ML19309C030
| ML19309C030 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/1980 |
| From: | Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Aamodt M AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19309C022 | List: |
| References | |
| NUDOCS 8004080051 | |
| Download: ML19309C030 (48) | |
Text
\\,
STAFF:
3/31/80 e
UNITED STATES OF AMEPICA NUCLEAR RH;ULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
MLTROPOLITAN EDISON COMPANY, ET AL.
)
Docket No. 50-289
)
(Three Mile Island Nuclear Station,
)
Unit 1)
)
NRC STAFF RESPONSE TO INTERVENOR AAMODT INTERROGATORIES; SETS ONE AND THREE THROUGH SIX Pursuant to 10 CFR 82.720 and 10 CFR 82.744, the NRC Staf f has responded to Intervenor Aamodt's Interrogatories to the NRC Staff, Sets 1, 3, 4, 5 and 6.
As noted in "NRC Staff Objections to Intervenor Aamodt's Interrogatories to the Staff," dated March 17, 1980, the Staf f objects to the Second Set.
Each interrogatory is restated and a response provided, k'here appropriate, the s
NRC Staff has invoked that portion of the Commission's Order of August 9, 1979
( S1_if 2 at 11) which allows as an adequate response to a discovery request a 0
statement that information is available in the Local Public Document Rooms and guidance as to where the information can be found.
Following the responses to-the Interrogatories are affidavits identifying the individuals who prepared the responses and verifying them..A complete set of enclosures to this Response is being sent to the members of the Board and to the Licensee. A con-plete set is also being forwarded to the local public document rooms.
Respectfully submitted, av /
wm Daniel T.
Swanson Counsel for NRC Staff s 004 080 05 h
V.
e AAMODT'Ist Set Interrogatory 1:
In the case of routine radioactive plant releases, f
a.
Under what circumstances'are quantitics estimated?
b.
Ilow are they estimated?
c.
What is the confidence level of this estimate?
d.
What emissions are never measured?
e.
What emissions are never reported?
f.
What emissions are sometimes not reported?
g.
Under what circumstances of (f) are emissions not reported?
Response
s la.
Section 4.4., Table 3, of the Appendix B Technical Specifications s
describes the number, type, location, sensitivity, and collection frequency of environmental radiological sampling.
These samples are taken routinely and serve to provide information regarding integrated accumulation offsite radiation level.
Ib.
The method of measurement of offsite radioactivity that is used depends upon the type of radioactivity that is being looked for.
For example, for air fodine-131 concentration charcoal cartridges are used. The methods for each are listed in Table 3 of Section 4.4 to the Appendix B technical specifications.
Ic.
For milk sampling one sigma 25% confidence levels are required.
For other types of sampling, measurements are required to meet " state of the art" sampling sensitivities. These are listed in Table 3, Section 4.4 of the l
Appendix B Technical Specifications.
1 i
V AAMODT 1st set.
Id.
Predictions of radioactive releases from this reactor are made based on actual measured releases from similar reactors. The environmental monitor-ing program is designed to measure all environmentally significant releases of'.
radioactivity.
le.
All measurements of radioactivity that are required to be made by the Technical Specifications are reported in the operating reports.
If.
Same as e.
Ig.
Same as e.
Interrogatories 2 and 3:
2.
Same as (1) for accidential releases.
sg 3.
Same as (1) for releases associated with reactor shut-down s
s
Response
Same as (1).
Interrogatory 4:
Provide best estimate of quantities by type (such as I-131) for d, e, and f of 1, 2 and 3.
Response
The radioactivity that is anticipated to be released from the plant is described,
l in the Staf f's Final Environmental Statement forTMI-1(FES),ChapterII5.
Measurements of actual releases of radiation generally confirm the estimates contained in the FES. The results of these measurements can be found in the annual operating reports for TMI-1.
Copies of the documents are located in the local public document room.
AAM3DT - 3rd SET Interrogatories
~
1.
What data,will be,'or is planned to be, monitored by HRC staff at an NRC control center according to your proposed plans?
2.
What will be the mechanism for data transmission?
3.
What objection, if any, would you have to providing this data simultaneously to local county commissioners?
Response
fhe data transmitted to the NRC Emergency Response Center in Bethesda, Maryland will be by telephone.
The data sent or requested will be based primarily upon the incident. The licensee has established an Emergency Operating Facility at the Visitors Center for the timely receipt of information for Federal, State and
~ local officials. Representatives of the local county governments are expected N '
to be there in the case of a site or general emergency.
s i
Interrogatory 4.
What was the NRC role in restricting national TV news programming in the Harrisburg area during TMI-2 accident?
Response
The NRC did not restrict national TV news programming in the Harrisburg area during the TMI-2 accident.
Interrogatory 5.
What studies have you made_ to assure telephone circuit availability during an -emergency?
Response
The telephone circuit to the NRC and the Emergency Operating Facility are dedicated lines and will be available during an emergency.
Communications are discussed in section 4.7.5 of the licensee's Emergency Plan.
Interrogatories 6.
Describe in detail the expected actions that you would require to be taken by the shift supervisor in the course of an event which leads to declaration of a.
a site emergency, b.
a general emergency.
s 7.
Provide model scenarios for 6.
~
w
Response
Tables 20-23 of the licensee's Emergency Plan provide the licensee actions for each class of emergency. Model scenarios for the above are not available.
S S
-w
l AAMODT 4th Set Interrogatory 1 In view of the fact that plant emission of radioactive iodine will fall on corn and hay as well as pasture, and corn (the whole plant) and hay are the j
principle " stored feeds" on dairy and beef farms in southeastern Pennsylvania, 1
please explain:
a.
Why milk testing is carried out only when milk cows are on pasture?
(Note that stored feed is often used on a last in, first out basis.)
b.
Why milk testing is not done on nursing beef cows, horses and ewes, since calves, foals and lambs can also be injured by elevated thyroid exposures?
Response
N la.
Calculations indicate that the doses that could result are largest when cows feed on pasture rather than stored food.
The reason for this is that the radioactivity on stored feed generally decays significantly before the feed is used.
lb.
Although guidelines have not been established for desirable limits a
for radiation exposure to species other than man, it is generally agreed that the limits established for humans are conservative enough to assume protection to animals.
The "BEIR" Report concluded that the evidence to date indicates that no other living organisms are very much more radiosensitive than man.
l Therefore, limits placed on environmental releases to protect human beings are sufficient to protect animals as well.
t e
,y_.
AAMODT 4th Set Interrogatory 2:
In view of the fact that radioactive iodine depositions do not diminish even an order of magnitude for distances over 100 miles in the path of a well-defined plume, and such a plume can be confined to a 15* are:
Are you confident that proposed mointiroing procedures-accurately a.
preduct milk contamination?
b.
If so, why?
If so, state for a case such as the TMI-s accident, the expected c.
dose a child who consumes one quart per day of milk from an exposed herd nine miles from the plant for that period which will elapse before the child's parents are made aware that the milk is contaminated.
Please do not discuss an average child.
N,
Response
5 k' ell-defined plume as the one described here exist only for short periods of time relative to variation in release rates.
Because of the inherent natural variability of the weather and large variations in plume types and directions considerable smearing out of the released radioactivity around the plant occurs.
Hence, sector averaging methods are appropriate.
(a.b.)
Yes, because the monitoring program measures actual iodine milk concentrations directly, and is-not based on predictive methods.
(c) Specific calculations were not done for the distance of 9 miles.
However, samples of milk were taken from many farms and dairies throughout the accident period for the TMI vicinity.
The iodine concentrations in milk that were observed are listed on page 74 of a report by the Ad Hoc Interagency 2
Dose Assessment Group, " Population Dose and Health Impact of the Accident at l
the Three Mile Island Nuclear Station", May.1979, Report NUREG-0558.-
s
/
AAMODT 4th Set,
' Interrogatory 3:
According to NUREG-0558, the full body and thyroid dose to each individual in the 50-mile radius of the TMI-2 accident, was assumed to be the same, i.e.,
the dose was calculated by dividing the total emission by_the total number of 1 people within the 50-mile radius.
Do you consider this an adequate measure 1
of ' dose' to population?
If so, explain why.
a.
b.
Does it apply (to adequately protect the population and assess subse-quent events) in the event of a well-defined plume?
Was it devised to apply to radioactive releases of the magnitude of c.
the TMI-2 accident?
d.
Was it devised to apply to radioactive releases to be expected in N
" core-melt" accidents?
s
Response
a.
It is not clear what exactly is being referred to in NUREG-0558.
The individual dose given in NUREG-0558 was not determined by dividing the total emission by the total number of people within the 50-mile radius, as stated in the question.
It was determined based on readings on dosimeters in the field and on the meteorological conditions.
The total population dose was determined in several ways all of which involved a type-of summation over the dose popu-lation distribution.
b.
The dose calculations of NUREG-0558 were specific for the meteorological.
conditions which occurred during the accident.
The results of this calculational method would not be the same if some other meteorological. conditions existed like the one described in question 3b.
i i
-m
AAMODT 4th Set c.
Yes.
'the methods of NUREG-0558 were specific for the data collected during the accident.
d.
'!E x s
AANDT - 5th SET Interrogatories 1.
Does the f4RC have any policy regarding news releases?
,_ If so,' provide.
f
~
a.
1 2.
Does the NRC have any policy regarding the news releases of utilities?.
i a.
If so, provide.
I
Response
7 The NRC Staff has no formal policy regarding issuances of public announce-ments, either its own or licensees'.
i Interrogatory 3.
In NRC news releases, are the terms " routine releases" or "no radio-x.
active release above routine" or similar terminology used inter-t changeably with expression "no radioactivity released"?
a.
If yes, explain.
i
)
Response
No.
l Interrogatories 4-6 l
Objected to.
l i
l e
g-.-
. w m.
.,..nm.
i!
lpterrogatory 7.
In NUREG-0396, sheltering is recommended as an appropriate emergency acti6h in 50 mile EPZ.
Have you studied how sheltering can be ade-quately accomplished and the amount of protection afforded by various e
methods of shielding?
a.
If so's provide information.
4
Response
The Staff has not made a study about sheltering.
However, Sandia Laboratory and the U.S. Environmental Protection Agency have made such studies. The following reports by these groups are studies in protection afforded by various methods, which are referenced in NUREG-0654.
4 (1)
"Public Protection Strategies for Potential Nuclear Reactor Accidents '.
Sheltering Concepts with Existing Public and Private Structures" (SAND 77-1725).
(2) " Examination of Offsite Radiological Emergency Measures for Nuclear Reactor Accidents Involving Core Melt" (SAND-78-0454).
i (3)
" Protective Action Evaluation Part II, Evacuation and Sheltering as Protective Actions Against Nuclear Accidents Involving Gaseous Releases" (EPA 520/1-78-001B).
Copies of these documents will be placed in the local public document room.
Interrogatory 8.
What events at TMI-1 or measurements made of those events would constitute the basis or bases for emergency declaration for the 50 mile EPZ?
Response
The events or emergency action levels for declaring emergencies are discussed in section 4.4 of the licensee's Emergency Plan.
(
n
Interrogatory 9:
Why is I-131 considered an adequate predictor of presence and quantity of all the radioactive lodines?
a.
How is it inadequate?
~
b.
Was the concept of I-131 as a predictor checked for reliability in post TMI-2 milk sampling?
Response
a.
It is not necessarily considered an " adequate predictor" of all other radioactive iodines.
The reason why it is focused on is because it is the principal contributor to the thyroid dose.
Iodine-131 was not evaluated as a predictive tool for other iodines in milk regarding the IMI milk sampling program.
'N b.
No.
s i
l Interrogatory 10:
Have you made a study of the history of milk sampling data in the vicinity of any nuclear plant.
If so, provide study or studies.
l i
l i
4 1
4 k
4 c.
~ ~., --.,,, - -
+,.n.
e
l
Response
Milk sample monitoring program and results are routinely reviewed by the NRC Office of]Inspectio'n and Enforcement and are reviewed by the NRC Office of
,f Nuclear Reactor Regulation as they relate to licensing activities.
The results-of many of these reviews are documented in the case files and are available to the public.
Enclosed is a copy of a report cotopleted by the Idaho National Engineering Laboratory which analyzes. in detail the concentrations in milk and vegetation around the Quad Citie's Nuclear Power Station.
I_nterrogatory 11:
If study was not made per 10, provide raw data for measurement of I-131, strontium 89 and 90 for milk sampling of farms in Peach Bottom area for years N
before beginning of operation of plant until present.
(Request was made of'.
NRC Reg. 1 office more than four weeks ago for use in evaluation of proposed installation of dairying equipment on our-farms.
It has not been received to date.)
State where farm sampled is located in relation to plant; give reasons a.
why it was selected for sampling.
Response
Not applicable.
Interrogatory 12:
Provide raw data for milk sampling from 1974 until present for TMI area.
b.
Same as 11.a.
1
e
. 4
Response
Y The results of the milk sampling that has been done for TMI are contained in the annual operating reports for the station.
These reports are in the NRC Public Document Room.
s e
e e
l Interrogatory
- 13. How have the differences of nuclear emergency from other kinds of disasters been defined and evaluated in assessing public performance r
in a real nuclear disaster?
Response
The Staff has not made such an evaluation.
The Environmental Protection Agency has produced a report on the risks associated with the evacuation of the area surrounding a nuclear power plant.
This report is entitled *
" Evacuation Risks - An Evaluation" EPA-520/6-74-002. A copy of this document will be placed in the local public document room.
1 s
t I
1 l
...-,4 y--
. Interrogatory
- 14. _What effect will public relations
- efforts of utilities to gain acceptance of nuclear power have on willingness of public to evacuate during various stages of an emergency?
a.
Is the comparison (in public relations efforts) of radiation from TV sets, background radiation and X-rays with plant emissions'a legitimate means of utility advertising?
b.
Does it condition to complacency, therefore not assuring public participation in emergency conditions?
Response
- a. Objected to.
- b. It is the staff's judgment that (1) confidence and trust in the local response agencies, (2) an advance educational program relating to the hazards of radiation and (3) prior instructions on emergency actions, will provide assurance that proper protective actions will be taken by the public.
N, 1
S e
k e
e I
2 S
AAMODT - 6th SET 1
QUESTION:
1.
Provi3e test for licensing operators used prior to TMI-2 accident.
~
Provide for each control room position.
ANSWER:
A copy of the written examinations administered to operators and senior operators at TMI-2 are enclosed.
Several sets of examinations were administered at TMI-2.
QUESTION:
2.
Provide test planned to be used for licensing operators for restart of TMI-1.
ANSWER:
Objected to.
QUESTION:
N 3.
Indicate any changes from 1 to 2.
How do you evaluate these changes 4
in testing?
s ANSWER:
Cannot be answered at this time; see objection to No. 2.
QUESTION:
4.
Are the tests upgraded in basic engineering and physics of thermal hydraulics?
ANSWER:
The tests will be upgraded in the areas of thermal hydraulics. We believe i
that the present tests explore basic engineering and physics to the depth required for operators and senior operators.-
-l 4
r
-n--
, QUESTION:
5.
Provide'65mes and background '(education and experience) of individuals I
or ccmpanies who constructed these tests referred to in 1 and 2.-
ANSWER:
The resumes of individuals who have prepared tests for.TMI-2 are enclosed.
The names and backgrounds of persons of individuals who construct the test '
for the restart of TMI-I will be provided when known.
QUESTION:
6.
Were the services of any testing service used to construct these tests? -
ANSWER:
4 No.
QUESTION 3
7.
Were the tests constructed upon any established principles to optimize
~
reliability as a predictor of job performance?
i a.
If so, give information.
1 8.
What assurance do you have that the upgraded tests can reliably predict job pe rformance?
i ANSWER:
The tests were developed by persons who are experienced in operating nuclear facilities, and are based upon their. knowledge gained and engineering judgement.
The tests were constructed to cover the subjects enumerated in Sections 55.21 through 55.23 of 10 CFR Part 55, Operator Licenses. A copy of this Part is enclosed.
t Based upon these factors, the Staff has reasonable assurance that individuals who pass these examss can safely and competently run the facilities.
i k
. QUESTION:
9.
Provide the names and backgounds of the person or persons who will administer and grade these revised tests?
(
ANSWER:
These persons have not yet been determined.
QUESTION:
- 10. Provide the names and backgrounds of the person or persons who adminis-tered these tests and graded them prior to TMI-2 accident, if different from answer to 9.
ANSWER:
The nanes are the same as those provided in response to number 5.
QUESTION:
- 11. What grade on licensing tests will be needed to pass?
a.
How have these standards been altered since TMI-2 accident?
s ANSWER:
An iddividual will be requir~ed to re~ceive 80% overall and at least 70% in each
~
~~
category of the examination to pass.
a.
The previous standard required an individual to receive 70% overall to pass. There was no category grade requirement.
QUESTION:
- 12. What procedure will be followed for those who do not pass?
ANSWER:
Individuals who fail the examination will be inforned by letter. The letter will deny their application and inform them of the reasons they were denied (a listing of categories failed). These individuals nay submit a reapplication two months from the date of the denial letter. The reapplication will be reviewed to determine that retraining has taken place prior to administering a second examination.
l 4 )
QUESTION: -
- 13. At what intervals will there be relicensing?
a.
Will the same tests be used?
ANSWER:
Licenses expire two years after the date of issuance.
a.
No.
QUESTION:
- 14. What differences between new' tests for licensing and those replaced do you believe will reduce operator error?
i a.
Explain.
ANSWER:
's The new examinations will contain additional categories that address fluid flow, heat transfer and thermodynamics. Assuring that the operators have a good understanding of these subjects, including applicability to their facility will give us additional assurance that errors will be minimized.
In additioW,' we~~will" assure that the operators are fully familiar with the emergency procedures governing their action in the event the high pressure injection system is activated. Their understanding of these procedures will give us additional assurance regarding competent performance.
QUESTION:
- 15. Relate 14 to TMI-2 accident.
ANSWER:
Lack of a thorough. understanding of thermodynamics, fluid flow and heat transfer as related to the facility operation contributed to the THI-2 accident.
t 4
9
. QUESTION:
- 16. How do~you plan to provide for adequacy of operator performance to
" totally unanticipated situations" (p.104 Rogovin)?
ANSWER:
Training. programs are being modified so that operators will respond to parameter changes and what these may indicate.
Based on the analysis, they will respond so as to put the plants in the safest condition, rather than be event trained.
QUESTION:
- 17. Do you plan to introduce " stress" in testing for licensing of operators?
ANSWER:
We are considering initiating a study to determine if stress testing for licensing is necessary, as discussed in NUREG-0660, Action Plan.
- However, the NRC has not yet determined whether stress testing will be required.
ss.
QUESTION:
s
- 18. Under proposed redesign of control room, to how many variables must an operator respond as'a function of time a.
during normal operation.
b.
during shut-down operation.
c.
during start-up operation.
d.
in the first 10 minutes of replay of TMI-2 ?
ANSWER:
There is no requirement for the' ~ redesign of the TMI-l control room.
Some i
additional instrumentation will be required, such as direct reading of the PORV, a saturation meter for the reactor coolant system and auxiliary feed flow indication. All of these instruments are designed to assist the operator in diagnosing system behavior by direct reading rather than by inference, as f
was necessary during the TMI-2 accident.
a.
The Staff does not understand what you mean by " variables." In general terms, there are four parameters that can vary during operation: pressure, flows, temper-ature, and flux. These paramters must be monitored at times during normal oper-ation.
b.-d.
These same four parameters are variables for these conditions, r
i QUESTION:.{
3 19.
How would pre-TMI-2 accident control room at TMI-1 differ applying question 18.
ANSWER:
Not applicable, since no redesign of the control room is required.
QUESTION:
- 20. Do you test for visual acuity, color blindness and reaction time of operators and supervisors?
- a. At what intervals?
ANSWER:
Operators must submit a Certificate of Medical History and Examination as i
part of their application for a license and for each renewal therof. As indicated ~above, renewals are required every two years. The examination i
includes visual acuity, color blindness and motor coordination tests.
s Reaction times are not tested.
s i
b l
r n
l l
1 1
l l
e a
u.
.- i
Question 21 By what criteria has the suitability of 6-hour shifts for operators been c
determined?
Answer: The normal' shif t duration for utilities in the United States is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This is the standard, in use for many years, in I
industries that require around-the-clock coverage. We are I
unaware of any criteria or studies of the suitability of 6-hour shifts for operators, a.
Is this the practice in most plants?
Answer:
No. We are not aware of any operating plant that utilizes 6-hour shifts.
t
- 1) provide data where there are differences.
Answer: We are unaware of.any criteria or studies of the suitability of 8-hour shifts for operators.
b.
How does this compare with Navy practices?
Answer:
It is our understanding that for a ship underway the normal watch rotation is 6-hours on, 12-hours off.
There are many variations of this, depending on the number of " qualified" personnel available.
l a
4-
___m
It should be noted that during the 12-hour off period duties such as maintenance may be performed, unlike the commercial power plant operator who goes home during the off period.
c.
Have any studies been made on the effects of fatigue on operator performance?
Answer: Yes. Most of these studies were made to determine the effect on the operator when extra hours are worked beyond the normal 8-hour shift.
Included is a Working Paper by A. D. Swain, Sandia Laboratories,that summarizes the results of a brief literature search on the subject. Also, we are currently
's evaluating a proposal to perform a study of fatigue and how s
it affects performance.
T 9
-9
. QUESTION:
22.-- Are you planning to test operators on ability to cope with Class 9 l
scenarios in addition to those of the general classification of the TMI-2 accident? Provide details.
2
- ANSWER:
7 We have required utilities to incorporate instructions on the use of
(
(
i installed instrumentation to control or mitigate accidents in which the core is severely damaged in their training programs. We will assure the effectiveness of the training through our examining process.
i j
Although we have general guidance, we have not yet developed the details l
for such testing.
1 1
4 h
1 l
i I
eg l
i 1
I 1
P t
T i
1 i
,,--,,--wr-<r,vw-c---
---w,,.,.-.va,--
--.n, n,----
a..,.,.,.,, -,,,,, - - - - -. -,
---..,.,w-,
..~n,
~
- 1,0 -
4 23.
Do you believe that the man-machine interface suggested by the Essex Corp will improve operator performance?
I a.
How much do you believe it will reduce incidents?
Give basis.
i b.
Would it have prevented initiation of the TMI-2 accident?
c.
Would it have mitigated the errors subsequently in the TMI-2 accident?
d.
Explain answers to b and c.
Response
This interrogatory relates to a specific man-machine irterface s
claimed to have been recommended by Essex. However, Enex did ',
not suggest a man-machine interface.
Although Essex did iake certain findings in its report, it did not make a recommenda-tion regarding this matter. Accordingly, the Staff cannot respond to this interrogatory.
d I
e
- 1,1 -
24.
Had a-man-machine interface study ever been considered by you before the TMI-2 accident?
a.
When and for what reason?
Response
Yes. Operator-process communication was a topic discussed i
during a 1975 visit to Halden Reactor Project. See following memorandum, which is attached to this document:
" Trip Report on Technical Survey of European Applications of 1
+
Digital Computers to Nuclear Power Plants - May 9, 1975 to l
V. Stello, From L. Beltracchi."
The Staff also developed studies in this area. These studies s '
include:
" Preliminary Human Factors Analysis of of Zion Nuclear Poser r
Plant - February 1975 - A.D. Swain."
" Human Engineering of Nuclear Power Plant Control Rooms and Its Effects on Operator Performance, Aerospace Report No. ATR (2815)-1, February 1977."
Due to the length of these reports, copies are not included.
You may, however, request these documents if you desire a copy.
i e
5 l
i-I i
Question 25.
Is there any plant where number of incidents is significantly
- lower than the industry average?
Question 26.
Is there any plant where number of incidents attributable to human error is significantly lower than the industry average?
Answer Both questions ask if there is any plant where numbers of incidents are significantly lower than the industry average.
Since " incidents" was not defined, we have selected the number of reportable occurrences as being representative of the number of incidents.
While the number of occurrences reported reflects the number of incidents, full equivalence between these two is in doubt because different plants follow somewhat different reporting procedures.
Reportable occurrences are defined in each unit's Technical Specifications (which are part of the operating license). There are two types of reportable occurrences; those which must be reported to the fiRC promptly, because of their potential significance and other, less significant events, which may be reported to the fiRC in 30 days.
Each reportable occurrence is classified by the licensee into one of several cause categories.
The available categories s
are personnel error; design, manufacturing, construction / installation; N
external cause; defective procedures; component failure; other.
s We analyzed the selected data (prompt, 30 day and total) for all causes for Question 25.
We analyzed the selected data (prompt, 30 day and total) for events caused by personnel error for Question 26.
Because the statistical techniques employed to answer these questions are the same for both of.them,.the. following discourse serves to support our answers to both. Where delineation is required, the terminology of
_ Question 25 and Question 26 is employed.
The underlying assumption for these analyses is that the numbers of incidents occurring at each plant is a Poisson-distributed random variable.
fioreover, we use the data attributed to each unit, not the. data attributed to each plant (which may consist of one or more units).
We consider the problem in the following general form:
1.
There are k units to be studied.
2.
Let i be the index for the,i_th unit.
3.
Let x denote the number of occurrences of a specific k'ind j
occurring in tj years of operation of the ith unit.
4.
Let vi denote the true occurrence rate for the ith unit.
The exgected val,ue of xj is pjtj.
~
5.
Ldt'rj = xj/tg denote the estimate of the ith unit's true I
occurrence rate.
Problem:
Are the true rates of occurrence all equal to each other?
If not, identify those units whose rates are significantly lower than the average rate for all k units.
The test for equality of true rates is described by Moore [1966].
Identification of "significantly lower" rates is a bit more complicated.
It follows a method by Scheffe and described by Gibra [1973, p. 363].
For this study, the contrasts are made between each of the ri values and the average of the full set of k units in terms of the square root of ri.
This makes use of the well-known and recomended transfonnation of Poisson random variables which provides constant variance.
Answers to Question 25 and Question 26 are provided for 70 NRC-licensed power reactors in the U. S. whose operating lives included some portion of the time covered by the survey; i.e., those units whose lives overlap
\\
the inclusive period from January 1,1969 through December 31, 1979.
For the ith reactor, ti is the amount of overlapped time, with the date of " initial criticality" used to mark the beginning of a unit's life.
--The~ data are taken from NRC's Licensee Event Report file and are displayed in Attachment 1. The analyses were done separately for each of the categories displayed in Attachment 1.
A computer program was prepared to perform the computations required by the analysis described above; the program's outputs are given as Attachment 2.
(The numbers in parentheses indicate the pages in Attachment 2 which display the corresponding computer output.) The results of the analyses are discussed in the ~ sequel for each of the 6' categories.
Then these findings are summarized to respond to Question 25 and Question 26.
Catecory 1:
Prompt Reports, All Causes (1 - 3)
The hypothesis of equal occurrence rates is rejected at the 5% level of significance.
The estimated average for the industry is 13.6 occurrences per year.
The lowest rate for a unit occurred at San Onofre 1 with 2.1 occurrences per year during the 11 years of overlap with the 1/1/69 - 12/31/79 period.
San Onofre l's rate is statistically significantly less than the industry average, when the test is made at the'5% level of significance.
i i
. Other units whose rates are statistically significantly lower than the industry average are:
Unit Estimated Rate Haddam Neck 2.36 i
Yankee Rowe 1 4.64
/
_ Category 2:
Prompt Reports, Personnel Errors (4 - 6)
The hypothesis of equal occurrence rates is rejected at the 5% level of significance.
The estimated average for the industry is 2.66 occurrences per year.
The lowest rate for a unit occurred at Browns Ferry 3 with 0.15 occurrences per year for the 3.40 years of life.
Scheffe's method of multiple comparisons does not identify any units as being significantly smaller than the industry average --
but the method is known to be quite conservative in its declaration of significant contrasts, so that conclusion is not inconsistent with the rejection of equal occurrence rates.
Catecory 3:
30-Day Reports, All Causes (7 - 9)
The hypothesis of equal occurrence rates is rejected at the 5% level'of significance.
The estimated average for the industry is 21.58 occurrences per year.
The lowest rate for a unit occurred at San Onofre 1 with 2.73 occurrences per year during the 11 years of overlap with the 1/1/69 - 12/31/79 period.
San Onofre l's rate is statistically significantly less than the industry average, when the test is made at the 5% level of significance.
thny other units have significantly lower occurrence rates than the industry average.
They may be identified in the list in pages 8 and 9 of Attachmnt 2 by those units whose value in the column head by ZZ(J) are grqater than.'89.4 = 9.46.
(This critical value is derived from the Scheffe methodology using the 95th percentile of the chi-square distribution for (k - 1) = (70 - 1) = 69 degrees of freedom.)
Cateoory 4:
30-Day Reports, Personnel Errors (10 - 12)
The hypothesis of equal occurrence rates is rejected at the 5% level of significance.
I The estimated average for the industry is 3.41 occurrences per year.
The lowest rate for a unit occurred at San Onofre 1 with 0.46 occurrences per year during the 11 years of overlap with the 1/1/69 - 12/31/79 period.
. i Note:
See comments under Category 2; they apply.also to Category 4 analysis.
_ Category 5: Total Reports, All Causes (13 - 15)
The hypotijesis of equal occurrence rates is rejected at the 5% level of significance.
The estimated average for the industry is 35.20 occurrences per year.
The lowest rate for a unit occurred at San Onofre 1 with 4.82 occurrences per year during the 11 years of overlap with the 1/1/69 -
12/31/79 period.
San Onofre l's rate is statistically significantly less than the industry average, when the test'is made at the 5% level of significance.
Many other units have significantly lower occurrence rates than the industry average.
They inaj be identified in the list in page 14 and 15 of Attachment 2 by those units whose value in the column headed ZZ(J) are greater than 9.46.
Category 6:
Total Reports, Personnel Errors (16 - 18) y The hypothesis of equal occurrence rates is rejected at the 5%
level of significance.
The estimated average for the industry is 6.10 occurrences per year.
The lowest rate for a unit occurred at San Onofre ~1 with 0.64 occurrences per year during the 11 years of overlap with the 1/1/69 - 12/31/79 period.
San Onofre l's rate is statistically significantly less than the industry average, when the test is made of the-5% level of significance.
Scheffe's criteria ' reveal only one other unit whose annual occurrence rate is significantly less than the industry average:
Haddam Tieck with 0.91 occurrences per year.
Answers to Questions 25 and 26 The foregoing allows us to answer the questions with a scarcely-equivocal "yes" for 4 of the 6 categories of occurrences, especially for Category 5 (Total Reports, All Occurrences) and Category 6 (Total Reports, Personnel Errors).
San Onofre 1 is significantly lower than the industry average for Category 1 (Prompt Reports, All Causes), Category 3 (30-Day Reports,.
All Causes), Category 5 (Total Reports, All Causes), and Category 6 (Total Reports, Personnel Errors).
~
Some equivocation must be employed for Category 2 and Category 4, both J
pertaining to Personnel Errors. Although the, corresponding hypotheses
~
of equal occurrence rates is rejected, Scheffe's method does not clearly designate the units with the lowest rates -- Brown's Ferry 3 for Category 2 and San Onofre 1 for Category 4 -- as "significantly lower" than the industry average.
Other methods of discrimination are possible, but they require rore development and documentation effort than can be spent on this task at this time.
e b
e b
.~
REFERENCES _
Gibra, I. N.
(1973) _ Probability and Statistica.1 Inference for Scientists and Engineers, Pren,tice-Hall, Inc., Englewood Clif fs, New Jersey..
Moore,R.H(1966)
"A Likelihood Ratio Test for the Consistency of a f
1 Set of Count Rates," - Los Alamos Scientific Laboratory Preprint, LA-DC-7665.
o l
l 5
O e
0 I
a.
._m_.
~.
_ie.
Interrogatory 27.
Provide educational and experience credentials of personnel of Essex Corp.
Response
c Requested documents are attached.
J Interrogatory 28.
Provide background of Essex Corp. including year founded, number of i
jobs performed, for whom jobs were performed, whether results of human engineering was assessed and assessments, if any.
i i
Response
1 N
Requested documents are attached.
1 1
Interrogatory 1
- 29. What other human engineering corporations or services were considered in hiring Essex Corp.?
t
Response
The XYZYX Corporation was considered. The capabilities of other companies-were discussed by NRC staff with the resulting conclusion that few, if any, had acquired experience, knowledge or capability to understand reactor con-
~}
trol room operations to enable them to provide a timely response to NRC needs.
e M
e
~
, =. ~,
,m-i e
4.
Interrogatory
- 30. Why was Essex Corp. chosen?
Response'"
f The Essex Corporation was chosen on the basis that they employed two (2) former reactor operators; had accumulated valuable knowledge and experi-ence in performing human factors evaluations of three (3) reactor control rooms for the Rogovin Commission as part of the TMI-2 investigations; and were under contract to the tiRC at the time the control room review effort was to be initiated.
\\
I O
~ _.
1 QUt3T10N:
31.
Have you considered " mind-set" of control room and other personnel as a variable in their perfortance?
a.
If so, give your considerations.
f ANSWER:
4 4
Yes.
Training programs are being modified so that operators will respond to parameterchanges and what these may indicate.
Based on the analysis, they will respond so as to put the plant in the safest condition, rather than be event trained.
i QUESTION:
l 32.
What do you tell operators about their responsibility in protecting the health and safety of the public? Provide copy.
ANSWER:
The licenses enumerate the individual's responsibilities.
Copics of operator and senior operator licenses are enclosed.
I QUESTION:
'N d
33.
provide copy of information that you give operators (both written and oral) relative to possible hazards of nuclear power generation.
ANSWER:
l We do not provide operators with documents regarding the possible hazards of nuclear poser generation.
However, utility training programs do deal with the possible hazards of nuclear power generation.
1
.i f
s s
i i
t l
,,.-~ - -..-,
. i QUESTION:
- 34. Do you agree that the majority of licensed operators believe that nuclear power generation is very safe?
~
ANSWER:
f a
We have not conducted a survey to determine the operators' feelings regarding the relative safety of nuclear power generation.
QUESTION:
- 35. What information do you give operators about the effects of low-level radiation? Provide copy.
ANSWER:
We do not provide operators with documents regarding the effects of low-level radiation.
However, utility training programs do deal with this subject.
9
\\
P 9
b e
G l
k p.
j 1
l
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
METROPOLITAN EDIS0N COMP ANY, et al.
Docket No. 50-289 (Three Mile Island, Unit 1)
AFFIDAVIT OF PAUL F. COLLINS I, Paul F. Collins, being duly sworn, do depose and state:
1.
I am Chief, Operator Licensing Branch, in the Division of Project Management, Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Cocinission.
I am reponsible for the issuance of licenses to operators and 4
senior operators at reactor facilities, including Three Mile Island, Unit 1 i
Restart Program. -
2.
The answers to Marjorie M. Aamodt Interrogatories (6th Set) 1-20, 22, 31-35) were prepared by me.
I certify that the answers given are true and accurate to the best of nty knowledge.
/ 92 Paul F. {ollins Subscribed and sworn to before me thisSday of
~
') ad
/ 9 af o
_fLn.a A su4 iot(ry Public
/d W
A / /7 My Cocmission expires:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matt"er of f
METROPOLITAN EDIS0N COMPANY Docket No. 50-289 (Three Mile Island, Unit 1)
)
l AFFIDAVIT OF JAMES C. STONE I, James C. Stone, being duly sworn, do depose and state:
1, I am a Reactor operations Specialist in the Division of Reactor Operations Inspection, Office of Inspection and Enforcement of the United-States Nuclear Regulatory Commission.
2.
The answer to Aamodt's sixth set of interrogatories, Question 21, was prepared by me.
I certify that the answer given is true and accurate to the best of my knowledge.
/
ca/s f"ames C. Stone Subscribed and sworn to before me this 20 Yay of March 1980
(
fw "U
hotary Public My Commission expires:
July 1, 1982
+
+
-u..m4 y..-
,m-y--
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
In the Matter of
)
METROPOLITAN EDIS0N COMPANY, et al.
Docket No. 50-289 (Three Mile Island, Unit 1)
)
AFFIDAVIT OF LE0 BELTRACCHI I. Leo Beltracchi, being duly sworn, do depose and state:
1.
I am employed by the Instrumentation and Control Systems Branch, Division
~
1 of Systams Safety, Office of Nuclear Reactor P.egulation of the United States Nuclear Regulatory Commission.
i N
)
2.
The answers to AAMODT Interrogatories 6th SET 23 and 24 were prepared by me.
l l
I certify that the answers given are true and accurace to the best of my I
knowledge.
O s-j W/ M' 0'//<ds.
1 Leo <Beltracchi Subscribed and sworn to before me this f ej day of "fi/4 A1980.
0 x Lcl~.
t Notary Public My Commission Expires:
I. / /fd F f
/
w tw-e w-p.-
m w
- p+m
-+-w.e, u
w-
.m
.m,,..
9 awy
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Metropolitan Edison Company, et al.
Docket No. 50-289 (Three Mile Island, Unit 1)
)
AFFIDAVIT OF RICHARD A. HARTFIELD I, Richard A. Hartfield, being duly sworn, do depose and state:
1.
I am the Chief of the Licensee Operations Evaluation Branch of the Office of Management and Program Analysis of the United States Nuclear Regulatory Commission.
I am responsible for managing the collection and review of operating data from nuclear power plants
's and the issuance of special searches and reports based on that data.
2.---The answers to AAMODT Interrogatories 25 and 26 (Sixth Set) were prepared in part by me.
I certify that the answers given are true and accurate to the best of my knowledge.
W te S
Richard A. Hartfield U
Subscribed and sworn to 4L before me this 14 day of h I Mc_4_
l990
&os4s Q lwshu)
Notary Public My Commission expires:
td IN 3
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Metropolitan Edison Company, et al.
Docket No. 50-289
)
(Three Mile Island, Unit 1)
)
AFFIDAVIT OF DAVID PUBINSTEIN I, David Rubinstein, being duly sworn, do depose and state:
1.
I am a Mathematical Statistician in the Applied Statistics Branch of the Office of Management and Program Analysis of the United States Nuclear Regulatory Commission.
I am responsible for various projects involving statistics and I have participated in several studies of Licensee Event Report data.
5 2.
The answers to AAMODT Interrogatories 25 and 26 (Sixth Set) were prepared in part by me.
I certify that the answers given are true and accurate to the best of my knowledge.
s v
hNGI bt.,
n1 David Rubinstein Sub3cribed and sworn to before ne this /7 day of M L > c/
I9?O YV) 6A<A~
LAt] " D Notlry Publ1c- [
5, >j My Commission expires:
I I n
,---..e
F UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~~
In the Matter of
)
METROPOLITAN EDISON COMPANY, et al.
Docket No. 50-289 (Three Mile Island, Unit 1)
AFFIDAVIT OF RAYM0ND G. RAMIREZ I, Raymond G. Ramirez, being duly swarn, do depose and state:
r 1.
I am a reactor engineer of the Nuclear Regulatory Commission's Instrumentation and Control Systems Branch.
I am responsible for the review and evaluation of U '- -
the instrumentation and control systems of nuclear power generation stations.
\\
j 2.
The answers to AAMODT Interrogatory, 6th set, Questions 27 through 30 were s
prepared by me.
Questions 27 and 28 refer to reference docunents and 29 through 30 are written answers.
I certify that the answers given are true and accurate to the best of rqy knowledge.
i Raymehd G. Ramir'ez '
Q 1
Subscribed and sworn to before me this 4 / day of Wu-1980.
0 d uf:'
).
rjf Motarf?ublic
/
Ky Commission Expires:
At.d/f[ V
//
//
V si
UNITED STATES OF AMERICA.
NUCLEAR REGULATORY C0:*. MISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of METROPOLIk[NEDIS0NCOMPANY Docket No. 50-289 j
2 j
.l (Three Mile Island, Unit 1)
L AFFIDAVIT OF FRANK L. INGRAM
[
l i
I, Frank L. Ingram, being duly sworn, do depose and state:
1.
I a'm the Assistant to the Director, Office of Public Affairs of the United States Nuclear Regulatory Commission.
2.
The answer to Aamodt's Third set of interrogatories, number 4, and the Fifth set, numbers 1-3, were prepared by me.
I certify that the N
answers given are true and accurate to the best of my knowledge..,
I 1 4-% f G.
N,
% g. 1.'q.3 Frank L. Ingram l
1 Subscribed and sworn to before me this )s A day of March, 1980 i
~ ~
1.4 i.
d e, j
) )l A 4
Notary Public /
My Commission expires':
ai n, I '; $ ~4 d
,, /
J t
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 8EFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, g al.
)
Docket No. 50-289
)
(Three Mile Island, Unit 1)
)
AFFIDAVIT OF WALTER J. PASCIAK
-I, Walter Pasciak, being duly sworn, do depose and state:
1.
I am an Environmental Scientist in the Division of Site Safety and-Environmental Analysis, Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission.
I am responsible for reviewing radiological environmental matters of assigned nuclear I
power plants, including Three Mile Island, Unit 1 Restart Program.
N 2.
The answers to the Aamodt Interrogatories 1-1, 1-2, 1-3, 1-4, 4-l'a, 4-lb, 4-2, 4-3, 5-9,.5-10, and 5-ll..were prepared by me.
I certify that the answers given are true and accurate to the best of r
my knowledge, f
f
$El (L1(A_(V 'L -
, Walter Pasciak Subscribed and sworn to
~~ -
before me this day of llH a-wt,- -, / 'i f u i
AA Y' I.
Notary Public 0 l[ /< // h V My Comnission expires:
s 1
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDIS0N COMPANY, et al.
)
Docket No. 50-289 (Three Mile Island, Unit 1)
AFFIDAVIT OF JACK R0E I, Jack Roe, being duly sworn, do depose and state:
1.
I am a Emergency Planning Analyst, Office of Nuclear Reactor Regulation t
of the United States Nuclear Regulatory Commission.
I am responsible for reviewing the emergency planning of assigned nuclear power plants, \\
including Three Mile Island, Unit 1 Restart Program.
s 2.
The answers to Sholly Interrogatories08-011, 08-012,08-013, 08-014,08-015 and 08-016; Aamodt Interrogatories (3rd Set) 1-3, 5-7; Aamodt Interrogatories (5th Set) 7, 8,13,14 wtre prepared by me.
I certify that the answers given are true and accurate to the best of my knowledge.
Jack W. Roe I
Subscribed and sworn to before me this ' ' day of t_,h Mur
/ ' LED.
Y k/; 12 t $[ 9 Nota fy' Public
'(; 6* IfSV Y
tty Commission expires:
(^
(
e UN11 ED STAT ES OF /JH R ICA NUCl. EAR REGULA10hY CO:e:lSS 10N
.EEFO.R_E Tile, AT@!!C SAFEiY AND. LlChSS_ING BOARD _
In the Mattef of
)
)
~
MElEOPOLITAN EDISON COMPANY, ET AL.
)
Docket No. 50-289
)
(Thrce Mile Island Nuclear Statfon,
)
raft 1)
)
C,F3rIr1CATE _Or. SERVI _CF I hereby certify that copies of (1) "!;RC STAFF RESP 0i!SE TO CEA SEC0!;D SUPPLE-cit TO 11S IllTERROGATORIES T0 I;RC STAFF", and (2) "rRC STAFF RESPONSE TO INTERVE!!OR AAMODT I!!IERROGATORIES, SETS OfiE Af;D THREE THROUGH SIX" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through J mosit in the fluclear Regulatory Comaission's internal mail system, this 1st day of April, 1980, except that a copy of the above was served on Ms. Marjorie Aamodt on 14 arch 31, 1980:
Ivan W.
Smi t h, Esq.*
Mr. Steven C. Sholly
'.te ic fafety and Licensing Board 304 South Marlet Street U.S. Nuclear Fogulatory Comnit sion Mechan icsburg, PA 17055 P shington, DC 20555 Mr. Timnas Cerusky Dr. Walter H. Jordan Eureau of Radiation Protect'en E81 W.
Outer Drive Departmcnt of Environncntal Oak Ridge, TN 37830 Resources P.O. Box 2063 Dr. Linda W.
Little l?arrisburg, PA 17120 5J00 H<reitage Drive Kaleigh, NC 27612 Mr. Marvin I. Lewis 6504 Bradford Terrace George F. Trowbridge, Esq.
Philadelphia, PA 19149 S'aw, Pittcan, Potts & Trowbridge 1E00 M Street, N.W.
Met ropolitan Edison Cox.pany W thington, DC 20006 ATTN:
J.G. Herbein, Vice President Farin W.
Carter, Esq.
P.O.
Box 542 535 Decutive House Reading, PA 19603 P.O.
Sex 2357 F trisburg, PA 17120 Ms. Jane Lee R.D.
f3, Box 3521 able Mark Cohen Et t ers, PA 17319 m
512 E-3 Main Capit al Building Earrisburg, PA 17120 Senator Allen R. Carter, Chairman Joint Legislative Cer.mittee on Uniter W. Cohen, Consuter Advocate Energy
<t tnt of Justice Fest Office Eox 142 f*ra-berry Spare, 14th Floor Suite 513 Senate Grecsette Failding Earrisburg, PA 17127 Columbia, SC 29202 i
~
I i
i 4
Holly S. Keck John f.evin. Esq.
Anti-Nuclear Group Representing PA Public Utilities Consission York Box 3265 245 W.. Philadelphia' Street Harrisburg, PA 17120 York, PA 17404 Jordan D. Cunningham, Eaq.
John E. Minnich, Chairman Pox, Parr and Cunningham 4
j Dauphin Co. Board of Commissioners 2320 North 2nd Street Pauphin County Courthouse Harrisburg, PA 17110 Prant and ::arket $treets 1
4 Harrisburg, PA 17101 Theodore A. Adler, Esq.
Widoff, Ecager, Sellowitz 6'Adler i
Robert Q. Follard P. O.,B0x 1547 l
l 009 Montpelier Street Harrisburg, PA 17105 I
Ea1timore, MD 21218 Ms. Ellyn R. Weiss E
i-Chauncey Kepford Sheldon, Harraon, Roisn.an & Weiss 4
Judith H. Johnsrud 1725 I Street, N.W.
Environ. ental Coalition on Suite 506
.';ucl ear Pcuer Washington, DC 20006 i
433 Orlando Avenue State College, PA 16801 Atomic Safety and Licensing Board i
Panel
- N Ms. Frieda Eerryhill, Chairman U.S. Nuclear Regulatory Commission Coalition for Nuclear Power Plant Washington, DC 20555 s
}
Postpon ment 4
2610 Grendon Drive Atomic Safety and Licensing Appeal
{
Wilmington, DE 19808 Panel (5)*
l U.S. Nuclear Regulatory Conmission Ms. Karen Sheldon Washington, DC 20555 l
Sheldon, Harmon, Roisman & Weiss i
l 1725 I Street, N.W.
Docketing and Service Section (7)*
i Suite 506 Office of the Secretary l
Washington, DC 20006 U.S. Nuclear Regulatory Commission Washington, DC 20555 Ms. Marjorie M. Aamodt 1
R.D. #5 l
Coatesville, PA 19320 l.
l.
i, k"->vA/ 5
-:. cm r Daniel T.
Swanson Counsel for NRC Staff i
1 D " ]O @h I
b M s h) WT @ k,
1 din i
2