ML19224A919

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Testimony Before Senate Subcommittee on Nuclear Regulation on 790430 Re PA Public Util Commission Actions Following TMI Incident
ML19224A919
Person / Time
Site: Crane 
Issue date: 04/30/1979
From: Goode W
PENNSYLVANIA, COMMONWEALTH OF
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NUDOCS 7906130211
Download: ML19224A919 (23)


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TESTIMot;Y OF CHAIRMA?I W. WILS0!J GOODE PElit;SYLVAllIA PUBLIC UTILITY COMMISSIO!I BEFORE THE SUBCOMMITTEE 011 NUCLEAR REGULATIO11 0F THE SENATE COMIITTEE 01: E!!'lIRot; MENT AND PUBLIC WORKS M0!! DAY, APRIL 3 0, 1979 7 9 0 613 0 2if 174 101

invitation to appear before May I express my thanks for the actions of our commission following your committee to discuss the the incident at Three Mile Island.

I believe it is appropriate to put into proper prospective this historic inci-the role of Our Commission in relationship to The Pennsylvania Public Utility Commission is an independent dent.

state legislature in 1937.

quasi-judicial agency created by the This Ccamission has the original primary jurisdiction of monitoring and establishing reasonable rates and safe, adequate service of We are all public utilities in the Commonwealth of Pennsylvania.

charged with the duty of protecting the public interest and must make determinations as to whether the plan and sersices of utilities are necessary or proper for the acccamcdation, convenience or safety of the public.

As regulators we must act to support the public in a manner that reflects a conscious awareness of fair and recognize and balance the open decisions.

This requires that we concerns of ratepayers, investors and the company alike.

These interests are often competing and it is our function to maintain the delicate balance that exists.

The Commission is given very this mandate.

brcad statutory authcrity to carry out With this legal framework in mind, it is now appropriate to describe for you this Commission's conduct upon Icarning of the accident at Three Mile Island.

On the date of the incident, never to be forgotten March 29, 1979, the Commissien had scheduled a company review of the operation of the Pennsylvania Electric Com-pany of Johnstown (a sister company of Metropolitan Edison and a 251 cwner of Three Mile Island II).

The notice to the Ccmmissica of the incident came at the outset of the ccapany's presentation.

'1 7 4 1

7 ti4 "I

L We were told that there was a general alert at Three "ile Island, but were assured it was not serious and that there was no indicatien of a radiation problem.

This announcement was repeated at least to us which lasted

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twice during the course of their presentation until approximately 1 p.m.

Three Mile Island, Frem the very first word of a problem at our Cc= mission, while of course concerned 'sith citisen safe ty,

moved quickly to assess the impact of a number of alternatives on Our Bureau of Conservation, Econcaic anc services and rates.

Energy Planning (called CEEP) was assigned to constantly monitor situation and to prepare an analysis showing the potential the cost and rate impact cf prolonged shutdown of Unit Number II.

By 2:00 p.m. en Wednesday afternoon (the 28th), it was very the problem which had been earlier described to us apparent that as "not serious" was indeed serious, and that the safety of the With the safety issue being public was the paramount concern.

quickly organized an internal task force within our primary, we Commission consisting of bureau heads and selected Commission the purpose of the task force was to enable employees.

The This task.urce was Commission to have a total response.

with the constituted under my personal leadership and direction, full backing of Commissioners Lo uis Carter and Michael Johnson.

daily frcm March 23 to April 9.

The task force met twice The task force concerned itself with th'-

following issues:

1.

The safety issue, although not within our scope of We developed a cocrdinated authcrity, was a primary concern.

effort with the Governor's Office and other agencies within the state.

174 103

2.

The econcmic impact of this extraordinary event was given top priority by the task force.

The Commission immediately opened an informah investigation into the potential financial consequences incurred by Metropolitan Edison and its ratepayers.

We developed us with factual of interrcgatories designed to provide a list information in a very short time frame.

May I point out here that this was necessary because there was a great deal of misinforma tion.

We chose the We needed the facts and we needed them quickly.

it would yield us the necessary informal investigation route because information in the most expeditious and efficient manner.

searched for the facts, we also assigned staff to analyze As we the the potenti11 effect that Ccmmission action would have on financial stability of Met Ed, Pennsylvar.ia Elec tric and their General Public Utilities Corp. (GPU).

We knew that the parent situation was delicate and had to be handled carefully lest the We did not want our action market ccmpletely lose confidence.

(prior to fully examining all the facts) to place the company in a more difficult state.

We knew that the situation called for a cool, reasonable, logical approach.

We proceeded in that manner.

the impact of the cost of We were concurrently concerned about replacement energy on the ratepayer and the company.

We examined of purchased energy our authority for placing a ceiling on the cost and the impact that would have on the ccmpany in financial viabili t y.

While we were in the midst of examining these issues in an (incidentally, we were making goci informal and expediticus manner progress in our fact finding), the Consumer Advocate of Pennsylvania 174 104 i

_4_

and the prosecuting staff of the Commission filed petition for rehearing and reconsideration of the C43.2 million rate increase granted on, March 22 to Met Ed.

Complaints also were made against the continued passthrough of purchased energy, and the continued inclusion of TMI-2 in rato base.

The filing of these petitions and complaints immediately and necessarily changed the approach of the Commission from informal to formal.

Again our response to the change in events was quick.

We shortened the usual time for filing responses to the petitions and complaints and scheduled cral arguments before the Commission en banc on the issues in the petitions for April 17 and promised a final decision on the matter by April 19, 1979.

We further stated that we would proceed immediately after the April 19th date with an expeditious schedule of hearings.

During the course of the oral arguments it became apparent that the Commission needed to address the iscue of whether the effectiveness of the rates could be stayed while the Commission examined the f acts.

At its meeting on April 19, 1979, and in response to the petitions of the Consumer Advocate and the Pennsylvania Public Utility Ccmmission staff, the Ccamission acted to:

(1) Set Met Ed's temporary rates at the level prior to March 22nd, the date of the last rate increase.

The effect of the action of the Commission was not to permit the ccapany's rate increase to be collected until all the facts were in so that the Commission cculd then more appropriately determine the proper level of rates.

In our order we said:

"Since the Ccmmission's final determinatica at the last rate case, the Respondent's operations have been totally transformed.

1/4 105

.u-As a result of the incident at the Three Mile Island Power Stat on March 28, 1979, and thereafter, Unit No. 2 has been rendered indefinite period.

The basic assumption at the inoperable for an that Unit No. 2 was useful of Respondent's rate increase, root property in service to the public, is no longer valid.

against the "The Commission has instituted its own complaint Respondent's rates.

Prompt hearings will be held before the The i

Commission itself in order to ensure timely decisions.

and Commission will avoid any extreme or precipitous action, reliable, continuous remains aware that the provision of adequate, investors who provide electric service requires the confidence cf the large amounts of capital needed by electric utilities.

"At the same time the Ccmmission cannot and will not sit by default, to be saddled with back and allow the ratepayers, There will be no automatic all of the costs of this incident.

justification and full passthrough of costs to consumers without heard.

Rates at all times must be based opportunity for all to be on the reasonable costs of providing servic of our rate has been c.ade a subject Although the caergy cost investigation, it was not frozen or set at a temporary level as This is because the energy cost rate la were the base rates.

Our calculations based upon a six-month historical average.

of the higher-priced purchased power indicate that the effect by censumers until June and will gradually build will not be felt up over five additional months, being fully realized in November.

Since our goal is to conclude all hearings in May, we saw no need rate.

action concerning the energy cost to take immediate II4 106 (2) Also on April 19, 1979, the Comm i s s io: filed ccmp:

at against the base rates and net energy cost chargcs of both Fot Ed and Penelec.

We stated in our orders.

"The rate increase granted (each) Eespondent was pred ic ited,

the cosi determined and based entirely or substantially upcn and operation of associated with the construction, maintenance the Three Mile Island Power Station, Unit Mo. 2 (TMI-2).

1979 and of e' rents which occurred on March 23, "As a result TMI-2 has been the Three Mile Island Power Station, thereafter at rendered ircperable and unusable for an i efinite period.

"The loss of the use of TMI-2 will res :lt in substant ially at costs substantially increased purchases of pcwer by Respondent in excess of the costs of THI-2 generation.

l o s t, increased pur:hased power costs associated with the "The of the use of TMI-2 are automatically recoverable by Respondent net energy cost rate.

through the operation of the of use of TMI-2 may have been the result "The loss of the in supervision or operation impruden+. or unreasonable nanagement, the construction, maintenance or operation of TMI-2.

the loss "A substantial portion of the costs associated with of the.use of TMI-2 may be recoverable by Respondent under insurance Contracts.

for the recovery of

" Respondent's base rates, which provide costs associated with the construc tion, naintena nce, and operation of unreasonable, unlawful, and to produce TMI-2, appear to be unjust, an excessive return.

" Respondent's net energy cost rate, whien provides for the associated autcmatic recovery of the increased purchased power costa II4 107 with the loss et~ the use of TMI-2, appear to be unjust, unreasonable, unlawful and excessive."

(3) On April 25, 1970, w._ set tomporary rates for Penelec at 025,000,000 less than the annual level of rates allowed on January ll, 1979.

Finally, we decidcd--in the interest of pt ocedural simplifica-tion--to consolidate all matters concerning these two companies into one investigation and expedite our nearings.

We held a Prehearing Conference on April 24, 1979.

At the Prehearing Conference we established formal, evidentiary hearing dates for May 2, May 8, May 9, May 14, May 22, May 23, Mey 23 and May 30.

In addition, the Commission will hold ene evening meeting for public input in Reading (the headquarters of Met Ed), cne in Johnstcwn (the headquarters for Penelec), and'another in Harr'cburg.

One or two other public input meetings may also be held.

The Commission itself will hear the entire case and has developed a tentative timetable to complete the matter by June 15, 1979.

The chronology I have presented should demonstrate that ours is a Commission facing its mandated duty in a judicial manner.

We have an especially complex regulatory job to do in an unprecedented situation, and we shall do it in the most responsibic manner possible.

We are faced, however, with a challenge that, no matter how judicial our approach, all the legal alternatives may result in such an extraordinary economic unpact that neither stockholders nor rate-payers could shoulder it.

Moreover, we are faced with an event that I14 108

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has profound national significance.

It seems appropriate therefore that the federal government share in the solution to +he problem.

It appears that a great deal of thcught was given to the potential financial consequences of a naclear inc2 dent when the federal government began to enccurage the develepment of atomic energy.

This was more evident in the development of the Price-Anderson Act, Sec. 170 Atcmic Energy Act of 195!., which provided for indemnification of Muclear Regulatory Com.aission licensees frca public liability arising out of or in connecticn with generation of nuclear energy.

Even though not spccifically mentioned in the Act, arguably the coverage provided shculd extend to enecmpass the purchase of power which is directly attributaole to nuclear incidents.

Further, should there also be coverage to provide for carrying charges on the company's investment in the plant while it's out of service?

The stated purposes of the Price-Anderson Act at its inception were:

"(1) to assure the availability of adequate funds to the public to satisfy liability claims in the event of a catastrophic nuclear accident, and (2) to remove the deterrent to private sector participation in atomic energy presented by the threat of enormous liability claims if such an accident were to occur."

The Joint Ccmmittee on Atcmic Energy (JCAE) in recommending the extension of the Price-Anderson ?.ct emphasized as its principal reason that:

"the need to assure the availability of funds to the public for the payment of claims arising cut of a catastrophic nuclear incident, still persisted."

l/4 109

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(JCAE Peport No. 883, 88th Congress, 1st Session, August 26, by Directorate 1965, p. 5 taken from Final Environmental Statem nt of Licensing United States Atomic Energy Ccmmission, issued August 1974.)

Clearly, neither purpose will be furthered if the costs are borne solely by the consumers resulting from this nuclear incident of central Pennsylvania or the investors of GPU.

In the event that this Committee determined that this inciden*

then it be considered under the Price-Anderson Act, should not should consider by what vehicle the federal government will partici-pate in remedying the economic disaster that will result as a consequence of the TMI-2 incident.

The f ederal government recognised the need to provide for indemnification from public liability claims arising from a nuclear incident.

We reccmmend that the federal government similarly recognize the devastating financial impact on the consumers of Pennsylvania and the investors of GPU in meeting the cost of purchasing needed power and incurring addi-tional debt costs.

This Commission recommends that the federal government consider enacting special legislation, if necessary, to address the economic its custcmers as a consequence on the entire utility industry and result of the TMI-2 incident.

There should be no hesitation to take such action.

I think that applicable precedent can be found for this in the federal gcvernmcnt's rescue of a private corporation threatened with bankruptcy, such as Lockheed Aircraf t Company, and a municipal l / 4

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The consequences of the TMI accident corporation, New York City.

are every bit as devastating as the Agnes Plood which struck federal government Central Pennsylvania in 1973 and to which the infusions of funds and other types of responded with massive relief.

This traumatic incident has left in its wake unparalleled as well as health and psychological prob-economic consequences, A decision to leave the entire lems now and for years to come.

a profound, burden on consumers or investors of GPU will have on the utility industry and all consumers deleterious impact throughout the country.

should take whatever steps are necessary to The government entire the consumer or the'ratepayers from shouldering the prevent possibility of the government making burden of this incident.

The loans to the company to meet its cost is but low or no interest one possibility.

A substantial grant or contribution to ccmpen-of service before for the differences in expenses and cost sate and after the accident is another possibility.

It is our final recommendation that this committee provide and that in its decision making process, for input by the state and federal action to address thcee be a coordination of state this problem.

I respond to In your letter of invitation you requested that four questions, and I believe I have touched on most of your concerns.

I would, however, like to explain one important facer related to your questions:

As I stated earlier, the Ccmmission has opened a formal investigation which will include testimony and exhibits relating to the matters I have cutlined.

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. ultimately rule on these As an impartial arbiter, who must I have of necessity avoided issues directly relatcd to

matters, Unt41 all the evidence is presented and made that in,estigation.

part of the public record, -

..ou.ld be inappropriate--and legally l.e a impossible -for me to com:nen+, on tha assessment of liability or TMI-2 the costs associated with the who should ultimately pa,f.co.

incident.

make at this time any spec.i#ic comments I might Furthermore, It could jeopa,,d'~e +he ultimate Commission decision in this case.

facts developed must be de;ided objectively, based solely on the procee_ings, w4 thout the remotest appearance of a

during the as I am sure you understand.

pre-judgment, 174 112

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a: A-Probe C3es Absence of Coolinu V ater (

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S' NUCLEAR, From Al inside at thousands of rems, all the things we needed to get from the 11-way through the containment, not just censee to judge what had occurre 1 The flwr readmgs v.ere in thq tens and what to do about it. This utility

- of rems uhtle the in the dome were Meanwhile, at a separate hearing, was not prepared to tape w th this j

80> re'ns. But the inst *uments in the (fome are thielded from radiation so N1(C staffers told the Advisory Com-kind of accident."

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that techmcians had to extrapolate to mittee on iteactor Safeguards that the Denton was asked if hlet Ed's lack

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s get the real radiation levch said the Three Mile Island core is so badly of competence implied a " systemic" 1,

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MC's IWer W. Mattson. Extrapola-damaged that it looks like an Inserted problem in the electric power indus-J

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tion from CJO gave technicians a fig-pyramid of debris and fragmented ure so high they didn't trust it, he fuel that reaches down five feet along try and he answered that many utili.

ties had top engineermg staffe but the 12 foot long fuel rods.

said.

that others did not. TI'ose "at the 9

  • 'I hat reading w ou hi have been Water finw through the core is 93 lower end contract their engineering f

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/f or tens of ti.ousands of percent blocked by the debris, and re-e mpetence outside That's difficult to L

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" thousands

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u m s-Mattson said. "It was only sistance to the circulating water is 200 deal with when you have an emer-

,' later on that we calculated the dose times what it normally is. Water is f'.y,f[~l, C

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C'"'Y-flowing at " fractions of a foot per sec-at that, Sen. Ilart responded: "At r 4%

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ond " according to NitC Staffer Garf day to have cooled the core down to dustry running a 21st century technol-

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Its worst, we have a 19th century in-

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Ifolahan. That was still enough yester.

the average temperature of 1*19 de-ody ~

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grees Fahrenheit, the lowest it's been.

I!oth hearings brought out the fact l!

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since the accident.

that an NitC Inspecter had visited T t'e NitC's Carl 11erlinger said Three blile Istrand twice in Llarch,

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once for four days (March 19 to 23) there are now 425,000 gallons of waste ~ and the second ume (Starch 26) for

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,y water contaminated with rr.dloactivity on the floor of the containment base.

one day.

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ment. The water is five icet deep, al-The auxiliary pumps that were most twice the depth of two wecks

  • blocked out" the day of the accident SI'N. GARY H ART ago. Berlinger blamed continuing in siolation of NitC rules were not
  • N*

leaks for the rising w.tcr levels-closed off on March 22 but were ap-At the Senate hearing, NltC people patently shut on the 26th during a were repeatedly asked about the com-test r nd were certainly thut on the serve some ' share of the blame, since petence of the utility, the Metropoli-20th, the day of the accident.

an inspector was in the plect on hlarch 26.

tan Edison Co.,in deahng with t'

ac-

"If in fact they were shut for two cident. In its rephes, the NitC ogues-days," the NitC's liruce Wilson told "On a planned ir spectiou like this, t,oned Met Ed's technical competence the Advisory Committee, "that's five we allocate 20 percent of our time to t

Do fewer than three times, shif ts lot operators) and it's one of the look for things that are wrong, said "We did not have irem the very largest mistakes

  • The NitC binted at the NltC's John Davis. "Unfortu-first day," Denton said, "the kind of the Senate hearing that it may de-nately,in this case, nothi ag was seen."

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Nuclear liu1nirr Cites Absence of Coolin a Water

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e By Thomas O'Toole and Joanne Omang Washinaleil PO4 SinIf Wrt! PTS

.The Nuclear he:. ulatory Com rnis-sio'n now believe's that 'the ' uranium '

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fuel in the Three Mile'!sland nuclear plant uas completely without ' cooling water for as long as A0 minutes on the day of the accident, and that. it was during thuse minutes that the f uel suffered most of its damage.

"The only thing cochng the fuel rods durin;; that time was a very low flow rate of steam," liarold R. Den-i ton, director of reactor re;;ulation at the NHC, told the Senate subcommit-tee on nuclear regulation yesterday.

"It's still too early to say how close we were to a meltdoan tut the core clearly reached very high temocra-tures, having come uncosered several times."

Denton said the early warnin;s of extensive fuel core dama;c were all there on the day of the accident (Weddesday, March OS) but that a com-bination of ignorance and instrument misreadings led the NItC to misjud;c the extent of the dama;e.

A small explosion os hydro;;en gas inside the concrete cortainment sur-

' rounding the damaged reactor took place at 1:5G' p.m. Wednesday but the NRC wasn't told of it until 19 a.m. Fri-day. Ilid the NltC t'een informed of the explosion when it happened Den-ton said, it wou!d have known that large amounts of hydrogen had es-caped from the reactor to the contain-ment-hydrozco that could come only from extensive damaee to the core.

"Why would an operator withhold information hke that for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Sen. Csr3 Ilart (D Coloa. chairman of the subcommutee, asked Denten.

Replied Denton: *! don't think te know the answer to that yetJ' And

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NRC Chairman Joseph M. llendrie said: 'It was or!e of the most disturb-Ing elements of what went on. It would have been enurmously helpful to know as soon as thu happened."

Ancther sign of heavy cote damage was the level of radiation it' the con-tainment, but the NltC conceded Jes-tecday that it chose to beheve or.e set of mstruments reading low radiation lesels on the fivur instead of another set reading hi;;h les cls un the telling.

Y 174 114

STATEMENT OF WILCOX COMPANY THE BABCOCK &

BEFORE THE SUBCOSD1ITTEE ON NUCLEAR REGULATION OF THE SENATE CO!Oi!TTEE ON ENVIRC-NME.T AND PUBLIC WORKS APRIL 30, 1979 174

lae

Wilcox Company is pleased to submit its statement e

The Babcock &

before the Subcommittee on Nuclear Regulation of the Senate Committee This statement is submitted in on Environment and Public Works.

conjunction with an invitation by the Subcommittee to Babcock &

30, 1979.

Wilcox to appear before the Subecmmittee on Monday, April Wilcox will be presenting a At the Subec=mittee hearing Babcock &

synopsis of this statement.

first, how a nuclear plant ecmes This statement will address,

into existence beginning with its inception es a planned addition d

to a utility's generating capacity including the participants an to briefly discuss a pressuriced water reactor their roles; second, third, to discuss the Three Mile Island Unit nuclear steam system; 2 background and the Babcock & Wilcox role with respect to its No.

scope of supply, the licensing of the plant and the startup and through the declaration by Metropolitan Edison testing of the plant and fourth to discuss the occurrence of its commercial operation; 1979.

2 which commenced on March 28, at Three Mile Island Unic No.

It is appropriate to begin this statement by briefly describing h

the genesis of a nuclear power plant and the particular roles eac of the participants plays.

Following a utility's decision that it wants to add a nuclear power generating station to its electricity producing facilities, will generally employ an engineering firm tc begin the process it Several decisions such as of bringing that decision into reality.

generating capacity, i

location,' desired date of commercial operat on, Generally, the and financial considerations are made.

ious components of firm will prepare bid specifications for the var lead times Because of the design and manufacturing these specifications the plant.

f required for the nuclear steam system, o ten Suppliers, s of the project.

are released to bidders in the early stage ls for review the specifications and prepare proposa Following including B&W, i

ring firms.

submitral to the customers and their eng nee i

period, an is usually a lengthy evaluation and negotiat on ineer begin to proceed what award is made and the supplier and the eng ent efforts to support with detailed design, licensing and precuram the customer's schedule.

hip is governed Each individual customer-supplier relationsd the require by the respective contract requirements an i

is to The supplier's responsibility to the util ty with these requirements.

by the NRC.

and services in accordance furnish equipment for the design the suFplier has the responsibility SpecificallyF responsibility to provide h

of the equipment which it supplies and t e llow the engineer to interface design information and criteria to a The f t' ' ccmplete plant.

integrate this equipment into the design o usually includes the ecmplete reactor sect. e o f sur. o. lv.

uxiliary support systems sua_ a. lier ' -

coolant _

ten, components within major a instrumentatien and control and emergency core cooling systems, fuel handline. ec.uie. ment.

sv. stems and other equir. ment such as 4

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part of the plant which is outside the scope Gene; ally that lier is referred to as of supply of the nuclear steam system suppThe engine i

the " balance of plant".

cf plant".

The

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l and precurement of ecuipment for the "ba ancek together to inte-nuclear steam system supplier and engineer worthe interface thr grate their respective scopes of supply atf interface information i

the transmittal, review and applicat on o system des-specifications, and criteria in the form of drawings, the nuclear steam system For instance, criptions and instruction.

system which is located in supplier provides the reactor coolant The is designed by the engineer.

The containment the containment.

into the containment integration of the reactor coolant system pplier and the design is an example of the interplay between the su engineer.

f a nuclear power plant Another key participant in the genesis o The NRC's role includes the is the Nuclear Regulatory Cc= mission.

design and the issuance responsibility for the review of the plantDuring the ea of the appropriate permits.

i Energy Act, in accordance with the provisions of the Atom cce cf the the NRC, issue a Censtruction permit based on their acceptan is necessary before any significan:

must This permit design at that time.

The NRC must also revic-construction activity may take place. Operating License plant and issue an the final design of the plant 174 118

4 This also is required e.u e,

4a.*.o *ho -cactor.

a the utility may,soam NRC is responsible for

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In ad44 4cn.,

m by the Atomic Energy a'c*-.

d for testing and establishing operator training requirements an Once a e'a.. has s'a-ted operating, the licensing of operators.

i g plant operation NRC maintains a surveillance function, monitor n

-lar.* *echnical specifications.

to insure compliance wi h ex4s 4..i 4-ose their speci ic

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e A particular engineer or c,,s~--

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...av.

  • hose imposed by another

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c*4*e.4a on a suc.o.ller which may va y

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basic nuclear steam system engineer or custcmer even though the c"a' 1 v., va-ying criteria 4

n' dC' i 6 would be categorized as the same type. " design er by the equipment may be imposed by the " balance of plantTherefore, even thoug selected for the " balance of plant".

t m supplier may be thought supplied by a particular nuclear steam sys e design they are usually h

of as being the same, in the specifics of t e e +-w-. e Babcock & Wilco).

different.

It is additionally appropriate.o desc 4x w4~5 ef,rence to Figures u n..~

pressurized water reactor in s4...r,e tanding of the 1 and 2 in order that one can have a basic unders 5 *he use of nuclear pcwcr.

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croduction o elec*

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stem is essentially t

A pressurized water reacter nuclear steam sy For definition pur-

. three separate an d's*-4n..c*

loops.

a made up c:

icop, the secondary Icep, poses we will call these loops the primary p ; e,,

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1 and the condenser /ccoling icep.

l~4 119

30 FIGURE 1 TO BE SUPPLIED SEPARATELY APRIL 1/4 120

-o-onents, all The primary loop centains the following major comp reactor vessel, ding:

cf which "are located in the containment buil The l

t pumps.

steam generators, pressurizer, and reactor coo an inside diameter with walls feet reactor vessel is approximately 14 i h an inner lining of approximately 9 inches thick made of steel w t l

It houses the fuel assemblies which are circa oy stainless steel.

Control rods which contain material tubes housing enriched uranium.

also contained in which controls the rate of nuclear reaction are These control rods move up and down within the the reactor vessel.

The steam genera-fuel assemblies to vary the power frcm 0% to 100%.

68 feet high with an inside tors are c.ressure vessels apprcximatelv.

They contain thcusands of diameter of appronimately 13 feet.

the diameter of i

nickel-iron-chrcmium alloy tubes roughly tw ce ically The pressurizer is a high pressure vessel vert d water reserve which a pencil.

mounted which provides a steam surge chamber an The l

t pressure.

can be used to maintain desired reactor coo an ery high reactor coolant pumps, 2 per steam generator, are v this flow throughout capacity pumps which deliver reactor coolant f

Heat which is generated frca nuclear reaction o crimary system.

l d fuel pins is trans-

"-""4um contained in zircaloy c a d

the enriche l under high ferred to water circulating through the reactor vesseTh pressure and flow around the fuel pins. h re the heated water pa through piping to the sream generatcrs w e reactor ccol:

tor and returns to throuch the tubes in the steam genera und the uel pins pumps to recirculate it through the reactor aro h rhe use of The primary system maintainc its pressure throug again.

n W-l t pressure The pressurizer maintains reactor coo an the pressurizer.

f the heaters or spray in the at desired level through actuation o (Figure 2)

This is a closed system.

pressuriner.

the turbine

rators, The secondary system contains the steam gene d auxiliary feedwater generator, condenser, heaters, and main an sing through the As the heated water from the reactor is pac ater frcm the secondary pumps.

tubes in the steam generator different wmitside of the tub is system is pumped around the h omium alloy material making transferred th ough the nickel-iron-c r which then leaves the up the tubes to tura this water into steamd passes through p upper region cf the steam generator anAs the steam h

drive the turbine.

it returns to its licuid turbine and further cooled in a condenser, After m generator.

state and again begins its return to the stea it d

ate system, leaving the condenser and passing through a con ens d through the steam returns to the feedwater pumps to be circulate lly a This is the secondary locp and is essenria generators again.

closed system.

d condenser waich The third loop contains the cooling towers an i

the such as a river, to cool the steam leav ng use a water source, in tubes in the condenser f

turbine-generator through heat trans er for its steam in the secondary system back to water and turn the sion to steam.

return through the secondary steam and its reconver (Ficure 1) 1 4

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, division of responsi-Recalling the earlier discussion of the and design, manufacture, bilities between the participants in thethe following ccmments a construction of a nuclear power plant,to a pressurized water nu with respect generally applicable the major components of the primary loop are

First, The steam system.

i ility of the USS supplier.

the design and manufacture respons b loop are generally the secondary icop and the condenser / cooling ith specific ccm-design responsibility of the engineering firm w ibility laid upon various ponent design and manufacture respons f the turbine generator.

manufacturers such as the manufacturer o ilities and interfaces Additionally, there are split responsib An example of such a split is in the between the participants.

designs and f abricates the primary system, where the NSS supplierrameters which must be met major components and specifies certain pa and where f the containment, within the engineering firm's design o ponsibility for the contain-the engineering firm has full design resf certain ccmponents within ment building itself and the locaticn o the containment.

t Three Mile Island Prior to Lhe discussicn of the occurrence a that scue specific background information about Unit 2 in detail, startup and testing

training, in the areas of licensing, plant should be addressed.

k hk

8-h d long before A great deal of data are developed and gat ere it is ccamenced.

any activity with respect to starting up a un e

fforts by the utilities Much of these data pertain to licensing e i

ry filing by the utilities with the NRC of their prelim na The following represents B&W's and the and final saf ety analyse s reports.

performed for the owners ef ferts with respect to the analysis it in particular with l

of Three Mile Island Unit 2 in general and a so in their licensing, respect to less-of'-feedwater situations for use d final safety efforts and in preparation of the preliminary an analysis reports.

l i g licensing In general, Babccck & Wilecx performs the fol ow n W nuclear steam systems.

assistance to utilities which incorporate B&

y generic It prepares and submits to the NRC all B&W Compan in support of licensing reports that are requer ted by the -Staf f it prepares those portions of In addition, utility applications.

to the B&W l

licensing reports required of the utilities that re ate These utility reports are subsequently sub-design for that plant.

mitted by the customers to the NRC.

address B&W recermends licensing plans to its customers that airements related to the nuclear steam current NRC licensing s

It h

plans.

cupply system and it participates in carrying out t ose d to lends assistance by providing expert witnesses that are prepare to discuss our designs the ACRS, and the ASLB appear before the NRC, in depth.

I74 125

_9_

The NRC has presently identified thirty-three design basis transients which are necessary for consideration in the licensing The basic approach to evaluating-review of a nuclear power plant.

conditions resulting from the thirty-three hypothesized the transient analyses to show transients is to perform sufficient design basis they will self-terminate by operation of the Reactor Protection that System (RPS) or terminate by other conditions which would result incperationoftheengineeredsafetk/ features (ESF).

Among the thirty-three hypothetical accidents for which which analyses must be performed is a loss of feedwater transient, was an initiating factor of the occurrence at Three Mile Island The analyses for the loss of feedwater situation showed Unit No.

2.

that the facility would accommcdate this transient within the applicable safety criteria using the auxiliary feedwater system as designed.

Operator training is another area in which B&W plays a role.

To understand that role it is important to recognize what is required by the NRC with respect to operators of nuclear power plants.

Licenses for nuclear pcwer plant operators are issued by the NRC Operator Licensing Branch after the examination requirements of Part the Federal Regulations are met by prospective candidates.

the candidate has of the requirements include demonstratien that a reactor facility which is generally classified c::perience at to the in ccmplexity and operating characteristics as ccmparable Acquisition plant en which the examinations are to be requested.

of this experience may be demonstrated in a number of ways, one 1/4 126 letion of an of which is certification of satisfactory compuclear power plant approved t raining program which utilizes a nOur specific in',olv simulator as part of the program.

he particular needs and any utility customer will depend on t The actual program utilized in the desires of that utility.

Island Unit Two was training of the operators for Three Mile B&W provided dison.

agreed to between the NRC and Metropolitan E i ht week simulator a portion of that program by conducting an e g simulator i ia nuclear plant i

training program at our Lynchburg, V rg n B&W also prepared and conducted a sample NRC type ight week period.

facility.

h reactor operator examination at the end of t e e a two l examinarion, This examination consisted of a two hour orahour written hour simulator operating examination and an eight The examination covered subjects which were not examination.

training program h

necessarily covered in the B&W portion of t e Satisfactory but which would be covered on the NRC examination.

ceptable scores completion of the overall training program plus ach NRC's on the sample examination were required prior to t e acceptance of candidates for formal examination.

t p Wilcox also provides support services in the star u Babcock &

These services are generally defined as phase of a nuclear plant.

tility with providing on-site consultation and advice to the u The startup and data provided by B&W.

respect to the equipment runs from fuel loading or from initial phase of a nuclear plant until tne plant

1978, TMI-2 was March 29, criticality, which at I14 127 The plant, of course, is is declared in ccamercial operation.

onsibility to see that under the' Owner's control, who has the resph step during the startup all NRC requirements have been met at eac representative Babcock & Wilcox dispatched a resident process.

Mile Island on January 22, who headed a B&W On-Site Team to Three He has remained in residence and continu 1973 f or Unit No.

1.

2.

site representative for Unit No.

as B&W i h respect to In addition to the censultation provided w t B&W assists with the the performance of equipment and services, tility test guides h

utility in its test program by providing t e u The test guides assist the utility in and test specifications.

The test i

ent.

performance of field tests on B&W supplied equ pm tional check-out specifications are prepared for the pre-opera ing as well as for startup and physics test of the equipment required by the NRC.

it is appropriate to move into a With this background, d

discussion of the incident at Three Mile Islan.

t in Lynchburg Early on the morning of March 28, B&W managemen Immediately thereafter, we convened was notified of the incident.

d manpcwer needs for a meeting to identify specific information an

ting, As a result of that r providing support to the Licensee.

l afterncon a five pecple were dispatched to the site and by ear y hburg which was ccmmunication center was established in Lync By the and technical people.

staffed by our senior managementin organization to provide ro second day we had established I74 128 specific responsibility Within that organization, clock support.

d from the site and i

was assigEed for evaluating data obta ne for conducting simulatiens developing a postulated sequence of events,for developing and of the events on the B&W simulator, for performing comparisons of physical contingency procedures, ested by and for conducting specific analyses as requ plant data, the Licensee or the NRC.

h incident should The factors which are of significance to t e rning the actions now be addressed and B&W views provided conce and the NRC in response the utilities, taken and planned by B&W, for these discussions, To provide a context to the incident.

shall be used factors identified by the NRC the six cignificant factors Following discussion of the significant as a framework.

be identified, to show the specific actions taken by B&W shall Additionally, safe operation of B&W plants can continue.

that t forth.

B&W's near and long term planned acticns will be setwo closed after the loss of feedwater occurred,

First, hing isolation valves prevented auxiliary feedwater from reac f eight minutes.

the steam generators for a period in excess o t r to remcVe This eliminated the capability of the steam genera o and resulted in a correspending from the reactor coolant system, and heat system temperature and pressure, increase in reactor coolant to promptly stabilize reactor diminished the ability of the plant system temperattre and pressure as designed.

coolant I/A 129

. system of the initial reactor coolant Second, as a result che pilot-operated pressurizer pressure and temperature increase, i

r) opened as tlocated at the top of the pressur ce relief valve thus allcwing reactor reseat properly, designed, but did not After approximately system pressure to continue decreasing.

instrumentaticn coolant l

t the operator recognized the data from p an and closed the block 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve was open, which indicated that thus preventing any valve in the relief valve discharge line, further loss of primarv coolant.

had the high pressure injection system, which

Third, t

coolant automatically actuated as designed on low reac or the operator system pressure, was prematurely terminated by i

f an opening even though there were simultaneous indicat ons o h.as in the reactor coolant system pressure boundary,- suc decreasing reactor coolant increasing quench tank pressure, essure.

system pressure and increasing reactor containment pr tor core This led to a diminished capability to cool the reac as primary coolant inventory diminished.

isolated in accordance with the Fourth, the containment this allowed the transfer of radioactive

However, licensed design.

iliary building, water frcm the reactor building sump to the aux radiation releases occurred.

from which subsequent high pressure injection was evidently T.anually

Fifth, i

We operated based on high pressurizer level indicat on.d and have conducted reviews cf data frca Three Mile Islan I74 130

. the indicated d

that performed analyses that lead us to conclu e We believe sicnificantly in error.

pressurice'r level was not ll during a long period that the pressuriner was essentially fu ccolent system of this transient but a portion of the reactor t m pressure.

developed steam voids due to the decrease in sys e independent NRC study.

This conclusion has been supported by an injection flow should Consecuently, operation of high pressure of pressuriner level.

not have been based on the single parameter in addition to two reactor coolant pumps having been

Sixth, pumps the remaining two reactor coolant shut off at 73 minutes, i iation of the incident.

were shut off at 100 minutes after the in t in each loop in Although shutting off one reactor coolant pump

dvisable, response to indications of low coolant flow may be a h

present is shutting off all pumps under the circumstances t en d a degradation believed to have caused an uncovering of the core an at about thirteen hours Ultimately, in core cooling capability.

the reactor coolant system after initiation of the transient, and at about 15 hcurs the reactor coolant was repressurized, pumps were restarted.

d credibly Our analysis of the foregoing factors and the nee reliability of nuclear power to build public confidence in the asures to has led us to conclude that we should take further me f B&W-supplied assure and enhance continued safe operation o turn to:

a) the actions Thus, this discussion will now reactors.

N

. to be taken, and c) the already taken, b) the near-term actions e

those objectives.

longer term actions appropriate to meet C has Our analysis of the six factors identified by the NR i

rrant yielded a set of three basic principles which we bel eve wa emphasis in considering any future action.

renewed emphasis must be placed in the near term on

First, systems important administrative controls to assure that plant consideration In the longer term, to safety are not defeated.

those admin-should be given to whether plant systems to augment d.

istrative controls should be developed and implemente renewed emphasis must be placed on maintaining the

Second, sses individual operator's focus upon the fundamental physical proce and on ensuring that systems complement which assure core cooling, focus.

or increase the likelihood of maintaining that any actions or modifications implemented must be

Third, of total plant safety.

Hasty censidered in the broader context sive and ill-considered actions, which might be partially respon could, in certain cases, prcduce adverse to the TMI-2 events, I 2.

impacts in other safety systems which were not involved at TM -

the actions already the following are With that introduction, and those anticipated for the near and longer term.

taken by B&W, Actions already taken A.

B&W contacted representatives of its other operating plants ih by telephone between March 29 and March 31 to provide them w they have statica information regarding TMI-2 and to recommend that 174 132

- personnel check the configuraticn of their auxiliary feedwater systems and make such inspections and tests as necessary to confirm e

flow of auxiliary systems are properly aligned to permit that the feedwater as designed.

By April 1, B&W had further data regarding TMI-2 which we believed would be helpful to other B&W operating plants in under-incident B&W standing the cau ses and course of events of that contacted each of the utilities and invited them to send representa-tives to a meeting in Lynchburg.

Soon thereaf ter NRC issued Bulletin 79-05, which requested a priority the utilities with B&W operating systems to conduct review of their system and procedures in the light of the TMI-2 incident.

The meeting was held on 1.pril 3 and 4 in Lynchburg wi-th At that each of the utilities having representatives present.

B&W presented the data we had on the incident and

meeting, discussed with the representatives similarities and differences Additional in their equipmenu and procedures from those of TMI-2.

informatien was provided and specific questicns by customer Bulletin 79-05 was discussed representatives were answered.

in resconding to Bulletin 79-05 and B&W provided assistance thereto.

both during this meeting and subsequent The first B&W advisory was forwarded by telecopy en April 2.

that the operators perform It reccmmended, as a precautionary step, 174 I33 "MN

. ascociated

ystem, a thorough review of the auxiliary feedwater s and normal maintenance and emergency support and control systems, lead to defeat ight procedures to identify potential actions that m is required.

It also of the auxiliary feedwater system when it feedwater system and i

recommended that the design of the auxil ary and emergency procedures associated the operating, maintenance, s, maintenance and t

with this system be reviewed with all opera or its importance to i

supervisory personnel with special emphas s en ituation This advisory was aimed at prevention of any s plant safety.

ailable when like that at TMI where auxiliary feedwater was not av needed.

d on April 4, A second B&W advisory to operators was issue 1979 to provide detailed 1979 and supplemented on April 17, ture termination instructions to operators which would preclude prema and shutting off reactor or reduction of high pressure injection, lt in degraded ccre coolant pumps under conditions which could resu cooling.

another meeting between B&W and the cwners was On April 16, d B&W held specifically to discuss information available an ii were preparing recommendaticns regarding the responses the util t esB&W Bulletin 79-05A.

to IE Bulletin 79-05 and supplementary 1 involving under-provided further assistance in regard to Iteminvolving operating and Item 3 standing the sequence of events, tial for procedures for coping with transients with a poten introducing voids in the reactor coolant system.

II

,,4 I3 to its customers a letter in On April 21, 1979 B&W sent IE Bulletin 79-053 which reduced the pressure set suppcrt of SRC for a reactor trip at high pressure to 2300 psig and addi-point for the pilot operated tionally increased the pressure set point Both of these raeasures pressurizer relief valve to 2450 psig.

d relief a;e aimed at precluding actuation of the pilot operate valve during anticipated transients.

N.__e a r-Te rm Ac t ion s B.

additional measures should be taken so B&W recognizes that The follcwing that operators are better able to manage transients.

rummarizes the actions B&W has currently underway or will be i

commencing soon to further enhance the safety of B&W un ts.

On Monday, April 9, B&W began conducting training for 1.

in the operating and management personnel on the events involved The training consists of the following:

TMI-2 incident.

Discussion of the TMI-2 transient from the information available to B&W.

on the B&W simulator.

Demonstration of the incident Training session of the simulator having students recover from a depressurization event which involves the plant system the formation of steam voids in the reactor ccolant outside the pressurice'..

The training Six operators are included in each training session.

All utilities with B&W systems presently sessions last one day.

have this training in progress or scheduled for perscnnel.

i/4 135 s

he

_19_

2.

fhe B&W supplied equipment in both the primary and secondary systems, t ith the exception of the pilot-cperated pressuriner relief valve, performed as designed.

However, in view of the events at TMI-2, design improvements are being further enhance the ability of plant operators considered to to control nuclear power plants during transients.

to recommend design improvements In the near term we expect affect other systems within the plant or require which do not extensive analysis to improve operator performance during transients similar to TMI-2.

In this category are such things More positive indication of pilot-operated relief valve as:

position and instrumentation which will indicate to the operator whether the reactor coolant is approaching the saturated condition.

recommendations of this type will be made within We anticipate that six weeks.

A special B&W task force has been appointed to advise of 3.

of the TMI-2 other implications for plant design as a result This task force is comprised of a diverse group of incident.

technical personnel with a charter to Review technical aspects of the TMI-2 incident.

Develop recommendations for equipment improvements, operator interface, recovery requirements and incident support.

k lbb

d potential Assess impact of the TMI-2 incident an 0

in regulatory requirements on resulting changes h i al activities.

Nuclear Power Generation Division tec n c Loncer-Tern Actions longer-term C.

i s,

Beyond the immediate and near-term act on actions will be undertaken.

anticipated B&W intends to undertake a review of thosef the pilot-o transients which result in the opening o in an open pilot-operated relief valve valve to confirm that is adequately covered conjunction with anticipated transients by existing safety analyses.

ions under our Beyond those actions for design modificat ther actions, but with near-term efforts, B&W will be examining o be carefully evaluated with the understanding that each must to any impact en other design requirements.

Babcock & Wilcox appreciates the seriousness respect In conclusion, d is committed to take of the incident at Three Mile Island anns learned.

B&W is responsive actions to incorporate the lesse communications center l

k" continuing to maintain an "around-the-c oc team -- which until i

at our Lynchburg facilities and an on-s tePresident -- who have at recently was headed by the Division Vice the efforts f B&W to support their disposal all of the rescurces o B&W as well as all others of Metropolitan Edison and the NRC.

is under control and the situation at TMI are gratified that progressing towards cold shutdown.

I/4 137 r-

ort the B&W will continue to give top priority to supp ctions by the NRC, h

efforts at the site and to implement t e a tion of Met Ed and all other utilities towards preven er generation industry.

any further occurrences in the nuclear pow i

to participate Babcock & Wilcox appreciates the opportun ty i

of the TMI incident.

in the Subcc=mittee's investigation and rev ew I/4 138

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