ML19309C803
| ML19309C803 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1980 |
| From: | Zahler R METROPOLITAN EDISON CO. |
| To: | ANTI-NUCLEAR GROUP REPRESENTING YORK |
| Shared Package | |
| ML19309C800 | List: |
| References | |
| NUDOCS 8004090283 | |
| Download: ML19309C803 (13) | |
Text
O March 17, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S RESPONSE TO INTERROGATORIES (FIRST SET) FROM INTERVENOR ANGRY INTERROGATORY NO. 1 Identify by name and location all gaseous and liquid effluent filtration devices which will be operational at the time of TMI-l's restart.
(a)
State the filtration capacity of each such device in terms of radionuclide(s), concentration of ef-fluent, and saturation levels.
(b)
Identify each case in which the filtration capa-city of equivalent devices at TMI-2 was exceeded during the March, 1979 accident.
For each such case specify the amount by which such capacity was estimated to have been exceeded, and the duration of the inadequate filtration.
(c)
State the basis for the Licensee's belief that the devices listed under Interrogatory No. 1 will provide filtration capacity adequate to protect public health and safety.
(d)
What percentage of the total fission product inventory of the TMI-l reactor core, assuming total release into effluent pathways, would such capacity be able to prevent reaching offsite areas?
Provide breakdown by radio-isotope.
(e)
What percentage of the fission product releases estimated in the following accident scenarios from WASH-1400 would such capacity be able to prevent reaching offsite areas (provide break-down by radio-isotope):
8 00409ON
(1)
PWR 5 (2)
PWR 4 (3)
PWR 2
RESPONSE
(a)
Information on the capacity of the gaseous and liquid effluent filtration devices is given in the TMI-l FSAR sections 5.6, 9.8, 11.2 and 11.4, and in TMI-l Restart Report Section 7.
m (b)
To the licensee's knowledge the design filtration capacity of equivalent devices at TMI-2 was not ex-4 l
ceeded during the March 1979 accident.
The degraded performance of the TMI-2 charcoal' filters in the
~
Auxiliary Building Air Ventilation System is believed to have been caused by extensive air flow through-the 1
filters prior to the accident, coupled with lack of i
periodic surveillance tests, which were not required at TMI-2.
This situation will be avoided at TMI-l by the surveillance program described in Section 7.3 of the Restart Report.
This provides additional assur-I ance that the TMI-l filtration devices have suffi-i j
cient capacity for design basis events.
(c)
Analysis which demonstrated that the devices will 1
provide filtration capacity adequate to protect public health and safety is provided in the TMI-l FSAR.
(d)
Licensee has not performed the studies required to answer this question.
The extent to which Licensee has analyzed source terms and filtration capabilities
~
=
. is described in the TMI-l FSAR.
(e)
Licensee has not performed the studies required to
~
answer this~ question.
INTERROGATORY NO. 2 Identify the measures the Licensee has taken in response to the criticisms of reactor control room design found in NUREG-0560 (pp. 8-11, 8-12) and in the report of the President's Commission on the Accident at TMI (p. 29: # 8 (b) (1) and (ii) and p.
72: #1).
(a)
What is the basis for the Licensee's belief that the present TMI-1 control room design is adequate to assure safe operation of the facility.
g
RESPONSE
Licensee is installing additional instrumentation in the control room as described in the Restart Report.
For example, instrumentation has been provided to ensure'that the operator has a direct indication of parameters such as pressurizer relief 1
valve position and the margin to saturation in the reactor coolant system.
Operators have been trained to monitor appropriate informa-tion and not to rely upon any one instrument when redundant or di-verse sources of information are available.
In addition Licensee has instigated a long-range review-of the TMI-1 control room from a human factors engineering viewpoint.
This review will consider the location of controls and indicators, the number and types of alarm annunciators and will specifically check the ability of the operators to carry out required actions for plant conditions.
INTERROGATORY NO. 3 Identify the provisions in the Licensee's Emergency Plan which either singularly or collectively are intended to prevent damage to property such as livestock in the area surrounding the plant site.
Explain how each contributes to_the achievement of this goal.
RESPONSE
Licensee's Emergency Plan establishes a. system to organize and direct Licensee's resources under abnormal conditions to:
(1) provide assessment and control of plant systems to minimize radioactive releases to the environ-ment; and (2) provide information to state and local agencies in a timely manner so that they will be able to make appropriate decisions and take protective actions, if necessary, to protect the public health and safety and to minimize damage to property.
The State Emergency Plan will have a section specifically dealing with agriculture, including appropriate protective actions for livestock.
INTERROGATORY NO. 4 Explain the difference between a " major radiation emergency drill" (EP S 4. 8.1. 2 (5) (a) ) and a " joint exercise radiation emergency drill" (EP S 4. 8.1. 2 (5) (b) (1) ).
(a)
State whether either or both will be performed before restart.
l l
(b)
If a " joint exercise" is not so scheduled, give reason.
RESPONSE
The difference between a " major radiation emergency drill" l
and a " joint exercise radiation emergency drill" is the level of participation of federal, state, and local entities.
In the-former, the federal agencies would not participate and the state's
. participation is limited to a communications interface, while in the latter, the federal, state, and selected local organizations will participate in the drill.
Recent NRC guidance in NUREG-0654, which is under evaluation, may require a change in these defini-tions.
(a)
Exercises will be run prior to restart which will test the emergency preparedness of Licensee, state, and local organizations.
(b)
A joint exercise, including federal participation, is not required prior to restart.
INTERROGATORY NO. 5 NUREG-0560, at p. 4-5, refers to a study performed by the Human Resources Research Organization which documents the poor perform-ance of trained personnel under emergency conditions.
In light of this study what is the basis for the Licensee's belief that persons with emergency response responsibilities will in fact dis-charge such responsibilities under the conditions of a nuclear accident which results in atmospheric releases.
RESPONSE
The referenced section of NUREG-0560 addresses the response of operator personnel.
The study cited by NUREG-0560 involved Army personnel being realistically exposed to incoming mortar fire.
The results of this study are summarized in NUREG-0560 as follows:
"As many as one third of new recruits fled in panic, rather than l
perform the assigned task that would have resulted in cessation of the mortar attack."
By comparison, TMI operators receive extensive training.
These training sessions simulate equipment malfunctions and acci-dent scenarios and provide the operators with the opportunity to function in a " stress" situation.
During the TMI-2 accident there was no panic.
Thus, it is not anticipated that control.
. room operators would fenction like "new" Army recruits.
In addi-tion, fleeing TMI would not be expected since the control building
~
is designed specifically to remain habitabl'e~throughout an'emer-gency, including those with radioactive releases.
Personnel required to be onsite are housed in the control building.
These personnel are aware that they are in a specially designed l
building to ensure their safety during an emergency so that they can take corrective actions to improve plant conditions.
Thus, the
" fleeing" observed during the Army study is not likely to occur at e
TMI.
INTERROGATORY NO. 6 Identify each step that must be taken from the time an offsite-radiation monitoring survey team is dispatched to the time the findings of such a monitoring effort are made available for dose assessment calculations.
(a)
How much time is required for the above-described ~
proceas to take place?
(b)
How would the answer to #6(a) be affected by the installation of offsite monitoring devices that could be remotely read onsite?
(c)
Explain the basis for the Licensee's belief that offsite monitoring devices that cannot be re-motely read onsite provide adequate accident assessment capability.
RESPONSE
I l
The steps taken by an offsite radiological monitoring survey team from the time it is dispatched are:
(1)
Proceed to Processing Center and pick up emergency kits and radio; (2)
Inventory and operationally check the instruments i
in the kit; (3)
Establish radio communications with the Operations Support Center;
. (4)
Receive directions and proceed to vehicle; (5)
Proceed in vehicle to monitoring point.
Obtain beta / gamma reading and call it in to the Radio-logical Assessment Coordinator.
(a)
The time for the above-described process to take place is about one-half tour.
(b)
Monitoring devices that could be remotely read onsite would provide real time readout of offsite radiation levels.
(c)
Licenseo does not believe that offsite monitoring devices that cannot be remotely read onsite provide adequate accident assessment capability.
Rather, during an emergency, Licensee would rely on procedures which estimate the projected offsite dose and on offsite monitoring teams to provide a rapid accident assessment capability.
Offsite monitoring devices (without-a capability for remote readout) provide historical data and inte-grated doses which are used for overall accident assessment.
INTERROGATORY NO. 7 How many " Radiological Analysis Support Engineers" will be onsite at any given time:
(a)
What is their-training and background in the area of radiological r.asessment relative to that of the
" Group Leader - Health Physics / Chemistry Support and his staffd identified as part of the Offsite Emergency Support Organization.
(b)
What capability does the offsite Health Physics /
Chemistry Support group add that is not already present onsite?
(c)
What is the potential for erroneous dose projections and/or protective action recommendations prior to mobilization of offsite Health Physics / Chemistry Support personnel?
Explain in detail.
i RESPONSE
" Radiological Analysis Support Engineers" as such, are in the call-up duty section, ar.1 are not necessarily onsite at any given time.
This function is performed initially by either the shift supervisor or the shift 'oreman, both of whom are fully qualified to perform dose assessment calculations and are on i
shift.
(a)
The training of the Radiological Analysis Support Engineers is specifically directed toward the cal-culation of liquid and gaseous effluents leaving the site.
These calculations are based on para-meters measured by inplant instrumentation.
The l
Group Leader Health Physics / Chemistry Support is trained to the same level as the Support Engineers for calculating liquid and gaseous releases from the plant and in addition is trained in onsite and' offsite radiological and environmental monitoring, post accident inplant sampling, the handling of radiation overexposure and centaminated injuries, l
and personnel / vehicle monitoring and. decontamination.
(b)
The offsite Health Physics /Chemiatry Support group pro-l vides environmental assessment support for the-onsite emergency organization.
In this manner they provide
~
assistance offsite so thatithe onsite personnel can-l
' direct their immediate attention to their onsite
. responsibilities.
. (c)
The potential for erroneous dose projections and/or protective action recommendations is not affected by mobilization of offsite personnel.
INTERROGATORY NO. 8 Identify each of the " radiological and meteorological instrumenta-tion readings" (EP S 4.6.2.3 (3)) that is required for dose assess-ment.
(a)
What is the time required for the gathering of this information?
e (b)
Identify each step that must be taken to convert such information into a dose assessment /projectior..
(c)
What is the time required for such conversion process.
(d)
How would the answer to #8 (c) be affected by the installation of an Atmospheric Release Advisory Capability system (ARAC) ?
(e)
What information additional to that generated by -
the process described in answers to #8-8(c) would ARAC provide?
(f)
Explain the basis for the Licensee's belief that an ARAC system is not necessary for adequate dose assessment / projection capability.
RESPONSE
In order to estimate projected doses, radiological readings are required from RMA-8, which monitors effluents from the auxil-lary and fuel handling building, and from RMA-9, which monitors the reactor building purge exhaust.
The required meteorological readings are wind speed, wind direction and wind range (fluctua-tions) or vertical temperature differences.
(a)
This information is continuously recorded on strip chart recorders in the control room.
These re-corders can be read in less than five minutes.
. (b)
Health Physics Procedure 1670.4 is utilized to v
project offsite doses during an emergency.
This procedure includes check-off sheets which are used by plant operators to make the dose assess-ment.
In the procedure meteorological data and precomputed factors are used to determine atmos-pheric dispersion values.
These precomputed factors are developed to assure conservative, e
i.e.,
bounding, estimates for any release.
The resulting dispersion values are then multiplied by the releases from the radiation monitors to determine dose rates.
(c)
The total time for this calculation ir, less than 10 minutes.
(d)
Licensee is not presently familiar with the operating characteristics of the ARAC system.
In particular, it is not understood how or if plant specific inputs would be used in the ARAC system.
However, it is doubtful that this system could provide dose esti-mates in much less than 10 minutes.
(e)
Licensee is not familiar with the information that.
ARAC would provide.
Licensee's present procedures provide dose estimates in the plume path to a distance of about 10 miles.
(f). Licensee's present procedures result in rapid assessment of doses for a full spectrum of acci-dent situations.
. t INTERROGATORY NO. 9 State whether an ARAC system was placed into operation at Three Mile Island during the accident.
t (a)
Who made the decision to install this system and l
what was the basis for such decision?
(b)
What decisions were made on the basis of informa-tion provided by the ARAC system?
Could such in-formation have been generated in its (ARAC) absence?
RESPONSE
An ARAC system was never installed at Three Mile Island dur-ing the accident.
It is Licensee's understanding that the results of ARAC calculations were available to personnel stationed at the Capital City Airport.
(a)
Licensee has no direct knowledge with respect to this matter, but assumes that the decision to provide ARAC calculations at the airport was made by one of the government agencies respond-ing to the emergency.
(b)
Licensee is not aware of any decisions made on the basis of ARAC results.
All dose informa-tion necessary for responding to the emergency was determined using plant procedures and was confirmed by the offsite radiological monitoring teams.
INTERROGATORY NO. 10 Does'the Licensee agree with the statement in NUREG-0475, p.
10 that "the calculation of doses to individuals at specific locations near the site are best carried out using environmental measurement data obtained at these locations."
If no, explain.
If yes, ex-plain how this principle is-incorporated into Licensee's dose assessment procedures.
4
4
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12 -
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RESPONSE
Licensee agrees with the referenced statement.
It isifor this reason that Licensee uses offsite radiation monitoring teams f
to confirm the results projected by computational techniques.
Similarly, Licensee relies on its offsite TLD monitoring program to provide after the fact assessment of dose.
Since the accident the number of TLD monitoring locatiores has been increased to im-prove this monitoring capability.
See also Licensee's responses to Sholly Interrogatory (First Set) Nos,04-001, 04-005 and 09-001.
INTERROGATORY NO. 11 What is the time required for the evacuation of each of the seven-
" hospitals located within a 10 mile radius of TMI" as listed in Table 3 of Licensee's Emergency Plan.
Explain fully the reasons for the time given in each case.
RESPONSE
Licensee's knowledge on the time for evacuation of hospitals is derived from estimates made by the Commonwealth of Pennsylvania.
Such information is set forth in a February 4, 1980 letter to the a
NRC, a copy of which is being placed in Licensee's Discovery Read-4 1
ing Room.
INTERROGATORY NO. 12 L'xplain how the estimates provided by Licensee in answer to UCS Iaterrogatory No. 171 would be affected by each of the following conditions:
(a)
Inclement weather (b)
Rush-hour traffic congestion (c)
Traffic accidents
..,, RESPONSE Because Licensee has objected to UCS Interrogatory No. 171, no response to that inquiry has been provided.
Licensee's esti-mates on evacuation times are based on information from the Commonwealth of Pennsylvania.
The information requested in (a),
(b) and (c) of this interrogatory has been provided in the Common-wealth of Pennsylvania's response to ANGRY Interrogatory (First Set) No. 16, Part b.
INTERROGATORY NO. 13 Identify all institutions other than hospitals containing non-ambulatory residents, such as prisons or nursing homes, within a 10 mile radius of TMI.
RESPONSE
All information in the possession of Licensee respohsive to this interrogatory is set forth in Licensee's Emergency Plah.
The Commonwealth of Pennsylvania is responsible for securing this in-formation.
INTERROGATORY NO. 14 Identify all documents and studies relied upon by the Licensee in answering the foregoing interrogatories.
RESPONSE
TDR-TMI-ll6 entitled " Assessment of Offsite Radiation Doses From the Three Mile _ Island Unit 2 Accident".
February 4, 1900 letter from Herbein (Met Ed) to Grimes (NRC).
Respectfully submitted, SHAW, PIT, MAN, POTTS & TROWBRIDGE
/
By:
Robert Zahler r.
Dated:
March 17, 1980