ML19309A708
| ML19309A708 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/25/1980 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19309A704 | List: |
| References | |
| NUDOCS 8004010042 | |
| Download: ML19309A708 (15) | |
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'~ g DOCKETED UNITED STATES OF AMERICA --
NUCLEAR REGULATORY COMMISSION g FEB 2 71980 > -
Office of the Secretary BEFORE THE ATOMIC SAFETY AND LICENSING BOARD r!n h
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In the Matter of N MEIROPOLITAN EDISON COMPANY Doc 50-289 (Three Mile Island, Unit 1) )
INIERVENOR STEVEN C. SHOLLY SECOND SEI 0F INIERROGATORIES -
AND DOCUMENT REQUESTS TO NRC STAFF Intervenor Steven C. Sholly hereby files the following interrogatories and' document requests with the NRC Staff pursuant to 10 CFR Part 2 and Staff's statements at the Second Special Prehearing Conference,13 February T980, regarding filing and answering of Interrogatories and Document Requests by NRC Staff. The answer to each interrogatory should contain the names and identifications of the persons supplying the answers. In addition, all documents relied upon in supplying the answer to each question are to be referenced in the answer according to title, authors, source of document, identifying numbers, and page numbers utilized in supplying the answers.
Interrogatories and document requests are considered to be continuing and are to be supplemented as required under NRC regulations. In particular, any documents supplied in response to a request i;h! ch are superceded in whole or in part should e supplemented by supplying 80040100
e the new documents and an explanation detailing which portions of the original documents are no longer in force.
Interrogatories and document requests are arranged by Contention numbers and request number within that particular contention. For instance,08-012 refers to Interrogatory or Document Request #12 on Contention #8.
01-005--Does Staff consider it adequate from a pubile health and safety standpoint for Licensee's proposed high radiation containment isolation signal not to meet the single-failure criterion? If so, explain why the pubile health and safety is adequately protected by not requiring the high radiation isolation signal to meet the single-failure criterion.
15-005--In NUREG-0560 at page 4-5, it is stated:
"NRC is sponsoring a safety-related operator action study to determine, with better precision, the times required for operator response. A second study sponsored by NRC addresses human reliability based on a detailed review of Licensee Event Reports (LERs)
I to develop reliability numbers for risk assessment studies. Finally we l are sponsoring a human reliability study regarding maintenance and instrument calibration tasks."
With respect to the referenced studies, answer l the followings l
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- a. To what extent are these studies underway or completed? Specify the names of the studies, who is performing them, and when the study was completed or is due for completion.
- b. Provide copies of the final reports resulting from these studies; if not yet available, provide a date when they will be available and provide a draft report if available.
- c. When they are completed, to what extent will the recommendations of these studies be applied to TMI-1?
- d. When the results of the LER review are completed, will these results be used by Staff to review accident analyses for TMI-1 to determine if any of the accidents analyzed should be reclassified, especially with respect to examining sequences for possible Class 9 events which should be analyzed either on a generic or case-by-case basis?
15-006--In view of the continuing analysis of the causes of the TMI-2 accident, and with regard to the human factors analysis of the TMI-2 control room and operator performance l during the accident (NUREG/CR-1270, 3 volumes), does the ;
following conclusion contained on page 4-5 of NUREG-0560 l
still apply, and to what degree "The Risk Assessment Review Group recognized ,
the difficulty of incorporating operator l error into fault tree analysis. However, '
the Group believed that the RSS underrated 1 the role of operators and other employees in-mitigating or controlling some potential accident sequences, particularly those that required a reasonably lengthy time to degenerate."
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15-007--I am informed by telephone conversation with NRC Staff attorney Lisa Singer (02/19/80) that NRC has not included TMI-1 in the ongoing study into human factors analysis of reactor control rooms being conducted by Essex Corporation. Explain why TMI-1 was not included, especially in view of the nunerous human factors problems identified in the review of TMI-2's control room (as detailed in NUREG/CR-1270, 3 volumes).
15-008--NRC has stated in response to an Interrogatory from ANGRY that it expects to have published on or about 1 April 1980 a set of review guidelines for control board layout and information presentation.
Is this date still firm 7 If not, estimate when the guidelines will be released (provide copies when they are released). Will these guidelines be applied to TMI-1, and, if so, will Licensee be required to back fit TMI-1 to bring it into compliance with the review guidelines? If backfit will not be required, explain why not.
15-009--In response to ANGRY Interrogatory 2, Staff stated that an NRC representative has been placed on the working group revising IEEE Std 566. Identify that
i NRC representative by name, title, and NRC division in which employed.
15-010--NUREG/CR-1270 volume I contains a fairly ringing criticism of Licensee's training program with respect to the Unit 2 operators. Does contemplate or have underway an in-depth review of Licensee's training programs with respect to TMI-1, especially the Operator Accelerated Retraining Program (OARP) discussed in Section 6 of the Restart Report? If so, identify the study, describe its purpose, list its members, and identify, if not an NRC review, what organization is performing the review. If such an in-depth review is not contemplated or underway, explain why not.
If such a review has been completed, supply a copy of the results. /
15-011--On page 8-9 of NUREG-0560, it is stated:
"While the merits of the single failure criterion may be significant as a '
design basis, it is not clear that it should be considered as a ilmiting basis for training purposes."
On this basis , has TMI-1 training been reviewed to determine the extent to which this training has been limited to single.-failure considerations, especially with respect to the OARP? If so, provide results of such a review. If not, explain why not.
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15-012--W111 Staff require Licensee to install an automatic recorder (either audio or videotape) to record operator actions during emergencies? If so, will the
. system be required prior to restart? If not required to be installed, explain why not in view of the lack of specific information which is missing from the logs of the Unit 2 accident, as detailed in NUREG-0600.
15-013--What is Staff's posttion regarding the necessity of a thorough human factors evaluation of the TMI-1 control room and training program prior to restart?
07-002--According to NUREG-0560 at page 8-13.
"The TMI-2 accident indicates that the possible effects on core coolability for smaller breaks are not completely understood. In this regard, the concern deals with such matters as the sensitivity of the break location, reliance on the steam generator as.a heat sink, the effects of delays in the availability of the auxt1Lary feedwater system, and long-term cooling using natural circulation. Furthermore, based on the expertenced gained from the TMI-2 accident, the effects of equipment malfunction and human error have not been studied in sufficient detall."
With respect to this statement, answer the followings
- a. To what extent have these concerns been answered since the pubilcation of NUREG-0560?
- b. To what extent do Licensee's submittals on LOCA analysis address these concerns?
- c. In view of the above statement, does Staff consider Licensee's analysts of the effects of SBLOCA's adequate? If net, why not?
- d. Has Staff underway a review of or has Staff contracted for a review of the impact of equipment malfunction and human error on the analysis of SBLOCA's? If so, provide details ,
including name of study, organization perform-ing the study, the expected completion date, and the names of Staff personnel involved in such a study. Also provide copies of draft or final reports resulting from such a study.
- e. Has Staff underway a review of the impact of break location on SBLOCA analysis , or has Staff contracted for such a review? If so provide details as in "d." above. Also provide copies of draft or final reports arising from such a review.
07-003--In, reference to the discussion at pages 8-12 through l 8-13 in NUREG-0560, has Staff required B & W or Licensee to perform the referenced analyses? If s o , to what extent do these analyses address single failures of safety features and control system interactions during transients, especially LOCA's and feedwater transients?
Reference the studies by title, author (s), source of report, a.nd publication date.'
08-010--Does Staff plan to require core melt mitigation features to be installed at TMI-1 prior to restart to ensure adequate lead time to implement protective actions in the event of a core melt? If not , explain why not, especially in the light of recent investigations by the "Roggovin Group" which suggest that TMI-2 came within 30-60 minutes of a core melt.
08-011--Are there any specific requirements for updating and maintaining updated letters of agreement and understanding with respect to emergency planning? If os, cite the regulations , regulatory guides , policy statements ,
etc., which require such updating. What is Staff's position regarding the necessity for updating of all letters of agreement for TMI-1 which were executed prior to the Unit 2 accident?
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08-012--What is Staff's position regarding the sufficiency of Licensee's description of the proposed 50-mile EPZ for ingestion exposure pathway as found in the " Restart Report"7 08-013--To what extent has Staff analyzed the local and state emergency plans upon which Licensee is dependent to ensure protection of pubile health and safety? Has Staff examined the assumptions underlying the state and local plans and compared these assumptions to the Licensee's Emergency Plan (section 4, Restart Report) to verify that these plans properly in'erface?
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10-002--In a communication to Robert Arnold (NRC/TMI-80-022, 02/07/80), John Collins of NRC indicates that activities scheduled for the Auxiliary and Fuel Handling Buildings l l
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at Unit 2 present a significant risk of inadvertent radioactive releases inside the buildings . What is Staff's position regarding the sufficiency of TMI-1/2 physical separation in terms of preventing such releases from adversely impacting on the safe operation of Unit I?
16-004--In view of the recent developments at TMI-2 wherein
. a reporter using improper identification obtained a security force position, has Staff's position regarding the need for improved security at TMI-1 and 2 changed?
If so, explain how.
16-005--Is it possible for the Unit 2 reactor at TMI to be placed into a mode which will result in core melt, and, if so, could this be accomplished by a deliberate act of sabotage by an insider at the plant in such a manner as to preclude preventing meltdown? If so, what steps will Staff require to ensure that this sequence of events can be prevented?
l ~ 17-005--In view of the fact that in the Alternative Event i Sequence Report (NUREG/CR-1219, page 5-14) a case is described which parallels closely Scenario "B" in Contention 17, and which the referenced report concludes would have resulted in core meltdown within one hour of power loss, what is Staff's position regarding
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the need for including within the accident analysis l
l for TMI-1 an analysis of the consequences of a core l
melt sequence?
16-006--The following documents are requested (if it is not possible to send them to me, please see that they are placed in the York PDR, York College):
- a. NUREG-0576, " Nuclear Power Reactor Security Personnel Training and Qualification Plan Review Workbook" , which was sent to Licensee by J.R. Miller, Assistant Director for Site and Safeguards, 07/30/79 (see NRC Acc. #
7909250158)
- b. Revised version of SAND 77-1033, " Entry Control System Handbook," which was sent to Licensee by J.R. Miller, 01/09/79 (see NRC Acc. #
7903120144)
- c. Revised version of SAND 76-0554, " Intrusion Detection System Handbook, " which was sent to Licensee by J.R. Miller, 01/09/79 (see NRC Acc. # 7903120144)
- d. Revised version of NUREG/CR-G;31, " Barrier Penetration Database," which was sent to Licensee by J.R. Miller, 01/09/79 (see NRC Acc. # 7903120144)
- e. NUREG-0219, " Nuclear Security Personnel for Power Plants Content and Review Procedures for a Security Training and Qualification Program," which was sent to Licensee by J.R. Miller, 10/30/79 (see NRC Acc. #
7910310581)
- f. "Sandia Barrier Technology Handbook," which was sent to Licensee by J.R. Miller, 06/12/78 (see NRC Acc. # 7910240839)
- g. Sandia Laboratories , " Systematic Approach to ;
Conceptual Design of Physical Protection Systems for Nuclear Facilities," which was sent to Licensee by J.R. Miller, 06/12/78 (see NRC Acc. # 7910240481)
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. 07-004--The following document are . requested:
LER 79-015/01T-0 on 07/23/79, from D.G. Mitchell,
, Metropolitan Edison Company (NRC Acc.# 7908170430)
RO 79-15/1T, from J.L. Seelinger, Metropolitan Edison Company (NRC Acc.# 7908130472) 14'-003--NUREG-0616, at page 46, states that:
"SRG concluded that Licensee personnel frequently ignored station procedural require-ments and that administrative controls were not effective in many different functional areas of the station."
In reference to this statement, answer the following s
- a. Specify the procedural requirements which were ignored by Licensee personnel, especially in the case of procedural requirements relating to emergency procedures, technical specifications, and engineered safety features actuation and associated procedurcs.
- b. Specify the functional areas in which Licensee administrative controls were ineffective, and discuss the inadequacies in administrative control present in each of the functional areas.
14-004--NUREG-0616, at page 48, states that:
" Lack of adequate corrective action by manage-ment to prevent recurring problems is common to the subsequent sections of this report dealing with plant maintenance, quality assurance, and radiation controls. The SRG believes that Licensee management was deficient in this area . . . "
In reference to this statement, answer the followings
- a. Provide details describing the manner in which l Licensee has failed to take adequace corrective actions to prevent recurring problems.
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- b. For each area in which plant management was deficient in requiring adequate corrective action to prevent recurring problems, provide documentation which shows that Licensee was advised of what was required and yet fatled to follow through with requirements or commit-ments for improvements.
14-005--NUREG-0616 at page 51, states that:
... the TMI investigation identified that test documentation records required by 10 CFR 50 ;
AppendLx B and by-LLeensee administrative. controlsc -
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were not kept as objective evidence of work per-formed nor were they reviewed by the Licensee managers and/or supervisors as required. Ltcensee ,
personnel stated during the investigation that there was insufficient storage space for records ."
In reference to this statement, answer the followings
- a. Specify the records which were not kept although -
required by 10 CFR 50 Appendix B and LLcensee administrative controls.
- b. Identify the Licensee personnel who stated that there was insufficient storage space for records, and provide documentation which contains exact quotes regarding this matter, if such documentation extsts.
08-014--NUREG-0616, at page 104, states that, "The licensee emergency plan and implementing procedures required actions which could not be supported, during the initial phase of the accident, by existing licensee resources."
To what extent has this sLtuation changed since the accident, i.e., does Licensee now possess sufficient resources such that its emergency plan implementing procedures can be implemented in timely fashion?
08-015--Has Licensee's emergency plan and implementing procedures been reviewed regarding the ability of Licensee to collect environmental radiation samples under adverse weather conditions? Does Licensee possess sufficient numbers of 4-wheel drive vehicles , snowmobiles ,
boats, and helicopters such that there is reasonable assurance that environmental surveys can be accomplished
.under adverse weather. conditions (how many of. each -
vehicle ilsted herein does licensee possess)7 08-016--Does Licensee meet the guidelines for emergency pre-paredness meteorological criteria contained in Appendix 2 to'NUREG-06547 If not, in what areas is Licensee deficient with respect to these criteria? Also, if not, will Staff require full compliance prior to restart?
If full compliance will not be required, explain why not in terms of protection of public health and safety during emergency conditions.
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Respectfu11y' submitted ,
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Steven C. Sholly pg7 DATED: 25 February 1980 304 South Market'S6 et Mechanicsburg, PA 7055 h--717-766-1857 w--717-566-3237
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of MEIROPOLITAN EDISON COMPANY Dock No. -289 (Three Mile Island, Unit 1) )
CERIIFICATE OF SERVICE I hereby certify that single copies of IFIERVENOR STEVEN C. SHOLLY SECOND SET OF-INIERROGATORIES AND DOCUMENT- REQUESTS TO NRC STAFF were served upon the persons on this service list by deposit in the United States Mall, postage prepaid.
on this 25th day of February 1980.
OU. * ,
E-Steven C. Sholly
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Ivan W. Smith, Esq. Docketing and Service Section Chairman, Atomic Safety and Office of the Secretary l Licensing Board U.S. ~ Nuclear Regulatory U.S. Nuclear Regulatory l Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 John A. Levin, Esq. ;
Dr. Walter H. Jordan Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Board Panel Utility Commission 881 West Outer Drive P.O. Box 3265 Oak Ridge, TN 37830 Harrisburg, PA 17120 Dr. Linda W. Little Karin W. Carter, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel Commonwealth of Pennsylvania 5000 Hermitage Drive 505 Executive House 1 Raleigh, NC 27612 P.O. Box 2357 Harrisburg, PA 17120 James A. Tourte11otte, Esq.
Office of the Executive l Legal Director (OELD) l U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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John E. Minnich Holly S. Keck Chairman Legislation Chairman Dauphin County Board of ANGRY Commissioners 245 West Philadelphia Street Dauphin County Courthouse York, PA 17404 Front and Market Streets Harrisburg, PA 17101 Robert Q. Pollard Chesapeake Energy Alliance Walter W. Cohen, Esq. 609 Montpelier Street Consumer Advocate Baltimore, MD 21218 Department of Justice 14th Floor, Strawberry Square Chauncey Kepford Harrisburg, PA 17110 Environmental Coalition on Nuclear Power Jordan D. Cunningham, Esq. 433 Orlando Avenue Attorney for Newberry State College, PA 16801 Township TMI Steering Committee Marvin I. Lewis 2320 North Second Street 6504 Bradford Terrace Harrisburg, PA 17110 Philadelphia, PA 19149 Theodore A. Adler, Esq. Marjorie M. Aamodt Attorney for IMIA R.D. # 5 Widoff, Reager, Selkowitz, Coatesville, PA 19320 and Adler P.O. Box 1547 George F. Trowbridge, Esq.
Harrisburg, PA 17105 Attorney for Licensee Shaw, Pittman, Potts, &
Ellyn Weiss, Esq. Trowbridge Sheldon Harmon, & Weiss 1800 M Street, NW Attorney for UCS Washington, D.C. 20036 Suite 506 1725 I Street, NW Washington, D.C. 20006 Karen Sheldon, Esq.
Sheldon, Harmon & Weiss Attorney for PANE Suite 506 1725 I Street, NW Washington, D.C. 20006