NCRTM CAROUNA
,, .__ ._.._,_____.._.,-,__,,____.___-.~_.,_m._.,.,-.,,._.._-,, ,,.m . _ . . _ , . _ . , _ . ~ . . . , _ , . - . . . _ . , -
. o Birch - Direct -
77 1 Q They provide from the airport the came information that 2 the meteorological tower provides?
3 A That , I 11on't know. They provide meteorological infor-4 mation.
5 4 Is any other source other than meteorology that you 6 know of that is used relied upon by the Company?
7 A We have a lot of historical data on the site.
8 4 That is used for protective purposes?
9 A Yes. '
10 4 How about other real time shall we say?
11 A Meteorological data, I am not aware of any.
12 4 All right, will the plan for the Catawba facility rely 13 on meteorological data collected by field monitoring teams?
14 A No; field monitoring teams do not collect meteorological 15 information.
16 4 Let's talk about those field monitoring teams. I am 17 going to ask you if you would first, Ms. Birch, this is the first 18 time I've seen this particular Document [ indicating]. This 19 is identified as Revision Two, January '53, of the Catawba Nuclear 20 Station Emergency Plan.
21 Can you tell me whether or not the procedures for field 22 monitoring in the event of a serious accident at Catawba are yet 23 included in that Document?
! 24 A Section I of that should indicate the composition of l 25 the teams, I believe.
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Birch - Direct 78 i
4 lb. Birch, for both Oconee and McGuire you have referred 2 rather to detailed procedures from varicus manuals that describe 3 the functions of,the field menitoring team. Are those detailed 4
procedurcs availabic for Catawba as f . cs you know?
5 A I'm not familiar with whether sney are completed at this 6 point. There are Station procedures, Crisis Management implementa-7 tien procedures.
8 4 Do you know, perhaps we can short circuit this a bit, 9 would it be appropriate to agree that the detailed Health Physics 30 and Emergency Procedures for Catawba that are available and have 11 been made available for Oconee and McGuire are not yet available 12 to us?
13 MR. McGARRY: I do not know the status.
34 MR. GUILD: Can we agree , Counsel, they are not 15 available to us this morning? They are not here amongst 16 the Documents that have been made available to us?
17 MR. CARR: That's correct.
18 MR. GUILD: But for the variations in meteorology 19 and the site differences at Catawba and McGuire not l
l 20 being at the same site, is it a fair conclusion that 21 the McGuire procedures are similar to the procedures
! 22 that are in process now for Catawba?
23 MRS. EIRCH: How similar is similar?
24 l 25 BY MR. GUILD:
1 EVELYN SERGEP ASSOCIATES STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CARQUNA
Birch - Dirnet -
70 1 4 I would like for you to identify the differences.
2 A Well, I have already identified differences.
3 4 Let's direct your attention specifically to the McGuirc 4 procedures, if we can, Ms. Birch. You had those available to 5 you a minute ago. Let's see if we can find them.
6 The two Documents that you looked at earlier, are those 7 the procedures for McGuire?
8 A Those are implementing procedures, and implemental 9 monitoring, yes.
10 4 Do those represent the description of the procedure 11 that would be followed by the field monitoring teams at McGuire 12 in the event of a serious atmospheric release?
. 13 A Yes.
14 4 Is it your underctanding those procedures are similar 15 to that which would be provided for at Catawba?
16 A Yes, they would be similar.
17 4 If you know of significant differences now, please so 18 state so the Record will be clear.
19 A I have indicated differences such as meteorological i 20 differences will vary. We have been through that.
21 4 Are there parts of thoss plans that would be different 22 for Catawba?
23 A The site is different, there will be different areas 24 of land and water.
25 4 Let's talk specifically, perhaps it will be clear what EVELYN BERGER ASSOCIATES. ETENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CARouNA
Birch - Diract 80 1
,happens when an initiating event occurs at Catawba such as that site personnel implement the c=crgency procedures that we have reference to. What happens to the field monitoring teams once 4
they have an indication there is an activity in the containment above the procedural level that will be set. They will place 6
the teams in the field. How does it work?
A I don't understand what you mean. There are call out procedures and all kinds of procedures. I'am not sure I under-9 '
4 That is what I am asking you about, how do you physically get the team in place to perform the necessary function that the field me:11toring teams are to perform?
A The people will be supplemented by people not presently at the site but on call.
14 15 4 All right, and lead me through the steps that will take 16 g A First of all, you have some site assembly where all g your personnel on site are in identifiable locations;'and'fiom 19 l
gg If they are Health Physics, you would take them there.
21 4 You have to go through the ccheme of different personne l?'
! A I can't give you the details of them, they are identified g in the crisis plan. There is a cite assembly.
34 4 All personnel on cite are in a roem?
l 25 A Not nececsarily a room, but they are assembled in varicus l
l EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NO%TM CAROLINA
c- .
Birch - Direct 81 i
locations based on the potential for consencus of the accident; i
2 and then there is a general emergency where the personnel, un-3 necessary personn,el,are evacuated from the site.
4 4 Yes, when do the field teams get sent out?
5 A Whenever there is some indication that there is a 6 potential, by their procedure, for activity that would be in 7 their Station procedure.
8 4 You have a Station procedure in front of you?
9 A No, I do not have a Station Procedure Plan. I have 10 a Henith Management Plan and Management Crisis Center Plan. For 11 example, the' Health Physics Manual Section references five dif-12 ferent procedures and a Station Directive.
13 4 Would you make those references explicit?
14 A Station site assembly and evacuation, Health Physics, is release of radioactivity, technical specifications, Health Physics 16 procedures, 1~,009/10,- release 'of radioactive material exceeding-17 technical specifications; -
18 Emergency Procedure 5,006 Alert, and Emergency. Procedure 19 A, 5,007 Site Area, Emergency Procedure 5,008, Accident Energency--
20 4 Are those Documents available?
21 1. No.
22
! 23 [Whereupon the Deposition Adjourned for a luncheon 24 Recess.]
25 EVELYN FERGER ASSOCIATES. STENOTYPE P.EPORTING SE RVICE. CHARLOTTE NORTM CAROLthA
Birch - Direct 82 1
MR McGARRY: Before we start back up on the Depoe i-2 tion I would like to put one thing en the Record. Durdng 3 the break as to Mary Birch's ability to comment furthed 4 on the field monitoring team, the extent of Mary Birch's 5 knowledge on this knowledge has been entered into the 6 transcript, and She h&S nothing further to add.
7 We did inquire as to the ability of Mr. Michael 8 Tuckerman to provide sone additional information in 9 this regard, and we conveyed that to Mr. Guild. We 10 were prepared to have Mr. Tuckerman attend this Deposi-11 tion and be subjected to questioning in this regard, 12 but my understanding is Palmetto Alliance chooses to 13 prcceed with Mary Birch.
14 And with that statement on the Record I have nothing 15 further to add.
16 17 BY MR. GUILD:
18 4 Ms. Birch, it is then fair, is it not, to say that you 19 are not familiar with the procedures beyond the Health Physics 20 and Station Emergency Plan excerpted for McGuire that we have 21 referenced earlier to discuss the specifics of the use of the 22 field monitoring teams in the event of a serious accident at .
23 McGuire?
24 A That is correct.
25 4 Mrs. Birch, have you ever been present on the ucene of EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CM ARLOTTE. NORTH CAROLINA
Birch - Diract .
83 1 'an operating facility where there has been an atmospheric relea se 2 cnd where emerconey plans to respond to such release have been 3 implemented in practice?
4 A Have I ever been at a facility that has had an offsite 5 release? I have been to the Oconee/McGuire Plant when they have 6 had offsite releases; fo3 implementation of the emergency plan, 7 no.
8 4 Any other facilities?
9 A TMI, but not during the time the emergency plan was in 10 effect.
11 4 What was the nature of your visit or work at TMI?
12 A I did not work at TMI. It was a tour.
- 13 4 Have you had occasion to study during that instance or 14 otherwise, the circumstances surrounding the accident at Three-15 Mile Island, the emergency response to that accident?
16 A Yes, that was part of the review that I mentioned earlier, 17 and also to look at it from the standpoint of the NESP, N-E-S-P 18 study.
19 4 Is that the Document that you have referred to earlier 20 that has been made available?
21 A Yez.
22 4 Was that study prepared as a result of that visit or '
23 input of yours for Duke Power Company?
24 A Visit?
25 4 The study of Three-Mile Island.
EVELYN BERGER ASSOCIATES. SfENOTYPE REPORTING SE RvlCE. CHARLOTTE. NORTH CAROUNA
Birch - Direct 84 3
A The study of Three-Mile Island had nothing to do with 2 the visit. You asked if I had been to a facility. My tour to 3 TMI had nothing t.o do -- you asked if I had been to a facility 4
cnd I had.
5 Q What was the relationship of the NESP study to your g visit to TMI?
7 A There was a study in the REG-Guide 1 798 requiring an 3 exposure rate monitoring system and an investigation was made 9 to determine the feasibility..of doing'.it .during the NESP. study.
in 4 Do I understand that requirement is no longer?
11 A That is correct.
12 4 Why is that, Ms. Birch?
33 A The reliability of the information from the system is 14 questionable and the number of monitors it needs to provide.
15 4 What is that?
16 A The ring around the station environmental monitoring 17 system.
is Q Ring, what is the acronym?
19 A RATS range around the station.
20 4 RATS?
21 A I didn't know I had RAT Contentien until just nou.
22 4 What inquiry did you make or did your work group make 23 about the alternative measures to implement' that proposal?
24 A All we did was we did not reconnend alternatives to 25 implementing that proposal.
EWELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROLINA
Birch - Direct , 85 3
Q Which group are you referring to? We need to clarify 2 there. 'It would help me, please clarify if there is more than 3 ene group. ,,
4 A We were talking about the TMI and NESP.
5 4 I understand TMI and the NESP. Was that also a working 6 group of which you were a part?
7 A Yes.
8 Q And When you are referring to response to the proposed 9 REG-Guide provisions for a perimeter monitoring system, was io that a NESP7 11 A That was a NESP study group.
12 4 I see, and it's the work of that group reflected in 13 the NESP Document that you have described?
14 A The NESP group is an overview to a contractor who 15 actually does the work.
16 4 Who is that contractor?
17 A SAI , I believe; but you can check it.
18 Q They are the authors of the study?
\
19 A Yes, the authors are listed specifically.
l 20 Q Can I have a copy of it?
i 91 A They changed authors during the review process because I
22 of changes in personnel. It was done by SAI Science Applications, i 23 Incorporated.
24 4 Who proposed the inclusion of a RAT requirement in the i
25 REG-Guide proposal?
i EVELYN OFRGER ASSOCIATES. STE*eOTYPE REPORTING SERVlCE. CHARLOTTE. NORTH CAROUNA
B2rch - direct 86
. A I believe the NRC since they wrote those. I don't know 3
2 who at the NRC. l 3
4 Can you give me an idea of the tire frome that proposal 4
would have b 'en under consideration?
5 A LED' 1979' 6
Q Did Duke with your involvement or otherwise pursue a 7
study of that alternative monitoring system?
A We participate in the NESP Study.
8 9
Did Duke perform such a study otherwise or was it all 10 through the IESP?
33 A No, the NESP.
12 4 Were there any site specifications made with respect 33 to any of Duke's facilities with regard to such a system?
14 A No.
15 Q And did you know anything of the circumstances of the 16 projection of the proposal for such a monitoring system as part 37 of the REG-Guide or NRC requirements?
ig A I don't believe it is a rejection, there are no require -
39 ments for such a system. There is the ! ESP Study and the NUREG 20 Documents that the NRC put out that discusses their evaluations 21 of such a system.
22 4 That is the one you have in your hand? .
23 A "An Assessment of Offsite Real Time Dose for Emergency 24 Situatior.s ," that's correct.
25 4 This Document was prepared by the NRC7 EbELYN DE RGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA
,_m_
m Eirch - Direct 87 3
. A Yce, that is what I understand.
2 Q Are ycu familiar with the authern of thic study?
3 A I have r,caG the study, but I have not been involved 4
in diccuscions of how they ctmo to their results.
5 4 All right now, I'm corry, if you uould, what was your 6 understanding of the basis for having rejected such a requirement 7 as part of a REC-Guide?
8 A I didn't say rejceted; I said they didn't have require -
9 ments for such a system. I think you would determine reading to that study that the information provided by such a syctcm did 11 not quantify the plume that you want. It may or may not detect 32 the plume depending on the amount of monitors.
13 The REG-Guide had a ring of 16 to 20 monitors, and that 34 study indicates that is not capable of doing the job with the is required accuracy.
16 4 Was there another basis as you understood for not making 17 that requirenent in addition to the accuraay question?
18 A The accuracy of the data was questionable. If there 19 arc other baces for it, they list several reasonc but that was 20 the one that I remember as the most outstanding.
21 4 To your knowledge did Duke ever censider for it's fac-22 ility such as Catauba the design and cctablishment of such a .
23 system acide from whether it was required or not?
24 A A requirement for cuch a system was not considered 25 for emergency tenitoring. He have not considered cuch a cyctem ,
EVELYN BERGER ASSOCIATES, STENOTYPE REPORTING SERvlCE. CHARLOTTE, NORTM CAROUNA e
Birch - Direct ,
GB 1
4 For any other purpose?
2 A Yes, we did concider it for normal releases.
3 4 Hou do y,cu distinguish the two?
4 A The difference in the range of =cnitcra.
5 4 Can you quantify that?
6 A Normal relcases, you are looking at the micro to milur0 7 range. In an accident you are looking at micro to milure range 8 that would be range per hour, of course.
9 Q Did you consider specific hardware for use of such a 10 system under normal conditions?
11 A Yes.
12 4 What kind of hardware?
13 A Harshaw equipment.
14 4 They are a manufacturer?
15 A Yes, as was considered Reuter-Stoken.
16 Q Uas there a meteorological component considered for 17 those?
18 A No, we already have meteorologicci equipment.
19 4 How was the information from these monitoring, pieces l
l 20 of monitoring equip. 2nt, to be ec=municated to Station persennel l
I 91 or others?
22 A The read out proposed for the system was one of strip ,
23 chart readings and micro R per heur.
24 4 At the facility?
l 25 A Yes, in one of the laboratories.
EWELYN BE RGER ASSOCIATES, STENOTYPE REPORTING SE RVICE. CHARLOTTE, NORTH CAROLINA i
Eirch - D2 rect 89 3
. 4 Was there a proposed in placement plan for these moni-2 ters?
3 A They were planned to be sited on land and two in the 4 water.
5 Q At what radius and what distance from the facility; 6 do you know?
7 A Site boundary.
3 4 What would that approximate, do you know?
9 A Depending on the plant.
10 Q Yes.
11 A I uould have to look for the Catawba Plant, what that 12 says. At Oconec it is a mile; at McGuire it is a-half mile, 33 and Catawba is somewhere between the two, I think, but I am not 14 sure what it ic right now.
15 4 So less than a mile?
16 A Yes.
17 4 How many detectors were proposed; do you know?
18 A Six.
19 Q Would the information from such a proposed system, Ms.
20 Birch, be useful in your judgement under accident conditiens?
21 A The system as proposed was strictly for environmental 22 release, level releases, and not for accident levels.
23 4 I understsnd your answer, but in your judgetent would .
24 it have been useful in accident conditions, althcugh designed 25 for measurements of normal releases?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SE RytCE, CHARLOTTE. NORTM CAROUNA
Birch - Direct 90 i
A No, I don't believe it would have fron the star.dpoint 2 thc.t if you loci: at the NESP study they placed one of thoce 3 systems around the TMI and cvaluated what the nenitors were 4 cceing during the accident; and they did not see the plume with 5 any accuracy and they put 16 or 20 monitors.
6 Q In your opinion Would the uso of such a Systen EU de-7 ceribed in this proposal not provide additional confirmatory 8 information to the nonitoring already in place?
9 L I don't believe that system would have provided additicinal 10 information because the ranges were wrong for an accident situat ion; 11 and the other thing is that that information could be more mis-12 leading than it could be accurate.
13 4 Why is that?
14 L If you only have four nonitors on hand you have a . lot 15 of space between them and that is like one at each compass point .
16 The plume could go between the monitors and never be detected 17 by the conitors.
18 Q Ms. Birch, when was such a proposal made?
19 L A proposal was not nade at Catauba, it wasn't considered 20 at Catawba.
21 Q When was such a proposal made though?
22 A The proposal was made in '73 or '74, somewhere in that 23 range.
24 Q For you said another facility?
25 A Yes, at McGuire.
EVELYN SERCER ASSOCIATES. STINOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Birch - Direct 91 __
4 And were you involved in that study, that proposal?
1 2 A At that time I was not involved in the actual decision ,
3 no. To come up with equipment selection, to look at what was 4 possible there, yes.
5 C Some of the equipment sc1cetion and I'm sorry, the last 6 part of that answer?
7 A To look at the possibility of what was available for 8 equipment, yes; I looked at that.
9 4 And who else participated in that study or in making 10 that proposal, Ms. Birch?
11 A I'm not sure I can remember everybody that would have 12 been involved.
- 13 4 Just do your best.
14 A My boss at that time, Mr. Lewis, someone in Design, 15 Electrical, possibly Charles Putnam.
16 Q Would he fit that description, Design ~ Electrical?
17 A [The Witness nodded her head affirmatively.] I'm not 18 sure who else.
19 4 What was your work at that. time;cma you recall what N your responsibility was then?
21 A Yes, it was either in the time frame of ry being Assist-22 ant Health Physicist, or starting to work on the programs and 23 procedures function in Health Physics.
24 4 By the way, Ms. Birch, were you responsible at this 25 time for writing the procedures that we had reference to, the EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CM4RLOTTE. NORTH CAROLINA
,+ . - . . . ~ . . _ _
. - _ . _ _, _~ . - . . - - . . . . , _ - - - - , - . - _ - - _, -- -
Birch - Direct ,
92 i licGuire Health Physics procedures?
2 A No.
3 Q Was that before or after your tire?
4 A The programs and procedures funct'en, if you are asking 5
me about that, geviews procedures but docs not write the=.
6 4 Vere you responsible for revisning them?
7 A Health Physics related, yes, g 4 How about the McGuire?
9 A No, that procedure has been written since I did that.
io 4 Uho nas thin proposal made to?
11 A Proposal?
12 4 The proposal for this routine real time system?
13 A I'm not sure I understand how you mean the word, " Pro-14 posal."
15 4 Study, recetmendation, whatever ters you want to under- -
16 stand the suggestien that at McGuire thereby this system?
17 A I don't know, I provided input.
18 4 Did you ever see the product of the work, a final written 19 report, any kind of written report, oral report?
20 A No, I'n not familiar with any.
21 Q You saw no report whatsoever t.s a result of the work?
22 A There nay be memes to file or notething, but I haven't 23 seen them.
24 Q Would Mr. Lewis have one if he were --
25 A He cay, I don't know.
EVELYN BERGER ASSOCIATES STENOTYPE NEPORTING SERVICE. CHARLCTTE. NostTH CAROUNA
r Birch - Direct gg If I can, I'n ,juct trying to understand the basis for 1 Q 2 scre of your earlier answers. There were no Docu~.cnts that 3
reficcted any of.this, and that is what I've understood you to 4 say. Can I ask you the basis fer your earlier answers specifying 5 the types of equipment and read out provisions, et cetera?
6 A What?
7 4 How do you know all of this if there 'was nothing --
8 A I looked at what the manufacturers provided.
9 4 How do you know there was a specific proposal for two 10 en water and four on land?
11 A You didn't ask the question whether we had them or not, 12 4 UcIl let's ack that one; do you have them?
13 A Yes.
14 4 Where are they, are they at McGuire?
15 A Yes, at McGuire.
16 Q I'm not trying to rf.ke this anymore unpleasant, Ms. Birch.
17 If you have an answer on the tip of your tongue, please do co-18 operate. I'm trying to make this as quick as possible. If there 19 is an obvious piece of information the absence of which will 20 distort the Record, I would hope that you would supply it.
21 l Is that system described in any of the available McGuire l- 22 Documents, FSAR for McGuire?
23 A No.
24
[ 4 Why not?
r 25 A It is an er.perimental piece of ec.uipment.
EVELYN BERGE R ASSOCI ATES. STENOTYPE REPORTING SE RvlCE. CHARLOTTE. NORTH CAROUN A l
Sirch - Direct , M 3
Q Does the I;RC kncw about it?
2 A I don't know.
3 Q Fr. McG?rry know tbout it?
4 A I don't know, I don't recall if we discussed it or not ,
3 h*c probably did, I don't know.
6 Q Mr. Carr know about it?
- A I don't know.
3 4 Mr. Quellette know about it?
9 A I don't know for sure.
10 Q In your answers to Palmetto Alliance's Interrogatories 11 did you indicate the existence of such a system?
12 A N0' 13 4 Tay not?
14 A I don't think it is pertinent to environmental monitor--
15 ing for an energency situation.
16 4 That is the basis for your not answering the question 17 indicating the existence of such a system?
18 MR. McGARRY: With respect to the answers to Inter -
19 r0Gatories, it is Applicenth position we answered all 20 Interrogatories that were directed to us in the appropri-21 ate fashion.
22 If there was no reference to this system at McGuire, 23 then our position is that that question was not asked 24 or that information was not responsive; and therefore 25 was irrelevant so we Object to any questions further EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
, e . w, , , , , -
Dirch - Diroet 95 1
in this regard.
2 MR. GUILD: Mr. McGarry ceens to cast a significantly 3 different light tc all of the Corptny's responses to 4 real tire nenitoring systers; and sir, I would hope to 5 to fcund in errer if ny assurption that you have not 6 disclosed this is accurate, but I an not aware of an 7 answer to any of the questiens that indicated an answer s that it uns in place, whether it uns routine or otherwise.
9 It is ny positicn it is a significant piece of in-l t
to fornation that should have been disclosed. I would like l
11 to know whether you vere annre that it existed up until 12 this pcint, sir?
13 MR. McGARRY: I'n . net going to answer that because 14 I'm not under Deposition. You have stated your position is en the Record and we have stated ours. Let's get on 16 with the Deposition.
17 MR GUILD: Are you instructing your Witness not 18 to ansucr questions on the subject?
19 MR. McGARRY: I'n not instructing ny Witness not 20 to ansuer. I have noted my Objection.
21 22 BY MR. GUILD:
23 0 Mrs. Birch, I'm interested in the systen. It is per-24 tinent, if they were to try to find a Docunent that described 15 this systen do you kncu how I would go about identifying such7 EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CARQUNA
B2rch - D2 rect c6 1
A There may be a system description.
- C 10 there ene to your knowledge?
3 L I don't J:nou, there may be ; I would have to go back 4 c.nd look. I haven't looked at this in seme time.
5 4 Are there written procedures that in any- tay detail 6 the operation of this system to your knowledge?
7 L There arc, I believe, procedures at the Staticn to 8 cover routine looks at it.~The system is not operable.
9 4 How do you mean that?
10 L I mean it is not operabic, it is not capable of being 11 operated at the present time.
12 4 Why not?
13 L Eardware problems.
14 Q What sert of hardware problems?
15 L It is on a construction site whose cables have been cuS.
16 4 Accidentally?
17 A Yes , and after they have been placed a limited number l 18 of times the data output is poor.
19 Q Do I understand that the read out from these monitors l
20 subscquently cperating goes en a print out?
f 21 A It goes on a strip chart.
l 22 4 Tell ec what a strip chart is, Mr. Birch.
! 23 L It is a piece of paper that rotates and it has either 24 a scale, in this case I believe it is in timo and units of, and 25 the other unit en the scale wculd be in micro R. You get a pen EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROUNA l
- -<, _ no-ooe 97 1 tracing with tine.
2 During what period was this systcm operating?
Q 3 A A few nonths after its initial installation.
4 4 When would that have been?
5 L Around '74, '73, scnething in that time frtne.
6 Have you seen the strip charts?
Q 7
A I've seen one.
8 4 Uhere is it?
9 A I would assume it is at the Station.
10 Do you know who the custodian of that is?
4 11 I imagine it is in the Master File at the Station.
A 12 4 \Tnat is that7 13 The Document storage area at the Station.
A 14 Who would be responsible for the custody of that Docu-C 15 nent?
16 I don't know who is responsible for the Master File.
L 17 Who is the nanager of the Station?
Q 18 A Morris Macintosh.
19 Q Do you know who would be respcnsible for any written 20 procedures that related to the operation?
21 It would be the Station's responsibility to have pro-A 22 cedures for operation.
23 Q Who would be responsible for maintaining those, having 94 custody of thoso?
" A Station Ecalth Physicists.
EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOMTM CAROLehA
Birch - Direct - 90 4 Who of the Station Eealth Physicists, if that is the 1
2 person responsible?
3 A Terry Keane.
4 4 Spell that last name.
5 A K-E-A-N-E.
6 4 Has such a system been considered or in place at Oconee ?
7 A No.
8 4 I believe in examining a copy of this NUREG, An Assess L 9 ment of Offsite Real Time Dose Measurement Systems for Emergency 10 Situations --
11 A Yes.
12 4 You are aware of this?
la A Yes , I have read it.
14 4 Do you agree with its conclusions as rejecting the use 15 of such a system, I will paraphrase it?
Is A Yes.
17 4 Again, it is similar to the characterization that you 18 made that if, I will paraphrase, combinations of cost and accur-19 acy --
20 A I didn't state cost, I stated accuracy; but you could 21 consider cost for the accuracy that you are getting, yes.
22 4 Well, number of stations determines accuracy level in 23 part, does it not?
24 A Yes.
25 4 And the more stations, the higher the level of accuracy EVELYN SERGER ASSOCIATES. STENOTYPE RE*ORTING SERVICE. CHARLOTTE. NORTM CAROLINA
Birch - Diract 99 1 likely to track a plume in an accident situation?
2 A !! ore likely that you would, yes.
3 4 And the . higher the number of stations, the higher the 4 cost?
5 A Yes.
6 4 And to the extent that the number of stations and accur-7 acy are related to cost, cost then becomes one of the consider-8 ations?
9 A Yes. -
10 4 You are aware, are you not, Ms. Birch, that a number 11 of operating cnd the nuclear facilities in operation and under 12 construction do, in fact, have real time monitoring facilities?
13 A I am aware that the facilities have installed those 14 systems.
15 4 I am going to show you Table 8 at Page 47 of this 16 Document, if Cou.15e1 has a copy to make available that would 17 be good. You are aware of that Table; have you seen it before?
I 18 A Yes.
19 4 And that displays 1,2,3,4,5,6,7 facilities that are l
20 indicated as having such real time installed systems?
l I
. 21 A Yes.
I 22 4 Have you made any inquiry or study of the systems that -
L ..
! 23 c.re indicated as being installed at any of those facilities?
24 A Did I check to find out whether they worked as they 25 had anticipated?
FWELYN BERGER ASSOCIATE 5. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
Birch - Direct -
100 1
4 Any inquiry, study, whatsoever?
2 A No, I have not contacted them.
3 4 Please bear with me, and if you have any information 4 I am interested in what you have.
5 A I have the information on this and the NESP study.
6 4 And that is all?
7 A That is correct.
8 Q You have not discussed the systems with any reprecenta-9 tive of these utilities? -
10 A No, not that I am aware of; no.
11 '4 Nor have any other informatien other than what is con-12 tained in the two Documents you have just mentioned?
13 A Unless I talked with a vendor about the fact he has 14 supplied them to someone. -
15 4 Have you done that?
16 A I have discussed them with the vendors. They have men-17 tiened it and I don't remember it.
18 4 Ms. Birch, in fact, all of those facilities, if this 19 Document is adequate, use the same hardware that comes with the 20 actual monitoring device.
21 A I am not sure whose hardware it is.
22 4 You don't know?
23 A No, there are two systems made in the United States that 24 are usually considered, and I have already mentioned those, the 25 Reuter-Stokes and Harshaw. Which are indicated here, I don't know.
EVELYN BE RGEft ASSOCtATES. STENOTYPE REPORTING SERVICE, CHARLOTTE. NORTM CAROUNA
Birch - Direct 101 1
4 While I'm looking for that, I will ask you come other 2 questiens about this Document, Ms. Birch; cnd if you would refresh 3 your recollection. and look at it a little bit, it will be pro-4 ductive use of time, I believe.
5 Would you accept that according to this lIUREG NCR 6 Document, Reuter-Stokes Century 1011 tre the systems in place 7 at this facility?
8 A I don't recall reading that.
9 4 How about Page 38.
10 A Okay.
11 4 Do you see that reference?
12 A It says it has been installed at several nuclear power
- 13 stations in the U.S. A. It did not say it has been installed at 4
14 all those on the list.
15 4 I don't see that language either. I understood that to 16 be the case. Are the two systems made in the United States, 17 the Reuter-Stokes and the Harshaw to your knowledge?
i 18 A. Pardon me?
l 19 4 Those are the two systems manufactured in this country l
l 20 and are manufactured as far as you know?
21 A The Harshaw and Reutcr-Stokes.
22 4 Are you aware that the station netr Columbia enploys 23 one of those systems?
24- A Yes, it is on the list.
25 Did you know that before I showed you the list today?
4 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTM CAROLINA L
Birch - Diract . 102 1
. A I read it in the listing earlier.
2 4 Do you have any independent information about that 3
installatien independent of this list?
, A I don't recall talking to anyone at the Virgil Sumpnore 5 Plant about it.
6 4 How about somebody at Reuter-Stokes or Harshaw?
7 A They may have told me about it, but I don't recall it.
3 4 Did you ever talk with anybody at the NRC about it?
9 A It being the Rcuter-Stokes. system?
io 4 Yes.
11 A Frank Congel of the NRC was on the NESP Task Group.
12 4 Spell his name.
13 A C-0-N-G-E-L, and we discussed the Reuter-Stokes and the 14 Harshaw systems. I don't recall any reference to a specific 15 plant.
16 4 I'm sorry, other than Mr. Congel, do you have any other 37 information concernin2 any of these systems independent of the 18 Table in this Document or the NESP study?
19 A I answered that previously; no, I'm not aware of any 20 conversations on these systens other than what was discussed in 21 the NESP study.
22 MR. McGARRY: I'm sorry, I didn't pick up that ,
23 questien. It may have been confusing. Could we have 24 that question repeated?
2~
j evrown ernaea associares. srs~orves aseoama se=vice. cuaatorra aonrw camou=4
Birch - Direct 103 i .BY MR. GUILD:
2 4 Sure, I would be happy to. L' hat I'm trying to under-3 stand, Ms. Birch, I truct you are not withholding any informatibn, 4 if that in the bottom line, that is the point.
5 If you have any other information I don't mean conver-6 sations necessarily, if you want to be ovsrly technical; but I 7 understood you to expreSL some reservations about your answers.
8 If you have none --
9 A The only information that'I have is the vendor litera-io ture that may have indications.
11 4 You do have vender literature?
It A Yes, I have files of vendor literature.
13 4 From these two manufacturers?
14 A And probably from some of those made outside the United 15 States.
16 4 Guardian?
i 17 A I'm not cure what the name is. It is represented by 18 somebody out of Minnesota.
19 4 I don't recognize the name in here, GCA. If you could i
20 help me understand, Ms. Birch, the nature of the vendor litera-
, 21 ture.
l 22 A Foldcrs indicating they have this equipment to sell and 23 a basic description of it.
I i 94 4 It is publications of general circulation by these ven-l 25 dors?
EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTH CAROLINA
Birch - Direct -- 104 1
A Oh, yes.
2 4 Exclusively?
3 A I'm not.sure what you mean.
4 Q Did they write you a letter saying Ms. - Birch, we would 5 like to furnish you this literature?
6 A Sure, I am sure I have it.
7 Q Which vendors have you received such proposals from?
8 L Reuter-Stokes, Harshaw, and I'm not --
9 Q Slow down if you would.
10 A Router-Stokes, Marshaw, and a British firm represented 11 by a company out of Minnesota. It is not GCA, that is not the 12 name that is familiar to me. I may remember the company that is 13 representing the firm.
14 4 Does Mypax sound familiar'c 15 q A No.
le Q Guardian?
17 A. No.
18 Q PAR Systems?
19 A PAR Systems?
j 20 Q yes, 21 A Is there a trade name for their equipment that is refer -
l 22 enced there, PAR?
l 23 Q Just PAR. Did any of thoce vendors make a propocal for l
24 a system at Catawba?
(
! 25 A Ho, unless it uns unsolicted; and in that case I wouldn't EVELYN BERGER AC50CIATES. STENOTYPE REPORTING $ERVICE. CHARLOTTE. NORTM CAmoumA
Dirch - Direct 105 i .know about it.
2 Q Uhy wouldn't you know about it?
3 A Generally it rould go to our Decign Department.
4 Q Your testimeny is you dcn't know of any unsclicted 5 proposal?
6 A I am not aware of one.
7 Q The proposals that you have received, have they been g for other stationc?
9 A I have not received any preposals. I an only aware io that we would have received one would have been on the McGuire 11 system.
12 4 Is that the routine sycten that we had discussions about?
13 A We discucced it, yes.
14 4 As far ac proposals for real time systems, Reuter-Stokes 15 and Harshaw, do I understand they were not with reference to any 16 cpecific station? What did you get from them?
r l 17 A All I've gotten from the vendors have been general in-18 formation saying they have the systems available and some basic l
l 19 informr. tion on what the systems do. I have not received a pro-l
( 20 posal from these vendors.
I ol .4 Did they quote you a price for their equipment?
22 A They may have given a ball-park figure, but that would 23 have been part of the proposal.
24 Q Uhat is Mr. Congel's positien with NR0; do you know?
25 A I believe he heads the Radiological Accesenent Branch, EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
Eirch - Diract . 106 but specific title, no. It just styc United States Nuclear i
R gulatory Conmission.
2 Ms. gh, have you served on any other professional
-3 bodies with respect to the subject of radioactive monitoring?
5 l- I'm not sure I understand. Have I been involved in 6 her technical bodies involved with radioactive monitoring?
i 4 Yes, g
A Yes.
9 4 Would you name those for me?
A AIP sub-committee on Radiolo5 i cal Effluence, text book! ;
10 33 which talk about radioactive monitoring.
12 4 What capacity did you serve en that?
A I was on the sub-committee.
13 34 4 Anything else?
15 A No.
16 4 The NESP study, other than that?
g A No.
18 4 Have you ever presented testimony before the Nuclear 3g Regulatory Commissien or any of it's Boards on the subject?
gg A No.
21 4 Any other testimony on the subject of radiation monitor -
22 ing?
g3 L No.
24 4 I unnt to direct your attentien, Ms. Birch, to Pages 34 through 36 of the CR Document you have had reference 25 NUREG EVELYN BERGER ASSOctATES STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAmouNA
- - , e
Eirch - Direct 107 1 to, 2 A Yes, 34 through 36.
3 4 Generally it talks about the spccifications for the 4 subject field stations that they were investir;ating.
5 g yes, 6 Q Do you agree with their state =ent that plus or minus 7 ten percent represents a reasonable accuracy level for such a 8 field station?
9 A The actual detector and electronics, yes.
10 Do your processor effluent strer.n nonitors meet that 4
11 standard of accuracy in your opinion?
12 A The actual nonitors in their electronics read about the 13 same.
14 Plus or ninus ten percent standard?
4 15 A Yes. I would say it is around that.
16 IIaybe less7 Q
17 A Maybe less, yes, it is going to depend upon where you 18 are in the range.
19 4 What range 7 20 A The range of monitors that we have discussed earlier 21 this morning.
22 Uhere would the accuracy be likely less than ten percent?
4 23 A At the leu range.
24 The icw end of the low range?
4 25 g yeg, EVELYN BERGER ASSOCI ATES. STENOTYPE REPORTING SE RVICE, CHARLOTTE. NORTH CAROUNA
Eirch - Direct ,.
108 1
4 Close to background?
2 A Yes.
3 Q Do state, of the art Thernolumineccent desincters meet 4 the accuracy level in your opinion?
5 A It depends upon what vance you are talking about. It 6 is probably a little bit higher than that. It depends upon how 7 long it is in the field, the fade characteristics.
. 8 4 How long in the field would it have to be to meet a 9 ten percent accuracy level if it met that at all, Ms. Birch?
10 A Environmental dosimeters, because they are there for 11 a long time, at least a month, a quarter, there is sene fade.
12 I am not sure when it would be at that point.
t 13 4 What accuracy?
14 L I'm sorry, I an not sure what time it would be to meet 15 that.
16 4 What accuracy level would a TLD state of the arts TLD 17 achieve in place after a month?
18 A I think your number is probably reasonable, plus or minus 19 30 percent, 20 percent.
20 Q For one month does it get worse than that if it stays 21 a quarter?
22 A Ho, that is about the minimum.
23 The fade will occur depending upon the material, but 24 it would be generally in the first week or two it is going to 25 icyc1 out.
EVELYN bERGER ASSOCIATES, STENOTYPE REPORTING SERysCE. CHARLOTTE. NORTH CAROUNA
Birch - Direct 300 1 4 Do the LTD's in place at your operating facility meet a a
2 that description?
3 A yoc, .
4 4 Do the LTD's proposed to be used at Catawba meet that 5 description?
6 A They are the same as used at Oconee.
7 Ms. Birch, on the cost information present in the 4
8 NUREG CR Document that we have referred to, is it consistent 9 with your knowledge and information' about the cost of the cenponent 10 and is it consistent with the NESP, consistent with the vendor 11 information you.have received?
12 A I have not seen specific dollar figures for these from
(
13 the vendors.
14 4 You know of no errors contained in the CR Documents 15 in the terms of cost?
16 A No, they give a fairly broad range, and I think that 1
17 is realistic.
18 Do you agree with the statement I have indicated on 4
19 Page 30 of this Document that the installation of a 100 unit 20- detector systen is not practical, feasible or cost effective?
21 Where is that on Page 30?
A 22 Let's see if I can find it for you.
4 23 l A I see it, it is in the last line above that ; I agree.
i 24 4 How nany detectors of the levels of accuracy and descrip-25 tion assumed in the CR Document do you believe would be necessary l
E VELYN SERGER ASSOCIATES. STENCTYPE REPORTING SERVICE. CHARLOTTE. NORT>e C AROLINA c__.. __ _ , . . _ _ - _
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in order to achieve ts reasonable icvel of accuracy in an accident:
setting?
2 3
A I believe. if I recall reading frequently in here, they 4
are talking about a five percent area in a system of about 40 5
or 50 detectors..
6 E_m interested in you opMon,14s. Meh. Do you 7
tmderstand the question as asked? I would be happy to repeat it, 8
g A Go ahead.
10 4 I am interested in your opinion as to the nunter of 11 station detectors of the assured accurney level es described 12 in this document nececenry to reprecent an adecue.te level of 33 accuracy in an accident setting.
34 L I would say probably around 150.
15 4 Phe.t level of accuracy would 150 stations represent 16 n yCW opinion?
17 1 Probably 20 to 30 percent, depending on what kind of 3g data output you have.
19 4 Uhat kind of data output would you assure?
20 A So:e kind of processing unit computer.
21 4 !*eteorological?
22
/. Yes , you would have to have noteorolo;-ical dr.ta in-23 cluded with that.
24 C The detectors as a::suned, ac described in thic docunent 25 eith those two pieces, CPU and reteorological date.?
EVELYN BERGER ASSOCsATES. STENOTTPE REPORTING SE RvlCE. CHARLOTTE NORTM CAROUN A
111 Pirch - rirect 1 A Yes. .
2 4 Hou that 20 to 30 percent error that you ::pcke of --
3 A Would be- from the center plune line.
4 4 The area projecting frcn the center plune line?
5 A Ye s . .
6 4 Now keeping our standard of reference equal for compari-7 tive purposes, Ms. Birch, what level of accuracy does your syste:n 8 propose for Catawba to achieve in projecting that sane quantity, 9 the center line plune dose at a given point?
10 A Using the field monitoring teams?
11 4 Use the entire systen you have proposed.
12 A Usually within that sane error range.
13 4 20 to 30 percent error?
14 A Yes. For the monitoring, itself, yes; now the total 15 system you have to have is something to compare against.
! 16 4 I don't understand.
t i 17 A The question is are you conparing it against true value !
18 or neasured value at the stack.
19 4 Those are two different things?
20 A You have an error in the nensurencnt and the stack.
l 21 4 So it depends on how you are looking at it? Uell, I 22 will look at it the same way you look at a: Real-Tine System which
( 23 you said uccid require 150 cenitors to achieve that level cf 24 accuracy. What is achieved at the stach" Let's be consistent.
25 A Okay, I want to be sure we arc. I'm saying 150 nenito: s EVELYN BERGER ASSOctATE S. STENOTTPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA
Eirch - Direct ,.
112 1
?lus or ninus 20 percent to what is being conpared at the stack.
2 4 Net at ecnter line plune?
3 A Plume dose based on your stack dose.
4 4 Isssuming : hat there is an at. curacy in the stack dose?
5 A Yes ; center line dosc is calculated from the stack re-6 lease.
7 Q What lcVel of accuracy does your present systen achieve 8 if the standard of neasurement was the actual center line plume 9 dose? ,
10 A Addition of errors , a little worse than that, I would 11 have to do an analysis and deternine.
12 0. How nuch worse?
13 A A few percents.
14 4 Several orders of nagnitude?
15 A No, it is not like the 500 percent that you are getting 16 with 130 or 50.
17 4 Do you use your field nonitoring team to detect and 18 cuantify the nacnitude of an unPnown release in the presence of 19 a known release? Yes or no, and please feel free to enplain.
20 A We vill cnly look for the release. We can't detect 21 uhether it is cenitored or unnonitored.
A 22 4 Is a fair cnsuer to my cuestion no?
23 A 7en.
24 4 Do you ute your field nenittring teams to estinate the 25 credibility er unccrtainty of the infor ation associated with EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA
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Birch - Direct 113 1 the estimated value of an unmonitored device?
2 A Would you repeat that?
3 4 Sure, do you use your field monitoring teams to provide 4 an estimate of the credibility or uncertainty of the informatior ,
5 associated with- the estimated value of an unconitored release?
6 A They provide the dose rate and the team in the manage-7 ment center will determine the validity of the data. The team 8 radios that information back.
9 4 Can you answer the question yes er no, and feel free 10 to explain.
11 A I thought I just answered it.
12 Q Let me direct your attention, I'm looking at Page One, 13 if you would look at Paragraph Three.
14 A Okay.
15 4 One of the tasks that this Document, the Study FIA 16 employed in analyzing a Fixed Real-Time Monitoring System was 17 in Objective Number Three here, and I am asking you whether your 18 field monitoring team performs that function in your judgement?
19 A No, the field monitoring team does not provide that 20 function. They measure dose rates. You are talking about the 21 information being interpreted. That interpretation of the data 22 is done by the Crisis Management Team. The team is like the 23 detector field . monitoring tean; it provides dose rates informa-24 tion. It doesn't evaluate that data.
25 4 But it's function, as you stated earlier, is to confirr Eb ELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
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Birch - Dirset . 114 1 cr otherwise evaluate the validity of the information that you 2 get from your effluent stream monitors?
3 A They provide data and the field monitoring team provide s 4 the data and the data determination is dcne by the crisis manage -
5 cent team.
6 Q So I misunderstood y'our earlier answer your field monitor-7 ing teams are used to confirm the accuracy of your stack monitor -
8 ing equipment?
9 A I meant that frem the standpoint of the calculations of 10 dese, and then you confirm the dose ratc.
11 4 Yes, but their primary function was confirmatory?
12 A Yes, they measure dose rate that confirms what we cal-13 culate, okay.
14 4 Have you made any study or are you aware of any study 15 performed by the Company or for the Company about a potential 16 reactor building shine?
17 A We have not done a particular study to see if that wou] d 18 be a problem in this case. It is a general problem at EWR Con-19 tainment Building, and the shine can seriously effect these 20 cenitoring systems. We do dose shine calculations, but I don't 21 have that.
22 4 Do you believe that building shine would be a factor 23 at the Catawba Station?
24 A It has the potential for being an interference, yes.
25 4 Is there anything particular about the Catawba site or EVELYN BERGER ASSOCIATE S. STENOTYPE REPORTING SERVICE, CHARLCTTE. NORTH CAROUN4
c-Birch - Direct 115 1 Catawba facility design that would make that shine problem sig-2 nificant?
3 A No. -
4 4 And it is lees a problem than it is with the CUR 7 5 A Yes.
6 Q Do you know whether or not specific data for diffusion 7 rate, plume diffusion rate is available for Catawba?
8 A It is in Chapter Two of the FSAR.
9 4 What is that, is that the weather data?
10 A Yes, weather data listed.
11 4 Wind shifts?
12 A You have referred me to Table 2 3.4-1.
13 A They are different Tables.
14 4 Weather data, wind data?
15 A Yes.
16 4 I am referring specifically to horicontal and diffusior.
17 rates. Are there specific values that have been obtained from 18 the study at the Catawba site?
19 A There is data present, yes.
20 4 Can you direct my attention to where that data is?
21 A I am not sure where it is in this Document.
22 4 Do you know how that data was arrived at?
23 A I'm not sure what models are used.
24 4 Do ycu know whether it is done en site specific --
25 A I know it is done on site specific basis. We are doing EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE. NORTH CAROLINA
Birch - Diract . 116 3
that for the effluent tech specs.
2 Q On the basis of what diffusion rates?
3 A No, that, is done, it is nailing it into computer codes.
4 4 What is the data?
5 A The data collected over the sites since the meteorological 6 tower has been on site.
7 4 Is it wind speed data?
g A Wind speed, direction data, temperature.
9 Q Are you familiar with the Gaussian plume model?
io A No.
11 4 So you don't know whether or not, what I'm speaking of, 12 vertical and horizontal rates, whether they are site specific 13 data for the diffusion model?
14 MR. McGARRY: We will note an Objection to site 15 inquiries that require expertise. I believe the area 16 of inquiry has been in that particular area.
l 17 MR. GUILD: For the Record I think we are talking, is I would like to understand if there is ergerical data 19 on vertical and horizontal diffusion rates for Catawba.
20 Let's understand whether or not she is stating 21 that there is such data. Then I can pursue it with l
22 the appropriate percen; but if I can show her this 23 pcGe and see if we are contunicating correctly, I am l 24 showing you Page 5; and if you uould look at the Page l
l 25 7, if you would look at the horitental atmospheric l
EVELYN BERGER ASSOCIATES. STENCTYPE REPORTING SE RvlCE, CHARLOTTE. NORTM CARouNA f
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Eirch - Direct 117 diffusion perimeter and the vertical diffusion perimeter as 2
set forth there, and tell me where that informatien is for the 3 Catawba Station and what the source of it 1::.
A The cnly meteorological are F1 over X values.
4 5
4 What does that represent, do you know?
6 A Top two terms [ indicating].
7 4 Okay, you are not aware then of hori ental atmospheric g
diffusion perimeters?
4 9 cok her head P.cGa h D .]
10 4 Do you agree with the following observation, same page, 13 came reference, "In this relationship the most critical terms 12 are the values for ..." and I don't know the Greek letters, if 33 ccmebody can help me with those. symbols, do both of these terms 34 carry a different value for each value of a doun-wind distance?
15 Unfortunately the values for symbol "Y" and symbol "C" 16 e not 3 and as such, must be detem.hd e.pedcam. Do you 17 know whether those data have been determined emperically for the ig Catawba Station site specifically?
l ig A I would have to reference Section Tr.o of the FS!R. I 20 haven't looked for those specific values.
21 Q You dcn't know?
22 A I don't 1new.
23 4 Do you agree with that observation that those are critical 24 values?
23 A I can't answer that.
EbELVN BERGER ASSOCIATES. STENOTYPE REPORTING SERylCE, CHARLOTTE. NORTH CAROUNA
m Birch - Direct .
118 1 Q Why not?
2 A I am not a metecrologist.
3 4 How can -you state with confidence then, Ms. Birch, that.
4 your current system in place projects within an accuracy range 5 of 20 to 30 percent?
6 A Based on calculations.
7 4 Excuse me, the center line plume exposure?
8 A Based on what you calculate, I feel we can meet that 9 accuracy of the instruments in the field are not a problem. The 10 same way you ack if the detectors in the RAT System were plus 11 or minus 12 percent, I can agree with you, yes, they are.
12 4 So you don't want me to underettnd that you have con-13 fidence that you can project the actual center line plume exposure?
14 A If you put those close enough together you will have 15 enough monitors covered that you should get it unless the release IC hops right over it. As long as that monitor, it goes by that 17 monitor if you have enough of those things in a ring the confidence 18 you have in the meteorological data does not really matter.
19 4 Dirscting your attention to the system in place that 20 you proposed for Catawba which does not include any site perimeter, 21 it uould seem to me you have confidence that you can project the 22 center plume exposure right to within 20 or 30 percent; but you 23 don't know whether or not there is any specific data for the 24 critical dosing plune assumptions of hcrisontal and vertical 25 diffusion factors.
EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SERWICE. CHARLOTTE. NORTM CAROUNA
Birch - Direct 119 1 I ask you then hcw can you have confidence in your 2 first statement about the accuracy of the node 17 3 A -I know the purpose and the function of the field 4 monitoring team.
5 4 Do you want to say anything else?
6 A [The Witness shcok her head negatively.]
7 4 Ms. Birch, tell me a little bit about what the problems s were with the SAMS Systens which are proposed to be released?
9 A They are battery operated single channel operators.
10 There are problems with the battery and voltage stability.
11 4 Batteries run down?
12 A The batteries really don't do a good job and the high 13 voltage was not constant, and if you don't have a constant high 14 voltage your output is worthless.
15 4 Is that a calculation problem in a nutshell?
16 'A No, instrument stability. If you recalibrate constantly, 17 yes, you could compensate for that.
18 4 What experience does Duke have in testing its radioactive 19 monitoring system for use under accident conditions, Ms. Birch?
20 A Testing?
21 4 Yes.
22 A Do you mean, I'm not sure what testing you mean.
23 MR. McGARRY: Let Counsel ask the cuestion.
24 5 BY MR. GUILD:
...tv~ ...... .. ociates. sta~orver ancoari~. sa= ice camatorre. ~oara ca ou~a l
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, , Birch - Direct . 120
~
1 4 Have you ever had a test of your system?
2 A It is checked to determine its functioning capability 3 to respond to a signal.
4 4. Yes, is it tested to see if it will behave the ucy 5 you believe it will behave in the event of an accident?
6 A It responds to radiation.
7 Q Have you ever had a drill?
8 'A Yes.
9 4 Have you ever had a drill where your field nonitoring to cystems have been tested?
11 A The teams are cut in the field, yes.
12 Q Tell me about that.
13 A The teams are cut in the field and they take the actual 14 instrumentation with' them and they actually radio data back.
15 They may report actual or ficticious data, depending upon the 16 centro 11ers decision.
17 Q How many drills have you had?
18 A Total number, I can't answer.
19 4 At McGuire?
e 20 A That I have been involved in?
21 4 Or that you know at ut?
22 A That I have toen involved in, two or three. I can't 23 recall specific numbers.
I 24 4 Ecu realistic were those drilla?
I 25 L Ren~.istic -- were there actual releasec of activity, no ;
EVELYN BERGER ASSOCIATES STENOTTPE REPORTING SE RVICE. CHARLOTTE. NORTH CAROUNA
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1 that was simulated. I would say relatively realistic, as much 2 ac you can and not actually have a release of activity. Infor-3 mation is provide.d to Linulate whtt would happen during an acci-4 dent.
5 Q How icng did it take to get the field monitoring teams 6 data from the time of the assumed initiating event?
7 A I can't answer that.
8 4 Who would Pnow?
9 A The offsite dose coordinater, the crisis management 10 coordinat or.
11 4 Who ucre those people?
12 L Lionel Lewis or Mike Glover.
13 4 Will you give their titles respectively?
14 L I'm not sure that is a title,cs far as their job respor si-15 bility, that is basically what they are doing.
16 4 What does Mr. Glover do: do you Imow his title?
l 17 L' No.
i l
18 Q Do you know his area of work?
19 A Yes, he is responsible for the Crisis Management Plan.
20 4 For the Cocpany?
21 A Yes.
22 Q Do you know when the first drill ucc appror.imately that.
1 23 uould have involved replication of this energency systen?
l k 24 A I prepared a drill in the last few months, but I can't 25 tell you whether it was Oconee or McGuire.
EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERytCE. CHARLOTTE. NOCH CAROUNA L
Eirch - Direct - 122 1
4 Vere there any problems with the radiation monitoring 2
systems disclosed by those drills?
3 L The installed radiation monitoring systems, as far 4
as I am aware of, functioned properly. There were no releases.
5 4 How about the system otherwise?
6 A The system otherwise?
7 4 Yes, that is not the whole systam, is it?
g A The system, it is hard to test them to determine whethe r 9 they work when we don't have a release of activity.
io 4 I appreciate that, but what I'm trying to understand 11 is did those drills disclose any problems with the system you 12 have stated would do an adequate job in a real emergency?
33 A I am not aware of any.
34 Q You are not aware of any modifications made to those 15 systems as a result of drill experience?
16 A As far as I know there have been no changes to the i- radiation monitoring systems. There have been changes in pro-33 cedures and how you operate.
19 4 Uhat changes?
20 A I am not familiar with this.
21 4 There have been some changes in procedures?
22 A Yes, they are reviewed regularly.
23 4 Scnc of these changes are as a result of problems dis-24 closed in a drill?
23 A I am not familiar with any.
EVE LYN BERGER AS$0CIATES. ETENOTYPE REPORTsNG SE RylCE. CHARLOTTE. NORTH CARouNA
m ,
Birch - Direct 123 1 Q Would ycu likely know if there were?
2 A No.
3 4 Uould !*r, Lewis Pnow likely?
4 A Yes.
5 4 Have you htd occcsion to be in contact or work with any 6 3ersonnel fron the South Carolina Department of Health and Environ-7 m. ental Control on this subj ect, Ms. Birch?
8 A Energency planning?
9 4 l'Onitoring of radiation under accident conditions?
10 A No.
11 4 Neither subject?
12 A No.
13 4 Did you ever know a man. named Lamar Prestor?
14 A The name is familiar.
15 4 Former Departtent Commissioner for the Department of 16 iealth, Environmental Control in South Carolina; does that refresh 17 your recollection?
18 A The name is familiar, but I don't recall talking to hir.
19 Q Do you know of any inquiries cr requests or cuggestions ,
20 ?roposals, by any state or local governmental official in North 21 cr South Carolina for the installatien of a Ecal-Time Monitoring 22 System?
23 A I'm not aware of any.
! 24 Q Would you know if such a succcstion was madt to the 25 ompany? Would it likely come to your attention?
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE, NORTH CAROUNA
.. 124 1
A
( Ycs, I would think so.
Q How about we take a five-rinute reccus?
3 Odiercupon, the Dapccition was adjourned for a 4 brief recccc, after which the Deposition was 5 concluded.)
6 FURTHER THE DEPONENT SAITH NOT.
7 8
9 '
10 11 I, Mary Birch, hereby certify that I have read and 12 understand the foregoing transcript, and believe it to be a
/
13 true, accurate and complete transcript of r.y testimony.
14 15 16 IUdtY BIRCH 17 18 19 This Deposition was signed in my presence by Mary 20 Birch on the day of June, 1983.
21 22 93
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- 4CTNNZ PUBLIC 24 25 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROLINA i
e 125 1
CERTIFICATE 2 STATE OF HCETH CAROLINA 3 COUl;TY OF I:EC LEliEU2C 4 I, Lynn E. Gillian, Court Ecporter and I;otary Public, 5 do hereby certi"y that the foreccing pcces are a true, accurate 6 and conplete transcript of the DcpcSition of Mary Birch; that 7 the proceedings were.by ne reduced to nachinc shorthand in the g presence of the witnescos, afterwards transcribed upon a type-9 writer under ny direction.
10 I further certify that thoce proceedings were taken 11 at the tine and pitee in the foregoing caption specified.
12 I further certify that I an not a relative, counsel or 13 attorney for either party or otheruice interested in the outcome 14 of this action.
- 15 IN WITNESS WHEREOF, I have hereunto set my hand at 16 Charlotte, North Carolina, en thic the day of June, 1983 17 18 LYNN B. GILLIAM 19 Notary Public 20 21 22 23 I- 24 25 l'y Connission Expires May 12, 1988.
E VELYN BERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTM CAROUNA