ML19308B708
| ML19308B708 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/10/1979 |
| From: | Berick D ENVIRONMENTAL POLICY INSTITUTE |
| To: | Cornell K, Deyoung R, Frampton NRC - NRC THREE MILE ISLAND TASK FORCE |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001160774 | |
| Download: ML19308B708 (3) | |
Text
m C.
Environmental Poh,cv Institute v'
317 Pennsylvanw Ave. 5.E. Plashini;mn D.C. C003 202'544 8 00
,Y,g8 8/10/79
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,To: George Framnton, Richard DeYoung, Kevin Cornell g
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NRC/Dil Special In uiry Group h.f
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From:' Dave Ecrick
,J,h h
k Re: Dil Investigation fl
,I
'AfteramoreleisurelyreviewoftheJuly30"Outlineofthe@FinalReport",
several areas which~I believe require further attention have come to mind:
- 1) Generic Issues--While Section 3(dealing with precursor events)and Section 4 (dealing with NRC standards, requirements and procedures) tangentially ad-dress the problem of generic issues, there should be a more direct discussion.
Not only did a. specific generic' issue--hydrogen generated from a circonium-water reaction--contribute heavily to the D1I incident, but generic issues underlie the entire-NRC licensing process.
The study has the obligr. tion to address not only those particular generic issues raised in the DII situation n - -~.
- h.L ',l" 'such as the zirconium-water problem, but the NRC treatment of such problems
" J.? z, as well.
- 2) Audit Review Philosophy--While the investigation spends a considerable (and justifiable) effort on the licensing process including the relationship betwecn the Standard Review Plan and the review of D:I-2, the " audit review" philo-
,ll t/ sophy which the NRC employs should be examined. The Standard Reviav Plan hr.s a number of inadequacies including the failure to review structural and mechanical calculations, failure to review ncn-safety systems outside of the context of design-basis accidents, failure to address procedures and trainin;:
in light-.of design features, and so on.
These shortcomings are a result of the 22C philosophy that it may simply audit the industry's design, manufacturi:
and-construction efforts and review a handful of areas of uncertainty.
The result is an unacceptable reliance upon qualit. assurance programs and vender Pr.n:tJ e.mey&J mu 80013go;7y
,o
e EP1 commente-2 expertise. As in the case of TMI, the industry has the capcbility to
" catch" =istakes.
The Michelson report or the B&W internal memoranda certainly confirm the technical capability.
The issue here is the re-liance upon industry implementation and QA to protect public health and safety.
I believe that a description of the " audit review" philosophy t/ and its implications would be a valuable additio. to the report.
3)
Radiological monitoring--There is no point at which the reliance by the NRC upon the utility for all radlulogical monitoring--on-site and off--
exists in the report outline.
Section 5.2 deals with the health physics program but does not address the issue of " captive" laboratory analysis.
~ The commercial laboratory analysis of film badges, TLD's, and environ-mental samples should be addressed.
In the TMI situation, there is an apparent conflict of interest situation in which GPU had such a prominent role in establishing and maintaining the laboratory in question.
Reliance upon utility and utility-contracted laboratories for radiological monitoring is one of the more glaring weaknesses in the NRC's surveillence of operating reactors.
4)
Accident nitigation--Studies exist en the ability to mitigate the crnsequences of' nuclear powerplant accidents through such mechanisms as distribution of
In the case of TMI, there seems to have been a noticeable failure to effect these measures to say nothing of the failure of the existing emergency mechanism. The report should address the issue of accident mitigatirr mechanisms beside evacuation, including the issue of reactor siting. Section 4 addresses the issue of prevention or amelioration of the accident through regu-
'latory requirements, but plant siting is conspicuously absent from the list.
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EPI cors:nts-3 0
5)
Shutdown of B&W reactors--Section 7,which deals with the adcquacy of the NRC response, fails to address the implications of the TMI incident, or any other accident, for operating reactors 9 'ing and immediately after the accident.
In the case of TMI, the immediate question was the risk at othq'r B&W reactors.
There is some question over the ability and manner in which NRC made these determinations and conducted a shutdown of other B&W reactors.
This issue should also be addressed in Section 1 of the report probably somewhere near Section 1.8 or 1.9.
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