ML19296D172
| ML19296D172 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/31/1980 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19296D173 | List: |
| References | |
| NUDOCS 8002290434 | |
| Download: ML19296D172 (17) | |
Text
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UNITED STATES OF AMERICA gK [ 48 I NUCLEAR REGULATORY COMMISSION -
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BEFORE THE ATOMIC SA FETY AND LICENSING BOAR 1 d 5'
' l lN e In the Matter of )
c METROPOLITAN EDISON CCMPANY es a t (Three Mlle Island, Unit 1) )
INTERVENOR STEVEN C. SHOLLY RESPONSE TO LICENSEE'S FIRST SET OF INTERRCGATORIES Licensee served interrogatortes upon Intervenor Steven C. Sholly on 18 January 1980. Preliminary responses to those interrogatories are supplied heretn supplemental information will be supplied to LLcensee na it becomes available and is developed into appropriate ~orm for response.
Interrogatorv 1-1 Section 2.1.1.5 of the " Restart Report" (Contatnment Isolation ModLftcations) is not fully responstve to Contention
- 1 for a number of reasons . To begin with, there is no indication that new experience avatlable as a result of the TMI-2 accident in terms of defining accident phenomena and containment responce has been taken into account in the proposed modifications to the containment isolation system.
General Design Criterton 50 requires that the contatnment structure, including access openings, penetrations, and the containment heat removal system shall be designed so that the containment structure and Lts internal compartments can accomodate, without exceeding the design leakage rate and 8002200
with sufficient margin, the calcula ted pressure and temperature cond!tions resulting from any loss-of-coolant acetdent. This margin is to be based upon, among others , ". . . the limited expertence and expertmental data avatlable for defining accident phenomena and contatnment responses . . . . The new data which is available and which can be generated as a result of the TMI-2 acetdent constitute new and significant information in this critical area of contatnment design and contatament isolation requirements and must be included within the evaluation of the proposed containment isolation system modifications. Netther the " Restart Report" nor the NRC Status Report on the Restart Report (11 January 1980) provide any indication that this new information has been taken into constderation in determining the needs for modifications to the contatnment isolation system at Unit 1.
Secondly, substituting the reactor trip signal as a basts for contatnment isolatton in place of SEAS signals is not satis factory in that this will result in clearing cf the tsolation signal when the low pressure condition (1800 pstg) is not present, but when HPI may sttil be in progress. SEAS signals must be utilized as a diverse conta nment tsolation signal.
Litrd, the proposed modifications are not acceptable because the high radiatton isolation provtston described in the Restart Report ts not single-failure proof, and as a result there is not cufficient assurance that the system
will perform Lts sa fety function when required. The high radiation isolation must be made single-fallure proof. In the event of a single failure in the high radiation isolatton system as proposed in the Restart Report, large quantitles of radioactively contaminated water could still be transferred to the Auxtilary Butiding, thus defeating the primary purpose of the Containment--preventing the release of radioactivity to the environment as a result of accident conditions in the reactor. Thts could still result in doses off-stre which exceed 10 CFR 20.105,10 CFR 20.106, and Appendix I of 10 CFR 50. This situation ts not responstve to the contention as admitted.
There are numerous procedures governing the by-pass of isolation signals which have yet to be developed by Licensee.
A few examples of this are the procedures governtng the by-pass of high radiation signals for the Reactor Butiding Sump and and procedures governing by-pass of htgh radiation signals for the RCS Letdown Itne. Until these procedures are developed for review by the Intervenor, it is impossible to evaluate fully the responstveness of Section 2.1.1.5 to this Contentton. By-pass procedures are extremeir important to this Contention in that inadequate procedural requirements for by-pass of containment tsolation could lead to effective defeat of this system if inappropriately by-passed.
Documents uttitzed in preparation of the response to Interrogatory 1-1 are the following:
- 1. " Supplement to Petition to Intervene Containing Final Contentions and Bases bet Forth with Specificity, Steven C. Sholly, Pet tt toner" , 22 October 1979.
- 2. "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations" , NUREG-0578, UbNRC, July 1979, pages 6 and A-13 through A-15.
- 3. " Status Report on the Evaluation of Licensee's Compliance with the NRC Order Dated August 9, 1979, Metropolttan Edtson Company, Et A1. ,
Three Mlle Island Nuclear Station, Unit 1, Docket No 50-289," USNRC, 11 January 1980, pages C8-21 through C8-25, and B-4, and C2-6.
- 4. " Restart Report," Metropolitan Edtson Company, pages 2.1 -11 through 2.1 -16, and Table 2.1 -1.
Interrogatorv 4-1 The basis for this claim is adequately stated in the basis for Cortention #4. To amplify briefly, NUREG-0600 at page II-3-95 tdentifies the basis for LLeensee to assess doses received via the principal pathway durtng the Unit 2 accident, in pa rt , as deriving from 15 indicator and 5 background locations from the rottine monitoring program. Under certain conditions , t.e.,
under the conditions present during the Unit 2 accident, the plume centerline will be between TLD locations. In fact, the proportion of the time during the first 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> of the aceldent in which wtrds blew steadtly into a given sector for several hours at a time is given in NUREG-0600 at page 11-3-95 as less than or equal to 30%. buch condLttons cause exposure rates to fluctuate cons tderably at any given point.
The TLD's uttitzed by Licensee for the above-descrLbed purpose are spectal TLD's which must be sent to etther Teledyne Isotopes or Radtation Management CorporaH on to be read. Therefore, an unnecessary and unwarranted dt '.ay exists between the time when
TLD's are collected from of fstte locations and when they can be read and have the exposure information relayed to the Licensee. This constitutes the "significant impairment" alleged in Contention #4. Such delays are not acceptable considering the rapidtty wLth with which major releases can begin following the initiating incident (cited in NUREG-0396 quoting from the RSS as being as soon as 30 minutes ) .
Licensee has the capabi ttty of making calculated estimates of exposure rates based on measured plant parameters. However, given the facts of the situation described in NUREG-0600 from page 11-3-71 through II-3-79, there is serlous question as to whether this represents a valtd means of exposure rate determination. Lack of on-site factllties for environmental TLD process tng therefore represents a significant impatrment to the Licensee's ablitty to provide dose assessments to off-stte authorttles with emergency response responsibilltles .
Trrerrneatorv 4-2 Health Phystes Procedure 1670.6, "Off-Site Radiological Monttortng ," requires in section 2.1.15(d) the placement of sufficient TLD's at either the continuous air monitor or at a convenient representative location in the designated area to permit readtng TLD's every four hours during the emergency.
NUREG-0600 quite clearly at page II-3-96, as stated in the bas is for Contention #4, gives evidence that Licensee is unable to carry out this provtston because of the lack of on-site TLD processtng fa c ti t t ies . Under conditions addressed above in
response to InterroSatory 4-1, this clearly leads to erroneous information or incomplete information regarding of f-site exposure rates to radiation in the event of an emergency. This contention addresses no other portion of the referenced procedure.
Interrocatorv 4-3 Because of the lack of on-site TLD processing capability, unnecessary delay extsts between the time when TLD's are collected in the fleid and when they are processed and exposure in formation is relayed to Licensee, Under conditions where major radiation releases from a nuclear power plant can start within 30 minutes of the initiating event , and under given meteorological conditions present at TMI wherein winds are highly variable in speed and direction. the presumption of a well-defined plume in the area of an existing TLD location lacks basis. Therefore, Licensee must rely on the placement of additional TLD's by personnel dispatched from the plant. Because these TLD's cannot be processrJ at the TMI site, and because Ltcensee is relying upon these TLD readings to provide radiation exposure information for transmission to off-site authorities, lack of on-site TLD processing facilittes for these TLD's dose not adequately protect public health and safety, which requires timely and accurate radiation exposure information in the event of an off-site release of radiation.
Interronatorv 4-4 As described above, Licensee is not prepared to implement section 2.1.15(d) of Health Physics Procedure 1670.6 ; thus ,
what TLD's are available are the ones in the Licensee's Environmental TLD program. As Itsted on page II-1-48 of NUREG-0600, there are only five of these sites outside of five miles (in fact, outside of 2.6 miles from the plant). These TLD's are not distributed throughout the radial area around the plant and do not extst in sufficient number to give reliable estimates of radiation exposure rates. It is not part of the procedure which places the quoted limit on TLD data but the lack of preparedness by Licensee to imnlement part of the procedure.
Interrneatorv 4-5 I am unable to respond to this question. Pages 7-13 and 7-14 of the Restart Report do not contain the referenced matertal (i.e., the REMP), but rather contains testing requirements for the filtration system of the Fuel Handling Butiding exhat . I am unable to locate the REMP within the Restart Report, but will gladly respond to this interrogatory at such time as Licensee provides me with a copy of the REMP. In the event that pages 7-13-14 purport to be the REMP, there is not such plan and that ts in itself a sufficient description of its inadequa cies .
Interronatorv 5-1 Intervenor i.as no quarrel with the number or location of the radiation monttoring instruments which are the subject of this contention. It is the ranges of those instruments which Lt is alleged is inadequate. The last sentence of the contention is perhaps unclear on this potnt- -what is alleged in this contention is that there is not now a sufficient number of
radiation monitoring instruments which can yleld on-scale readings under certain conditions. Acccrding to NUREG-0578 at page A-37, it can be shown that the potential releases from postulated accidents may be several orders of magnitude higher than was encountered at TMI-2. Intervenor takes this to indicate releases of at least 100 times those from the accident at Unit 2 (100 being two orders of magnitude) . This would, in the example of the Unit 2 vent monitor, place the releases nearly 10,000 times the maximum scale reading on the device at the time of the accident.
Having reviewed Licensee and NRC documents on this subject, Intervenor will limit pursuit of this contention to those radiation monitoring instruments in effluent discharge paths. These devices must be capable of providing on-scale readings during the highest release rate conditions of the Class 9 accident scenarios proposed by Intervenor in Contention #17. Intervenor advises Licensee that based on the document NURDG/CR-1219, Analysis nf the Three Mile Island Acetdent and Alternative Senuencqs, and the document Technical Sta ff Analvsis Reoort on Alternative Event seanences published by the President's Commission on the Accident at Three Mile Island, it appears that at least one of the scenartos advanced in Contention #17, scenario B, involves a core melt with breach of containment . Therefore, the radLation release monitors in the effluent discharge paths must be capable of providing on-scale readings during the highest
release rate conditions which would take place during such a sequence of events , i.e., core melt with breach of containment.
Interroratorv 5-2 The answer to this question is yes. The scenarios are described in Contention #17 advanced by this Intervenor. Keep in mind that at least one of these scenarios involves a core melt with containment breach.
Interrneatorv 10-1 This interrogatory is inappropriate for the following reasons.
This Contention simply requires that the impact of activities at Unit 2 on the waste handling and storage capacity at Unit 1
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be evaluated prior to Restart to determine if there exists reasonable assurance that Unit 1 can be safely operated while Unit 2 is decontami nated . This evaluation would be performed by NRC, not by this Intervenor. Once an Intervenor party has identified such an issue, this is sufficient to trigger a Staff review of the situation. It is not up to the Intervenor to identify the requested accidents, but rather up to NRC Staff.
Therefore, this interrogatory is objected to and will not be further addressed except at the Order of the Board.
Interrneatorv 10-2 1 do not contend that Unit I waste handling and storage capacity gill be used to assist in the Unit 2 decontamination and cleanup activities, but rather may be used. Such use can be ordered by the Commission to protect the public health and safety. Specification of the portion of such capacity is not
possible until it is identified what procedures will be utilized in the decontamination and cleanup of Unit 2.
Interronatorv 10-1 This interrogatory is not germaine to this contention and is objected to and not answered for the same reasons as Interrogatory 10-1 above.
Interrocatorv 10-4 To the extent that the separation of fuel handling areas is not yet described in the Restart Report except to say that "an approved environmental barrier sys tem will be functional" prior to Restart, this physical separation plan is inadequate to comply with GDC 5 and resolve the concerns identified in Contention #10. One cannot evaluate compliance of a non-existent barrier plan with GDC 5. This topic is discussed in the Restart Report on page 7-3, amendment 4.
Interrneatory 10-5 The " Status Report" referred to by Licensee is not a safety evaluation. I am informed by NRC Staff Counsel that the SER will not be issued until mid-April 1980. At that time Licensee may seek discovery on the safety evaluation subject to the ruling of the Board regarding such discovery.
Nonetheless, the identifed pages of the " Status Repo rt" do not contain a " safety evaluation" of the environmental barrier for the fuel handling areas. Therefore, the " Status Report" evaluation of physical separation of Units 1 and 2 is inadequate. The document and pages are the referenced pages of the " Status Report."
Interronatory 10-6 Inasmuch as the methods to be utilized in decontaminating and cleanup of Unit 2 have not been identified, it is impossible at this time to determine if the referenced storage capacities and capabilities are suf ficient to resolve this Contention.
Interroratorv 10-7 There has not been issued a safety evaluation of the Unit 1 and 2 storage capacities. When such an evaluation is issued, discovery may be sought on the same.
Interrnentory 14-1 Intervenor is in the process of evaluating LER Reports and Inspection Reports for Units 1 and 2 and is not able at this time to respond to this Interrogatory. When this review is completed, the answer to this Interrogatory will be provided.
Interroratnrv 14-2 (a) Safety-related functions are those functions performed by Licensee which could have an impact on the public health and safety.
(b)Intervenor is in the process of reviewing Licensee actions during the Unit 2 accident to make determinations related to non-ttmely execution of safety-related functions. To date the following have been identifted:
(1) Late declaratton of Site Emergency and General Emergency. This occurred on 28 March 1979.
Actual declaration of bite Emergency occurred at 0655, actual declaration of General Emergency occurred at 0724. The Site Emergency should have been declared at 0415 at which time Condition "c" of Table 1 of Section 2.1 of the TMI Emergency
Plan was satis fied. General Emergency should have been declared at 0635 when Condition "e" of the TMI Emergency Plan was satis fied. (see NUREG-0600, pages II-F-5 and II-F-6, and 11-2-1 through II-2-7) .
(2) Failure to maintain adequate control over access to vital areas in the plant. This should have been maintained throughout the accident. At approximately 1015 hours0.0117 days <br />0.282 hours <br />0.00168 weeks <br />3.862075e-4 months <br /> on 28 March 1979, the site security force shut down the security console, thereby defeating o
security contr'ls for vital areas in the plant.
Control over vital area access was resuned between 6 and 7 April 1979. (see NUREG-0600, pages II-2-18 through 11-2-21: NUREG-0616, pages 152 through 156; Pre- and Post-Accident Securttv Status at Three Mile Island, Donald G. Rose, LASL, 1979, pages 2-7).
(3) Non-timely confirmation survey of 40 R/hr predicted dose in Goldsboro on 28 March 1979. Prediction completed at 0710, confirmatory survev not made until 0748 at onsite location GE-8. A survey to confirm such an alarming dose rate should have been implemented immediately to determine the need for emergency evacuation or other appropriate protective action. (see NUREG-0600. page 11-3-94) .
(4) Failure to perform radiation surveys in a timely manner in well-established plumes in off-site areas on 28 and 29 March 1980. These plumes weres
- a. 1700-2238 (when first measurement was made) on 28 March 1979--a 13mR/hr reading was obtained at Kunkel School, 5.6 miles from TMI .
- b. 0340-05'40 on 29 March 1979.
Radiation surveys should have been performed as soon as the plumes were identi.fied. (see NUREG-0600, pages 11-3-83 through II-3-85, and pages II-F-11 throu6h II-F-12).
Interrnantnrv 14-3 Intervenor is engaged in a review of LER's , Inspection Reports, and other documentation which has been received in order to define the items which collectively demonstrate lack of managerial and administrative control. When this review is complete, this Interrogatory will be fully answered. To date, the following items have been identified
(1) Lack of adequate corrective action to prevent recurrence of problems with plant maintenance, quality assurance, and radiation controls . The subject of this allegation is or will be the subject of interrogatories to the NRC Staff and recetpt of answers to those interrogatories is a necessary precondition to being able to provide spectfics which are requested. Thts allegation is made by the Special Review Group of I & E in hUREG-0616, page 48.
(2) Fallure to randomly or routinely inspect by independent methods operations surveillance activities required by 10 CFR 50 AppendLx B and ANSI N18.7. The same explanation as given in (1) above appites here. This allegatLon is made in NUREG-0616 at page 51.
(3) Failure to requLre QA/QC supervisors to participate in exit interviews Lnvolving NRC inspections .
The explanatLon in (1) appites ere also. This allegation is made in 'NUREG-0616 at page 52.
(4) Permission of radiation protection and health phystes supervisor to perform his/her own audit of respons tbtlities . Explanation in (1) above applies. Allegation made in NUROG-0616 at page 52.
(5) Fallure to require adequate maintenance be performed on portable radiat Lon dose rate instruments . Exp-lanation in (1) applies. Allegat Lon based on events described on page 55 of NUREG-0616.
(6) Failure to timely correct recognized deficiencies identified during emergency drt11s. Explanation in (1) applies. Allegation made in NUREG-0616 at page 135.
(7) Fallure to maintain adequate control over access to vital areas during the period 28 March through 6-7 Aprtl 1979. Details given in response to Interrogatory 14-2 on page 12.
Interroratorv 14-4 Intervenor is engaged in a revtew of LER's , InspectLon Reports, and other relevent documents which have been received. When such review ts completed, this interrogatory will be answered.
Interrogatorv 14-5 The following records have been lost by Licensee or Ltcensee's staff during the period of the Unit 2 accident. All information is taken from NUREG-0600 at the referenced pages.
(1) Alarm Typer and Utility Typer output, 0515:59 through 0648:08 on 03/28/79. Operator " dumped" alarm status printout memory by actuating alarm suppress function at about 0648 hours0.0075 days <br />0.18 hours <br />0.00107 weeks <br />2.46564e-4 months <br />. To best of my knowledge, maintenance of this record is not required, but lack of this record hampered I & E investigation of the accident. NUREG -0600 at page I-4-46.
(2) Alarm Status Prtntout, 1848:59 through 1910:29 on 03/28/79. Alarm Typer jammed (apparently) .
It is not known whether the missing records were lost, thrown away, or otherwise disposed of.
I & E alleges that loss of these records did not hamper the investigation; Intervenor constders this statement speculative. NUREG-0600 at page I-4-46.
(3) Utility Typer output , 0000:00 through 0324:24, on 03/28/79. Records were not found by I & E.
NUREG-0600 at page I-4-46.
(4) Analog Trend Recorder Number 2, 03/28/79. This strip chart has never been found. NUREG-0600 at page I-4-47.
Interronatory 14-6 None.
Interrnaatorv 15-1 This item is under intensive review by Intervenor, especially having just received the Human Factors analysis of the TMI-2 control room performed by the Essex Corporation for the NRC Spectal Inquiry Group. This study will be the subject of discovery with both Ltcensee and NRC Staff. At this point, the following inadequacies in the operator-instrumentation interface have been identified:
(1) Human factors engineering is the science of applying behavioral principles to systems. The province of human factors engineering lies in two major areas, these being human engineering design and evaluation and human resources development . The overall objective of human factors engineering is to prevent human error. It is obvious from a preliminary review of causes listed in TMI-1 and TMI-2 LER's that personnel error accounts for a large percentage of reportable occurrences . This evidences a general lack of human facto engineering involvement in the design of the TM1-1 control room. This in itself is a major inadequacy in the control room design.
(2) Licensee emergency procedures, according to NUREG-0585, page 2-6, do not show evidence of compatibility with the design bases of the systems involved.
(3) Instrument readings which are ambiguous and fall to provide direct indications can lead the most highly-skilled and well-trained operators into errors , especially in fast-moving emergency situations .
Personnel in the control room must be trained in the capabilities and limitations of control room instrumentation.
Intervenor has proposed a site visitation for the purposes of, among other things, measurement, inspection, and photography in the Unit I control room. This will facilitate the ability of Intervenor to answer this question. This question will be the subject of soon-to-be-submitted interrogatories . The stage of Intervenor's review of human factors in the Unit 1 control room at this time does not lend itself to detailing problems.
The review is at the stage of identifying criteria , reviewing existing human factors reviews of other plants, and eventually applying these principles in a review of the Unit 1 control rocm with a view toward proving the need for a full-scale human factors review perior to Restart.
Interrneatorv 15-2 As in the answer to Interrogatory 13-1, the status of Intervenor's human factors revtew of Unit 1 is such that a dettled, definttive listing of proposed alterations is not possible. To the extent that current information permits, the following alterations have been identifled as necessary for the Unit 1 control rooms (1) Installation of a video and voice recorder system in the control room to record operator response to emergency situattons . Such a system would be actuated by certain key occurrences, such as reactor trip, turbine trip, HPI initiation, containment isolation, etc. This would provide a source of continuing informat ton on which to base reviews of incidents and with which to assess the need for future improvements in the design and layout of the Unit I control room.
(2) Complete reworking of the alarm display system into functional groupings , with alarms located near to the controls with which they are associated.
(3) Implementation of a more professional appearance among operating personnel in the control room.
This could take the form of uniforms or more formal attire. This will help eliminate the casual attitude and "atr" which I found to exist in the control room during two visits to the site in late 1979. It should foster a more " professional" attttude in the control room.
(4) Replacement of the computer and dtsplay and printing systems with state-of-the-art systems whose capabilities are more consistent with the functions of these Ltems. The speed of these systems must be such that the maximum data which is generated during an accident such as the Unit 2 accident could be handled without loss of function.
Respectfully submitted, DATED: 31 January 1980 .- %O A StevenC.Sholly{j/
AFFADAVIT OF STEVEN C. SHCLLY State of Pennsylvania )
- ss:
County of Cumberland )
Before me the subscriber personally appeared Steven C.
Sholly, who being duly sworn according to law, doth depose and say that the information contained in the responses to the attached interrogatories are true and correct to the best of his knowledge and belief and further sayeth not.
2 a ?; )J fg}/ v . ., ! L .i L, Steven C. Sholly -
Sworn to and subscribed before me this
[
W- day of February 1980
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CERTTFICATE OF SERVICE I hereby certify that a single copy of IhTERVENOR STEVEN C.
SHCLLY RESPCNSE TO LICENSEE'S FIRST SET OF INTERRCGATORIES ,
dated 31 January 1980, was hand delivered to the TMI Observation Cgnter, addressed to the Attention of Mr. John Wilson, on the "T-i ' of February 1980, for service to the other parties of this proceeding according to the Licensee's provisions for such service.
DATED: - 2' -YFebruary1980 7 q
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V % .'cf !5 w Steven C. bholly