ML19305D102
| ML19305D102 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/31/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | CHESAPEAKE ENERGY ALLIANCE |
| Shared Package | |
| ML19305D049 | List: |
| References | |
| NUDOCS 8004140062 | |
| Download: ML19305D102 (30) | |
Text
< .
Lic 3/31/80 ,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '
. t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD !
In the Matter of ) ,
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289 ;
) (Restart) I (Three Mile Island Nuclear ) !
Station, Unit No. 1) )
LICENSEE'S RESPONSE TO FIRST SET OF INTERROGATORIES OF CHESAPEAKE ENERGY ALLIANCE ,
i INTERROGATORY NO. 5-1 l Summarize and explain Licensee's position on the contention. ,
Identify any and all documents relied on by Licensee in reaching that position. l RESPONSE !
Licensee has objected to this interrogatory.
INTERROGATORY NO. 5-2 Identify those aspects of the contention that Licensee considers to be matters of controversy. For each such aspect, summarize briefly the opposing positions on the controversy as perceived by Licensee. Identify and summarize any and all documents in support of either position.
RESPONSE
Licensee has objected to this interrogatory.
INTERROGATORY NO. 5-3 Identify and briefly summarize any and all documents known to Licensee that would tend to provide evidence and/or support for this contention.
l 8004140067 i
4 t
RESPONSE
1 Licensee has ob 3 ected to this interrogatory.
INTERROGATORY NO. 5-4 Identify any and all persons that Licensee intends to have testify on this contention; state the qualifications of each person; and present a summary of the testimony that person is expected to provide.
RESPONSE
Witnesses have not yet been selected by Licensee and testimony stating Licensee's position has not been drafted, reviewed or finalized.
INTERROGATORY NO. 5-5 Identify any and all present or former members of Licensee staff who dissent from the overall Licensee position on this contention, and for each such person, provide a summary of his/her dissenting position on the contention.
RESPONSE
See Licensee's response to Interrogatory No. 5-4.
INTERROGATORY NO. 5-6 Identify the critical or central pdrameters of this contention i as it is perceived and understood by Licensee, and briefly summarize Licensee's position on, and evaluation of the importance of, each such parameter.
RESPONSE -
Licensee has objected to this interrogatory, i
4 s .
INTERROGATORY NO. 5-7 Provide a complete and accurate description of the present storage of radioactive water from the TMI-2 accident, specifying where all that water is being stored, and providing an estimate of the radio-activity levels (by isotope) of the water.
RESPONSE
Radioactive water is stored in various locations in TMI-2 as follows:
Volume Principal Radioisotopic Location (Gallons) Concentrations (uc/ml)
H3 Csl37 Csl34 Sr 89 Sr 1 Reactor Building Sump 620,000 1.0 180 40 41 3 Reactor Coolant System 90,000 0.2 42 8 33 27 Reactor Coolant Bleed Tanks 158,920 0.5~ 26 6 2 1 Miscellaneous Tanks in Auxiliary and Fuel Handling Buildings 113,792 0.03 15 3 2 1 INTERROGATORY NO. 5-8 Provide a detailed description of the proposed methods for de-contaminating the radioactive water from TMI-2. Identify and de-scribe any and all documents, based on actual previous operating experience with those methods, that demonstrate that the proposed clean-up methods are both effective and free from risk.
RESPONSE
There are three main methods proposed for decontaminating the water: filtration, ion exchange, and evaporations. The systems incorporating these techniques are:
Epicor II Radwaste System Submerged Demineralizer System Liquid Radwaste Evaporation-Crystallizer and Solidification System
Experience and documentation related to these methods are exhaustive.
No single reference was used for selecting these methods. Each method is well documented as being effective in accomplishing de-contamination as proposed.
INTERROGATORY NO. 5-9 Describe in detail any and all evidence that demonstrates that the EPICOR-II system being used for decontaminating TMI-2 inter-mediate level radioactive water has operated less effectively or safely than LIC had projected. Describe the present expected '
schedule for decontaminating the intermediate level water with EPICOR-II,.and compare that schedule with the schedule initially projected by LIC. Provide full justification for any revisions that have been made in the schedule. Identify any and all docu-ments relied on in the answer to this interrogatory.
RESPONSE
The Epicor II Radwaste System has operated as projected. De-contamination of intermediate level water has proceeded as origin- ,
ally scheduled. Decontamination of this water is projected to be complete by the end of 1980. The Water Processing Plan as docu-mented and forwarded to the Nuclear Regulatory Commission by ,
letter TLL 043 dated February 5, 1980, was used in responding to this interrogatory.
INTERROGATORY NO. 5-10 Describe the expected schedule for decontaminating the high level water presently in the TMI-2 containment building. Also provide an estimated overall schedule for the completion of all the major steps in the TMI-2 clean-up.
RESPONSE
The decontamination of the high level water is expected to commence no earlier than November 1, 1980. The overall schedule is as documented in the "Smumary Technical Plan for TMI-2 Decon-I tamination and Defueling" dated December 12, 1979.
~ .
INTERROGATORY NO. 5-11 Identify and describe any and all accident scenarios at TMI-2 during the clean-up that could generate additional quantities of radioactive waste water; describe the probabilities of each such accident scenario, demonstrating the basis and justification for these probability estimates; for each such accident scenario, estimate the quantity of radioactive waste water generated and the levels of radioactivity of the water, describing the mechanism !
by which the radioactive waste water will be generated; and for each such accident, identify the available storage space that would be used for the waste water.
RESPONSE ;
Licensee has objected to this interrogatory insofar as it calls upon Licensee to provide mathematical probability estimates of accidents or other occurrences, and insofar as it requires f
Licensee to identify any and all conceivable accident scenarios.
The accident scenarios thus far developed for TMI-2 cleanup '
activities have been associated with systems and operations c('.- ,
sidered to date. The major remaining activities outlined in the
" Summary Technical Plan for TMI-2 Decontamination and Defueling" will be reviewed for potential accident scenarios.
Copies of analyses performed to date will be placed in Li-l censee's Discovery Reading Room. l INTERROGATORY NO. 5-12
- Identify and describe any and all potential accidents at TMI-2 during clean-up that might impact on the operation of TMI-1, in-cluding but not limited to those accidents that would require
, site evacuation of Three Mile Island; for each such accident, l describe the probability of its occurrence, showing the basis and justification for the probability estimate; for each such accident, describe the impact it would have on the operation i of TMI-1; identify any and all documents and persons relied on in identifying the accident scenarios and estimating the prob-abilities of each accident.
o .
RESPONSE
Licensee has objected to this interrogatory insofar as it calls upon Licensee to provide mathematical probability estimates of accidents or other occurrences, and insofar as it requires Licensee to identify any and all conceivable accident scenarios.
The accident scenarios thus far developed for TMI-2 cleanup activities have been associated with systems and operations con-sidered to date. The majcr remaining activities outlined in the
" Summary Technical Plan for TMI-2 Decontamination and Defueling" l
will be reviewed for potential accident scenarios.
Copies of analyses performed to date will be placed in Li-censee's Discovery Reading Room.
INTERROGATORY NO. 6-1 See Interrogatory No. 5-1.
RESPONSE
See Licensee's response :to Interrogatory No. 5-1.
INTERROGATORY NO. 6-2 See Interrogatory No. 5-2.
RESPONSE
See Licensee's response to Interrogatory No. 5-2.
INTERROGATORY NO. 6-3 See Interrogatory No. 5-3.
RESPONSE
See Licensee's response to Interrogatory No. 5-3.
INTERROGATORY NO. 6-4 See Interrogatory No. 5-4.
RESPONSE
See Licensee's response to Interrogatory No. 5-4.
INTERROGATORY NO. 6-5 See Interrogatory No. 5-5.
RESPONSE
See Licensee's response to Interrogatory No. 5-5.
INTERROGATORY NO. 6-6 ,
i See Interrogatory No. 5-6. -
RESPONSE ,
See Licensee's response to Interrogatory No. 5-6.
INTERROGATORY NO. 6-7 '
Identify the rate, in gallons per minute, at which radioactive water is being discharged, or is leaking, from the primary coolant :
system of TMI-2. Describe the source and location of each such leak or discharge in the primary coolant system; for each leak / .
discharge, describe in detail the measures that are being planned ,
or implemented to correct the leak / discharge. Identify any and all documents and persons relied on to answer this interrogatory. ,
RESPONSE ,
Radioactive water is leaking from the Primary Coolant System l if TMI-2 at a rate less than 0.5 gallons per minute. The precise location of the leakage sources has not been determined because of i i
the inability to gain access to all system components and piping. l Radiological conditions have thus far prevented full access for in-i spection purposes. This response was prepared by individuals on i the staff of Recovery Operations and Engineering Departments, i
i l
l
INTERROGATORY NO. 6-8 Identify and describe the probabilities of any further leaks from the TMI-2 primary coolant system, with particular reference to any possible corrosion of seals, and/or embrittlement of valves, and/or embrittlement or corrosion of pipes; provide justification and basis for the estimates of probability of leaks from corro-sion and embrittlement, citing any and all documents and research pertaining to embrittlement and corrosion under continued condi-tions of radioactivity as prevail in the primary coolant system ,
of TMI-2, and identify the author (s) , and their professional qualifications, of the cited documents. Identify and describe the measures that are being taken or planned to reduce or elimin- t ate the probability of such corrosion or embrittlement.
RESPONSE ,
Licensee has objected to this interrogatory insofar as it calls upon Licensee to provide mathematical probability estimates of accidents or other occurrences. Furthermore, without having ;
full access to all portions of the primary coolant system it is impossible to determine the probability of further leaks. Once access is gained, the condition of the system will be evaluated, and maintenance performed as required. Meanwhile, no measures can be taken to reduce or eliminate the possibility of corrosion or embrittlement. ,
INTERROGATORY NO. 6-9 Identify, and estimate the probabilities of, any and all leaks from the TMI-2 containment building, with particular reference to any possible corrosion and/or embrittlement caused by the radioactive water in the containment building. Identify the basis and justification for the probability estimates, citing any and all documents relied upon. Identify and describe the measures that are being planned or implemented to prevent such corrosion or embrittlement.
RESPONSE
Licensee has objected to this interrogatory insofar as it calls upon Licensee to provide mathematical probability estimates
of accidents or other cccurrences. Furthermore, it is impossible to evaluate the probability of leakage without gaining access to the Containment Building to evaluate conditions. There is no indication the TMI-2 Containment Building is leaking radioactive water. To the extent possible, steps have been and continue to be taken not to alter the present conditions in the building. -
INTERROGATORY NO. 6-10 Identify any and all sequences of events at TMI-2 that could re- t sult in substantial loss of reactor coolant. Distinguish between those sequences that are predicated on operator error and those that are predicated on equipment and/or instrumentation error or malfunction. Estimate the probabilities of each such sequence, i showing the basis and justification for each such probability ,
estimate. >
RESPONSE
Licensee objected to a series of interrogatories, including Interrogatory No. 6-10, insofar as they call upon Licensee to provide mathematical probability estimates of accidents or other occurrences, and insofar as they require Licensee to identify all conceivable accidents or other scenarios. Interrogatory No. 6-10 is limited to the two areas to which Licensee objected.
INTERROGATORY NO. 6-11 l
i Describe any and all presently unused storage tanks that are i available to receive major additional quantities of radioactive ,
! water from TMI-2 if needed, giving the capacity of all such storage tanks. If any storage tanks presently assigned to TMI-l could be required to hold such radioactive water, describe the mechanism by which the radioactive water could be transferred from TMI-2 to TMI-l in an emergency.
o r
RESPONSE
The following tanks are available to receive major additional quantities of radioactive water in TMI-2: '
l Volume Available Tank (Gallons)
Reactor Coolant Bleed Holdup Tank (lA) 72,830 l Miscellane. Waste Hold up Tank 19,610 Tank Farm Tanks 14,002 Neutralizer Tanks 16,920 At the present time, water can be transferred to Unit I by installed piping and pumps to:
Reactor Coolant Bleed Holdup Tanks (1A and 1C) 155,000 Miscellaneous Waste Storage Tank 19,000 As a result of the Unit I Restart Program, these transfer lines will be placed out of service to satisfy separation criteria.
Additional tankage exists for the storage of processed water as follows: ,
Unit II Borated Water Storage Tank (As of 4/10/80) 220,000 Process Water Storage Tanks (As of 9/1/80) 1,000,000 EPICOR II System Tanks 130,000 INTERROGATORY NO. 7-1 See Interrogatory No. 5-1.
RESPONSE
See Licensee's response to Interrogatory No. 5-1.
INTERROGATORY NO. 7-2 See Interrogatory No. 5-2.
i
RESPONSE
See Licensee's response to Interrogatory No. 5-2.
INTERROGATORY NO. 7-3 See Interrogatory No. 5-3.
RESPONSE
See Licensee's response to Interrogatory No. 5-3.
INTERROGATORY NO. 7-4 See Interrogatory No. 5-4.
RESPONSE
See Licensee's response to Interrogatory No. 5-4.
INTERROGATORY NO. 7-5 See Interrogatory No. 5-5.
RESPONSE
t See Licensee's response to Interrogatory No. 5-5.
INTERROGATORY NO. 7-6 See Interrogatory No. 5-6.
RESPONSE
See Licensee's response to Interrogatory No. 5-6. I INTERROGATORY NO. 7-7 Specify and describe in detail any and all potential radioactive pathways for which the monitoring provisions described in the .
TMI-l Restart Report and reviewed in the NRC Status Report would be incapable of discriminating between TMI-l and TMI-2 effluents.
_m
f~ .
RESPONSE
Potential radioactive pathways are subdivided into two categories: liquid and air. The ability to discriminate ef-fluents between Units I and II is as follows:
AIR: Both units have essentially independent air handling systems. The effluent of each is monitored and released via separate stacks. The Fuel Handling Buildings of Units I and II are interconnected posing a potential path for air mixing. As discussed in the TMI-l Restart Report, this pathway is being separated to eliminate possible mixing and thereby achieve full separation of plant systems and effluents.
LIQUID: The release of processed water from Unit I and Unit II buildings is through separate and distinct pipes. Each piping system contains monitoring equipment so as to distinguish activity from each unit. Prior to leaving the station, the two piping systems are joined and the effluent liquid is mixed with river water from the mechanical draft cooling towers. This com-bined liquid leaves the station from one pipe. This pipe contains a radiation monitor to determine net activity release from TMI Units I and II.
INTERROGATORY NO. 7-8 P
Specify and describe in detail any and all sequences of events at either TMI-1 or TMI-2 that could lead to a breakdown of the ability to distinguish between the radioactive effluents of TMI-l and TMI-2. For each such sequence of events, describe the esti-mated probability of its occurrence, and the basis and justifica-tion for deriving the probability estimate.
RESPONSE
Licensee has objected to this interrogatory insofar as it >
calls upon Licensee to provide for mathematical probability estimates of accidents or other occurrences. The inability to distinguish Unit I and II radioactive effluent due to specific events is unlikely. The only air systems that have a potential for mixing are the connecting fuel handling building systems.
Separation walls and/or doors would have to fail prior to the occurrence of intermixing. Piping systems would have to fail in order for an indistinguishable liquid effluent release to occur.
Technical Specifications require monitors to be operational prior i
to and during releases. Therefore, by procedural and administra-tive controls, a release could not cccur without proper monitoring instrumentation. No release commences without the review and ap-proval of site management personnel.
INTERROGATORY NO. 8-1 See Interrogatory No. 5-1.
RESPONSE
See Licensee's response to Interrogatory No. 5-1. ;
INTERROGATORY NO. 8-2 See Interrogatory No. 5-2.
RESPONSE
See Licensee's response to Interrogatory No. 5-2.
l L
o
- 14 _
INTERROGATORY NO. 8-3 See Interrogatory No. 5-3.
RESPONSE
See Licensee's response to Interrogatory No. 5-3.
INTERROGATORY NO. 8-4 See Interrogatory No. 5-4.
RESPONSE
See Licensee's response to Interrogatory No. 5-4.
INTERROGATORY NO. 8-5 '
I See Interrogatory No. 5-5.
RESPONSE
See Licensee's response to Interrogatory No. 5-5. ;
INTERROGATORY NO. 8-6 See Interrogatory No. 5-6.
RESPONSE '
See Licensee's response to Interrogatory No. 5-6.
INTERROGATORY NO. 8-7 Identify, and provide a detailed summary of, any and all documents '
that have been prepared or commissioned by or for LIC concerning its management strength and capability. For each such document,
- identify the author (s) and their professional qualifications.
RESPONSE
Licensee has objected, in part, to this Interrogatory. See Licensee's objection dated March 14, 1980. In its objection, Licensee stated that it would limit its response to documents i
i
, - - . , - -g- - - - - - - - - - - . - -e- ~,,,,,-_,-.v - -
ge---- ,,
relating to Licensee's management of TMI-2 and its capability to clean up TMI-2. The following documents, which are being placed in Licensee's Discovery Reading Room, fall into this category: ,
- 1. Radiation Safety Program Report - Management Plan for the TMI Unit 2 Radiological Control Program (February +
8, 1980). Prepared by Metropolitan Edison Company. [
- 2. Determination of Technical and Organizational Readiness for Placing Three Mile Island Unit 2 Into Commercial Operation (October 26, 1978). Prepared by Metropolitan Edison Staff. ,
- 3. Unit 2 Nuclear Plant Management Review (January 18, 1979). Prepared by Metropolitan Edison staff. l
- 4. General Review of The Health Physics Program At The Three Mile Island Nuclear Station (NUS-3364, March ,
20, 1979). Prepared by NUS Corporation. !
- 5. Radiological Control Review of Three Mile Island :
(BETA-101) (November 12, 1979). Prepared by Basic Energy Technology Associates, Inc. (BETA).
- 6. Final Report of TMI-2 Accident Assessment Documentation - ,
Training Programs and Procedure Review (May 16, 1979).
I Prepared by Personnel Qualification Services, Inc.
(PQS) . ,
- 7. Review of The Three Mile Island - Unit 2 Construction Project (October 25,. 1978). Prepared by Touche Ross
& Company.
e
- 8. Review of Operating Efficiency and Management Effective-ness of GPU Service Management. (May, 1978). Prepared by Booz-Allen & Hamilton.
- 9. TMI-2 Final Safety Analysis Report, Section 13.
- 10. Management and Technical Resources. (August 6, 1979).
Prepared by Metropolitan Edison Company. [
- 11. TMI-l Restart Report, Section 5.
- 12. Report and Recommendations Concerning TMI Organization.
(March 30, 1979). Prepared by Fred Cox.
- 13. Three Mile Island Management Audit (January 9-20, 1978). ,
i Auditors: J. L. Shirk, A. Tsaggaris, J. J. Colitz, ,
G. J. Troffer. I INTERROGATORY NO. 8-8 f
Identify any and all aspects of LIC's management capability, in respect of which LIC, NRC, or any other party has uncovered evidence of inadequacy or deficiency. For each such aspect, ;
describe in detail what measures have been taken, or are, planned, to remedy the inadequacy or deficiency, providing a full and complete justification as to how LIC can demonstrate that the remedial action will indeed correct the management inadequacy or deficiency that has been identified.
RESPONSE
For the reasons stated in Licensee's objections to Interroga-tory No. 8-7, Licensee's response is limited to the identification i
of criticisms which have been made as to Licensee's management i
of TMI-2 and capability to clean up TMI-2.
In addition to documents listed in the Response to Interroga-tory No. 8-7, other documents describing deficiences in Licensee's management of TMI-2 include the following:
I l . _ . - _
- 1. Three Mile Island, Unit 2, Radiation Protection Program - Report of the Special Panel (NUREG-0640, December 1979).
- 2. Staff Report To The President's Commission On The Accident At Three Mile Island - The Role Of The Managing Utility And It's Supp?iers (October 1979).
- 3. Investigation Into The March 28, 1979 Three Mile Island Accident By Office of Inspection and Enforcement (NUREG-0600, published August 1979).
- 4. Report:Of The Governor's Commission On Three Mile ;
Island. (February 26, 1980).
- 5. Report by NRC Special Inquiry Group (Rogovin Report - !
January 1980) ,
INTERROGATORY NO. 8-9 Identify, and provide a detailed summary of, any and all documents pertaining to any investigation of the perceptions and attitudes of LIC's employees (present and former) of its management capability and practice. Include both documents that are specifically concerned with LIC's management of the TMI-2 accident, as well as those concerned with LIC's overall management capability and practice. For each such document, identify the author (s) and their qualifications.
l
RESPONSE
Licensee has objected to parts of this Interrogatory, and will limit its response to investigations of perceptions and !
attitudes relevant to the managemen; and cleanup of TMI-2.
Perceptions and attitudes of Iicensee's employees are dis-cussed in Licensee's Employee Attitude Survey Report, a copy of l
l l
l l
i
- 18'-
i which has been placed in the Discovery Reading Room. The documents listed in Responses to Interrogatory Nos. 8-7 and 8-8 also reflect input from interviews with Licensee's employees.
INTERROGATORY NO. 8-10 Has LIC conducted, or caused to be conducted, any systematic in- ,
vestigation (s) into the attitudes towards, and perceptions of, :
LIC by persons who have left the employment of LIC since March 28, i 1979? If so, provide a detailed summary of the conclusions of such investigation (s), and identify and describe the professional qualifications of the persons conducting such an investigation. ;
If no such investigation has been conducted by, or for, LIC, -
provide a thorough justification as to why such investigation i would not provide needed insight into LIC's management ability ,
and practice.
RESPONSE l i
See response to Interrogatory No. 8-9 and Licensee's objec- !
tions dated March 14, 1980. I i
INTERROGATORY NO. 8-11 i' i Are the employees of LIC affiliated with any Labor Union (s) ? If L 1
so, (a) identify the Union (s) , describe the grievance process, ;
and provide a summary of the disposition of those grievances; (b) identify and provide minutes of any meetings between union repre- r sentatives and management; (c) if LIC's employees are not repre- '
sented by Labor Union (s) , describe in detail any formal or informal grievance procedure available to LIC employees to current manage-ment and/or safety problems, and provide a summary of the grievances I that have been filed under this procedure.
l RESPONSE ',
Licensee has objected to this interrogatory, and limits its l response to the identification of any labor unions with which ;
I Licensee's employees are affiliated.
Some of the Licensee's employees are members of the Inter-l national' Brotherhood of Electrical Workers. There are no other unions representing employees of Licensee.
6 o INTERROGATORIES NO. 9-1 through 9-6 See Interrogatories No. 5-1 through 5-6.
RESPONSE
See Licensee's response to Interrogatories 5-1 through 5-6.
INTERROGATORY NO. 9-7 Identify and provide a detailed summary of, any and all documents prepared or commissioned by or for LIC since March 28, 1979, con-cerning the adequacy of LIC's financial resources. For each such document, identify the author (s) and describe their professional qualifications.
RESPONSE
Licensee objected on March 14, 1980, to the scope of this interrogatory but did agree to provide CEA with a copy of its latest financial statement and other information on financial status and projections. The 1979 Annual Report will be placed !
in the Discovery Reading Room. The GPU System's projected finan-cial resources are roferenced in the response to Interrogatory 9-8.
INTERROGATORY NO. 9 _8 Provide a summary of LIC's present financial status, with pro-jections of income and expenditure for the next 12 months.
Identify *he principal assumptions incorporated in those pro-jections, including the clean-up costs for TMI-2, replacement power costs for TMI-l and TMI-2, decisions of PaPUC and NJBPU concerning rates and rate base, and the estimated date of re- '
start (if any) for TMI-1. Provide a detailed justification and basis for the assumptions.
RESPONSE
The testimony and exhibits of Mr. John G. Graham submitted in the Pennsylvania Rate Proceeding Docket No. I-79040308 detail the present financial status of the GPU System (GPU Corp. , Jersey
o -
. Central, Metropolitan Edison and Pennsylvania Electric). -
Mr. Graham's testimony is identified as Met-Ed/Penelec State- ,
ment A-1, Supplement No. 1. The relevant exhibits are identified as Met-Ed/Penelec Exhibit A-23, 24, 25, 26, 27, 28, 29, 35,-36, 37, 38, 39, 45, 46, 49, 57, 60, 61 and 72. A copy of Mr. Graham's testimony will be placed in Licensee's Discovery Reading Room.
The principal assumptions incorporated in those forecasts are described on pages 6, 7 and 8 of Mr. Graham's testimony and specifically address " clean-up costs for TMI-2", " decisions of PaPUC and NJBPU concerning rates and rate base", and "the esti-mated date of restart for TMI-1". With respect to " replacement power costs for TMI-l and TMI-2", those estimated costs for.1980, net of savings from various purchase power agreements that have been made since the accident, are as follows:
Estimated Monthly TMI Replacement Energy Costs for 1980 Million Dollars Per Month TMT.-l TMI-2 Total Met-Ed $ 6.4 $ 4.2 $10.6 Penelec 2.7 2.7 5.4 Jersey Central ,
4.9 6.2 11.1 Total $14.0 $13.1 $27.1 INTERROGATORY NO. 9-9 Describe in detail any and all action LIC has taken, or plans to take, to remedy any financial weakness of LIC. In particular, describe in detail any proposed corporate reorganization plans that are being considered in order to remedy LIC's financial status, and demonstrate how such reorganization would in fact remedy LIC's financial status.
. RESPONSE Since the TMI-2 accident, the GPU System has sold $147.5 million of the first mortgage bonds (S97.5 of Jersey Central Power & Light and $50 million of Pennsylvania Electric). Addition-ally, the GPU System entered into a Revolving Credit Agreement with a group of 45 banks. This agreement currently makes available to the GPU System $292 million of credit with an additional $120 million upon approval of an 85% majority (in dollars) of the parti-cipating banks. A summary of the terms of this agreement are in-cluded in the testimony of Mr. John G. Graham as Exhibit A-1-1 (Pennsylvania Rate Proceeding Docket No. I-79040308). Mr. Graham's testimony also addresses possible future financings. A copy of Mr. Graham's testimony will be placed in Licensee's Discovery Reading Room.
At the present time, there are no proposed corporate re-organization plans in the financial sense of the term, that is, financial merger or consolidation. Met-Ed/Penelec Exhibit A-66 i in the referenced rate proceeding addresses the legal impediments to such a financial merger.
INTERROGATORY NO. 9-10 Describe the financial impact on LIC that would result if PaPUC were (a) to revoke Met-Ed's standing as a public utility, (b) to.. exclude TMI-l from its rate base until such time, if any, that TMI-l is permitted to restart. Describe in detail the effect on LIC's financial ability to operate TMI-l that-(a) and (b) above would have.
I
T
. RESPONSE Licensee objected on March 14, 1980, to the scope of this interrogatory but did agree to furnish information as to the portion of Licensee's current base revenues attributable to TMI-1.
This information is summarized in the following Table and the ex-hibits referenced in the Table will be placed in the Discovery Reading Room. The TMI-l expenses and returns allowed in the last retail rate case are:
Details contained in Pennsylvania Docket S Millions No. I-79040308, Exhibit Jersey Central 14. -
Met-Ed 26.9 A-16 Penelee 11.7 A-32 INTERROGATORIES NO. 12-1 through 12-6 See Interrogatories no. 5-1 through 5-6.
RESPONSE
See Licensee's response to Interrogatories 5-1 through 5-6.
INTERROGATORY NO. 12-7 Provide a detailed explanation of Licensee's criteria for deter-mining, from the realm of possible accidents, which accidents fall within the design basis. If Licensee's criteria is based on the assumption of single failure (of systems or components), provide a full and complete justification for so limiting design basis accidents, and for excluding design basis consideration of multiple failure accidents. If any assumptions are made concerning probabil-ities, provide full and complete documentation of the basis and justification for computing such probabilities. Identify all doc-uments relied on, and for each such document, identify the princi-pal authors, their professional qualifications, and relevant publications.
RESPONSE
Licensee has objected to this interrogatory.
INTERROGATORY NO. 12-8 Identify any and all known documents that challenge Licensee's justification for refusing to consider multiple failure accidents in developing design basis criteria for nuclear power plant opera-tion. For each such document, identify the principal author (s),
their professional qualifications, and relevant publications.
Provide a brief, but detailed summary of the arguments advocated in each such document.
RESPONSE
Licensee has objected to this interrogatory.
INTERROGATORY 12-9 Specify, in numberical probability terms per operating reactor year, the probability of an accident below which probability the accident is not considered credible by Licensee. Provide a full and complete justification for the Licensee's selection of that probability level as the cutoff point for accident credibility.
Identify any and all documents relied upon in this answer.
RESPONSE
Licensee has objected to this interrogatory.
INTERROGATORY 12-10 Describe in detail the process relied upon by Licensee in computing the probability of any given accident sequence. Provide detailed and thorough justification for this computational method, paying particular attention to the respective determination of the role of human (operator) error as compared to roles of equipment and instrumentation information malfunction. For each of the above- i identified three components of error-(operator, equipment, and instrumentation-information) demonstrate the extent to which the assumed probabilities are based on past experience or on other estimates. Where past experience is used as a basis for probabil-ity estimates, state whether the estimate is based on past exper-ience with identical reactors and control room designs to TMI-1; i
t
49 o a .
if not, state what methods are relied upon to take into the account the specific reactor and control room-dependent character-istics of TMI-1, as well as the quality and effectiveness of oper-ator training and emergency procedures at TMI-1; if there is no-such consideration of TMI-l specific parameters of probability in determining accident probability, provide a full and thorough justification why such consideration is not needed. If estimates other than those based on past experience are utilized in .calcu- l lating probabilities, provide a detailed justification and basis for those estimates.
RESPONSE
i Licensee has objected to this interrogatory.
INTERROGATORY NO. 12-11 !
Identify any and all experts who were relied upon in providing the answer to 12-10 above; for each expert provide name, address, phone number, and professional qualifications. ,
RESPONSE
Licensee has objected to this interrogatory. !
INTERROGATORY NO. 12-12 f Identify and all documents that were relied upon in providing +
the answer to 12-10 above; for each document, provide author (s), ,
and their professional qualifications. l
RESPONSE
Licensee has objected to this interrogatory.
INTERROGATORY No. 12-13 !
In a document dated Jan. 25, 1980 from Steven A. Varga to All i Boards,in reference to Turbine cracking, it is stated that !
...the probability values used...may have been too low and may be revised upwards." Identify any and all other circumstances l known to Licensee where the probability estimate of-any equipment, ;
instrumentation, or operator error or malfunction has had to be ;
revised upwards by NRC or by any Licensee in the light of'exper- :
ience, research, or other new information. Provide, for compar-ison, identification of'any and all circumstances in which such i
i I
[
probability estimates have been revised downward in the light of experience, research, or other information. Do these data provide any evidence of an overall trend towards high or lower overall probability of errors, malfunctions, or transients? Provide justification for your conc.lusions.
RESPONSE
Licensee has objected to this interrogatory.
INTERROGATORY NO. 12-14 A meeting was held on Octoer 23, 1979 with representatives of the B&W owners' group, B&W, & Oak Ridge National Laboratory (ORNL) to discuss the " Integrated Control System Reliability Analysis" (BAW-1564) and questions raised of this Analysis by ORNL.
Question 12 and the response are quoted below:
" Question 12: " Multiple failures are not treated although it is acknowledged by B&W that many failures are not annunciated and therefore may exist until other failures occur, resulting in effective multiple failures. It appears that multiple failure situ-ations may have significant probability of occur-rence. How is the omission of multiple failure considerations justified in the analysis? Might Fault Tree Analysis have been a better technique for addressing the concerns and producing the results requested?
Response: B&W has identified transients that have occurred, in the Operating History Section. Therefore, with respect to multiple failures the report has identified critical areas. Although this is true, an event tree of ICS may highlight other important multiple failures. this type was considered to be too exten-sive for the time available."
(Sun: mary of meeting, at 7, emphasis added) a) Answer fully and completely the two questions posed in Question 12 above.
b) Provide full and complete description as to any Fault Tree Analysis (FTA) that has been conducted or commissioned by or for
7 t
[
Licensee or B&W to remedy the omission of' multiple failure considerations; provide a. full justification for the scope _of such FTA as had been conducted or commissioned. c) If no FTA-has been conducted or commissioned pursuant to the above cited question, provide a full.and complete justification as to why such FTA was not considered necessary. d) If the lack of avail- .
able time is cited as one such justification, provide a full and complete explanation-as to why the health and safety of the !
public would not be more reasonably protected by delaying restart i of TMI-l until there has been sufficient time to conduct such FTA i as is required to eliminate or substantially reduce.the proba- !
bilities of occurrence of multiple failure situations.
RESPONSE
Licensee has objected to this interrogatory. f INTERROGATORIES NO. 13-1 through 13-6 See Interrogatories no. 5-1 through 5-6. !
i RESPONSE i i
See Licensee's response to Interrogatories 5-1 through 5-6. !
INTERROGATORY NO. 13-7 i Describe in detail any and all screening procedures, known to the Licensee to detect the development or existence of an opera- j tor "mindset," wherein an operator is so conditioned on the basis '
of his experience, in conjunction with prevailing management and operating attitudes, to substanially rule out an interpretation of a sequence of alarms, adverse signals, and indications of abnormal transients, as indicative of a major. accident with consequences of '
a partial or full core melt. If any psychological tests are.so' used as *creening procedures, identify such tests, identify the author of such tests, and his/her qualifications and professional background, and summarize any research-that has investigated ,
whether the tests provide an accurate indication of the existence of such an coerator "mindset."
l RESPONSE l i
Licensee is not aware of any screening procedure in use for nuclear _ power plant operators specifically aimed at' detecting a "mindset" as defined in this Interrogatory.
?
- INTERROGATORY 13-8 i
Describe in detail any screening procedures that will be used by Licensee to detect the development or existence of an operator "mindset" (as defined above). Summarize any research that has been conducted to evaluate the efficacy of such screening proce-dures, identifying the principal investigator (s), and providing their professional qualifications.
A
RESPONSE
See Response to Interrogatory No. 13-7.
INTERROGATORY 13-9 Identify any and all known research investigating the relationship between the development of operator "mindset" and the frequency of alarms or indications of minor abnormal transients, and/or the frequency of false alarms or other false indications of abnormal transients. For each such research, identify the principal investigator (s), describe their professional qualifications, and summarize the findings of the research.
RESPONSE
Licensee is not aware of any research on the relationship between the development of operator "mindset," as defined by the Intervenor in Interrogatory No, 13-7, and the " frequency of alarms or indications of minor abnormal transients, and/or the frequency of false alarms or other false indications of abnormal transients."
INTERROGATORY NO. 13-10 Identify and describe any and all studies that have been developed, commissioned, or planned by Licensee into factors associated with the development of operator mindset. If so such studies have been prepared, commissioned, or planned by Licensee, provide full and detailed justification why such studies are not considered to be necessary.
RESPONSE
Licensee has not developed, commissioned, or. planned studies
o .
specifically addressing factors associated with the development of operator "mindset" as the term has been used by Intervenor.
Licensee believes that its training and testing standards, together with ongoing performance by management will assure that operators will properly analyze control room information and respond in an appropriate manner.
INTERROGATORY NO. 13-11 Describe in detail C y and all communication and dialog.that has taken place between Licensee and professionals with experience and research into operator mindset in situations analogous to nuclear power plant Control Rooms, for example, personnel in the NASA Aviation Psychology program. If no such communication and dialogue has taken place, provide a thorough justification as to why that has not been considered necessary or valuable.
RESPONSE
Licensee has objected to this Interrogatory except insofar as it requests that Licensee identify communications and dialogues, if any, between Licensee and professionals with experience and research into operator mindset.
Licensee is not aware of communication and dialogue between Licensee's employees and professionals with experience and research into operator "mindset," as that term has been defined by the Intervenor, in situations " analogous to nuclear power plant Con-trol Rooms, for example, personnel in the NASA Aviation Psychology program." See Licensee's March 14, 1980, partial objection to Interrogatory No. 13-11.
I o .
INTERROGATORY NO. 13-12 (a) Does Licensee maintain full and complete records of any and all alarms that have been displayed on the control rooms of TMI-1 and TMI-27 If so, identify any and'all documents recording the occurrence and frequency of such alarms and whether such alarms are false alarms. If not, provide a full justification as to why such documentation is not maintained. (b) Has Licensee conducted or caused to be conducted any systematic analysis of the frequency and occurrence of alarms (including false alarms) that have been displayed on the TMI-1 and TMI-2 control panels? If so, identify, and provide a detailed summary of any and all documents describing such analyses. If not, provide a full justification as to why Licensee considered such analysis as not necessary. (c) If Li-censee has conducted such analyses, has Licensee conducted, or caused to be conducted, any investigation into the relationship between the frequency of alarms, false alarms, and the development of operator "mindset".
RESPONSE
Licensee has been unable to complete its response to this interrogatory and will supply its response within two weeks.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: .Aj x M[/,j yorgy'F.'Trowbridge /
Dated: March 31, 1980 1
l l
l
i\
. o SHAw, PITTMAN, PoTTs & TROWBRIDGE 8800 M STR E ET, N. W.
WASHINGTON, D. C. 20036 eAMSaf O. poTTS STE PM EN S.MuTTLER 1202)33t esCO STEUAmt L. PITTM AN WINTMnOR N. SmCwN _
QComOE F. Taowenico! JAMES S. M AM uN CTE PM E N O. POTTS ROSEnf C.ZAMLEn TELCCCPIEm Q ERALO CHARNCFF #4CMamo E.QALEN AMILua O. SOSTwsCa ROS Em? 3. ROS$1Ng 4202)296 0694 & 286 0760
- m. TIMOTMY MANLON STEVCN M. LUCAS -
QEOmOC M ROG E a s. J R. M Af tAS F. TmavtCSC DIAZ JOMN S. mMINCLANOEm VICTCNIA J. DEMINS TELEX C.30CC w. CMumCMtLL JOM N M. O'N EILL. J R.
g g ,gg g g g ggg,L,g ,gg g LESU E A. NICMOLSON, Jm. JAY A. CDSTIEN MAnflN O. AmALL NANO L. ALkEN CA B LC "$ M AW LAW "
KICMam0 J. KENOALL TIMOTM f S. Me S pl O C JAv C. SILSEmo E LIS A B ET H M PEN O LCTO N ~
CAmeanA M. mCSSOTTI LuCV G.EuASOF C EOmO E V. ALLEN. JR Paul A. M A PLAN EOwAND S.CmCSLAND ww. Sm AQronO aCYNCLOS MAmmf M. GLAS SDICO EL CQuNSEL FRED A.uTTLE TwoM AS M Mc CQ a MIC M FRED ORASNER sus AN O. FAL* SON NATM ANIEL m S WE ED. JR. WILLI A M
- SAmm MAmM AUGENSUCR JCMN 6. .A mm, s m.
EiN E ST L. BLAM E. JR. DMtLam J.MaevEY CARLLTON S. JON E S ACS ERT M. GCROON THOM AS A. SAKTCm JCANN E A. CALOCRON JAMCS M. SumoEn Samsama J. MonoEN8 CMELOON J. WEISEL SONNIE S. GOTTLICS JOMN A. McCULLouGM ALFm EO M. poSTELL J. patalCM MIC u ty SETH M. MCCoASI AN JAMES TMCMAS LENMAm? SMEILA C.McCAFFEmTV LTEVEN L. MCLTZC A DELIS SA A. mlOGwaf DEAN O.AuuCn R CN N ETH J. M AUTM AN JOHN ENQEL Davf D LAWRENCE MILLCm M., A.M.m. .M r e. March 31, 1980 Mr. Robert Q. Pollard 609 Montpelier Street Baltimore, Maryland 21218 Re: Three Mile Island Unit 1 Docket No. 50-289 (Restart)
Dear Mr. Pollard:
I enclose Licensee's responses to CEA's first set of interrogatories, dated February 25, 1980. Copies of signed affidavits for the enclosed responses are not included, but will be forwarded soon.
Sinc rely yours, e
mM F. T owbridge Enclosure cc: Service List