ML19312D694

Response to Sc Sholly 800117 First Set of Interrogatories. Includes Info Re Containment Isolation Sys & Conditions Defeating ECCS by Reducing Flow Rate or Turning Off Sys. W/Affidavits & Prof Qualifications

ML19312D694
Person / Time
Site:	Salem, Crane
Issue date:	02/29/1980
From:	Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Sholly S AFFILIATION NOT ASSIGNED
References
NUDOCS 8003250202
Download: ML19312D694 (48)

Text

{{#Wiki_filter:5 "Y ::., UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the' Matter of ) ) . METROPOLITAN EDIS0N COMPANY Docket No. 50-289 (Three Mile Island, Unit 1) ) NRC STAFF RESPONSE T0 INTERVENOR STEVEN C. SH0LLY FIRST SET OF INTERR0GATORIES Pursuant to 10 C.F.R. 52.720 and 10 C.F.R. 12.744, the NRC Staff has responded to Steven C. Sholly's Interrogatories to the NRC Staff dated January 17, 1980. l l-Each interrogatory is restated and a response provided. Where appropriate, the NRC Staff has invoked that portion of the Commission's Order of August 9,1979 (Slip Ojl. at 11) which allows as an adequate response to a discovery request a 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 i-the individuals who prepared the responses and verifying them. I l l ~8003250gog

c3 -lN ;- Question 1-1-- Will, Unit I at TMI be required to confor;a with Standard' Review ~ ' Plan Section 6.2.4, " Containment Isolation System" prior to restart? If not.why not?-

Response

The Three Mile Island, Unit 1 (TMI-1) plant was ' designed and constructed prior to the issuance of the Standard Review Plan (SRP). Therefore, the ^ TMI-l licensee will not be required to meet all the provisions of SRP -Section 6'2.'4, " Containment Isolation System." The staff will require, ~ however, that the TMI-l licensee satisfy the recommendations in NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations." Item 2.1.4, " Containment Isolation Provisions for PWRs and BWRs," of NUREG-0578 discusses the isolation requirements that TMI-1 should conform to prior to restart. A clarification of these requirements is included in H. R. Denton's October 30, 1979 letter, " Discussion of Lessons Learned Short Term Requirements." We find the degree to which TMI-l conforms to SRP 6.2.4 acceptable. 4 l l i )

' n w, _u -Question-1-2 Does the Staff consider the containment isolation system at TMI-l to be 'in conformance.with GDC 16, 50 and -54? Explain why or why not. . Response The Staff ~ considers TMI-l to be in conformance with GDC-16 (Containment . Design),50(ContainmentDesignBasis)and54-(PipingSystemsPenetrating Containment). The basis for this conclusion can be fou7d 'in Section 6.2 of the Staff's Safety Evaluation Report for TMI-1, dated July 11, 1973. 1-i f e i 4 ) e b + q 1-a-y- c-- g g n-- --y3- ---y a y

i s. .3: v Question 1-3

Islit the' Staff's position that the containment isolation system at THI-1. should be backfitted to provide for. automatic isolation

~ on diverse _ signals? If not, why not? 1 -Res'ponse ~ The. Staff-will. require. the TMI-l containment isolation system to-include diverse containment. isolation signals that satisfy' safety-grade requirements prior to restart. a l: J. r g p# l I-

y y _uestion 1-4 Q Has Staff estimated the quantity of radiation which was released to the environment as a direct result of failure of the Unit 2 containment.to isolate and prevent the pumping of the reactor building sump to the auxiliary building? If so, provide this data. If not, will Staff provide such an estimation in testimony? _ Response It 'is necessary to comment on the wording of this question. The containment sump pump was ' designed to pump water in the containment sump to the auxiliary building. Most of the radioactivity released resulted from letdown 'line leakage in the auxiliary building and was not a result of failure of containment isolation, as implied in the question. The staff estimated the radioactivity that was released to be about 13 million curies of Xe-133 (see NRC memorandum from Lake Barrett to-Distribution, April 12, 1979, " Preliminary Estimates of Radioactivity Releases from Three Mile Island" which can be found in the local public document rooms) and about 14 curies of I-131 (see NRC memorandum from Lake Barrett noted above and NRC memorandum from R. C. DeYoung to W. Kreger, October 3,.1979, " Calculated Offsite . Iodine-131 Air Co'ncentrations from Three Mile Island which can also be found in the local public document room). These isotopes represent most . of the radiation that was release 1. Ad Hoc Interagency Dose Assessment Group, 'May,1979., " Population Dose and the Health Impact of the Accident at Three 4 Mile Island Nuclear Station", NUREG-0558, a copy of which is being sent to all intervenors in this proceeding. c a

- w Question 2-1 NUREG-0578 at page A-7 comments, with regard to the PORV in the pressurizer at TMI-2, "It is not clear whether these past instances of improper operation resulted from inadequate quali-fication of the valve or from a basic unreliability of the valve design." Doest Staff now know which of these alternatives is -the case? If so, which.one? Rgsponse An update.on this subject can be found in-NUREG-0565, Section 2.1. A copy of this document is being'sent to all Intervenors in this proceeding. Question 2-2 Has Staff received from the Licensee details concerning the qualification testing program for the pressurizer PORV, conduct of which is required by a recommendation from the Lessons Learned Task Force? If so, identify-documents relating to this . ma tter. Iffnot, will this qualification testing program be required to be complete prior to restart? If not, why not?

Response

A response will be provided by March 17, 1980. c. L e

4- ).

Question 3-1

.Under what conditions would Staff consider it appropriate for reactor operators to defeat the emergency core cooling system at Unit 1 by either reducing flow rate or turning off the system? - Response The Staff considers it appropriate to terminate or override the automatic actuation of High Pressure Injection (HPI) if the following conditions exist:

1. ~ The Low Pressure Injection System is in operation and flowing at a rate in excess of 1000 gpm in each line and the situation has been stable for 20 minutes; or

2.. All hot and cold leg temperatures are at least 50 F below the saturation temperature for the existing RCS Pressure and the action is necessary to prevent the indicated pressurizer level from going off-scale high. The degree of subcooling beyond 50 F and the length of time HPI is in operation shall be limited by the pressure / temperature considerations for the vessel integrity.

If 50*F subcooling cannot be maintained, HPI shall be reactivated. L These conditions are consistent with the criteria established for Unit 1 by ' Babcock and Wilcox in the Small Break Operating Guidelines dated November, 1979. [' -A copy oflthese guidelines is contained in Amendment 12 to the Licensee's L . Restart report. ~.

w . Question 3-2 Has Staff estimated the maximum pressure which Unit l's reactor ' containment will withstand before failure? If so, provide this data. If provided,.is.this pressure greater than, equal to, or less than the pressure provided'by the detonation of hydrogen gas which would result from a metal-water reaction due to a reaction of 65% of the metal in the core?'

Response

.The flRC Staff has not estimated the maximum pressure which Unit 1 reactor containment will withstand before failure. Question 3-3 Has Staff reviewed Licensee's procedures which govern the use of the ECCS at Unit l? If so, has Staff found that the revised pro-cedures will prevent defeat of the ECCS under conditions where such-defeat in the core becoming uncovered? Specify the procedures which were reviewed.

Response

The Staff has reviewed emergency procedure 1202-6, " Loss of Reactor Coolant / . Reactor Coolant Pressure," dated 1/14/80, which has been revised by the licensee to provide operator instruction on the use of the ECCS during a LOCA. This procedure includes the criteria noted in the response to Question 3-1 for the termination or override of HPI. Hence, emergency procedure 1202-6 has been revised to prevent defeat of the ECCS under conditions where such defeat could result in.the core becoming uncovered. In addition, the procedures listed below were reviewed to ensure reference uto 1202-6 was made under conditions which could indicate a LOCA: 1202 - 4 Reactor. Trip 1202 - S' OTSG Tube Rupture-1202 - 26 Loss of Feedwater 1202 -:29~ Pressurizer Systems Failure ~

~ .. z,, y Mr . Question 3-4 j Isjit Staff's position that Unit-1, complies with GDC 35 with regard {; Lto. metal-water reactions _ following an LOCA? Explain your answer.

Response

i - A response will be'provided by March 17, 1980. s Question 4-1 = Identify the document (s) which represent the Licensee's radiological monitoring program.

Response

,The 11censee Radiological Environmental Monitoring Program is described in L 1 the: Environmental Technical Specifications which are available in the local public document. rooms. [c s p-- y-I e L'. _ ~

Question 4-2 Will Staff require on-site processing of TLD's for the radiological monitoring program for off-site locations as a condition of restart? If not,' explain way.

Response

The Staff will not require on-site processing of TLD's for the radiological monitoring. - Since TLD's must be retrieved and read they are not sufficient for real time radiation monitoring. Therefore, the Staff will require adequate offsite ra'diological monitors including ratemeters and sampling devices prior to restart. This is part of the long-term program and will be reported on before restart. Even at release rates that occurred during the Unit 2 accident the TLD's had to be left in the field for periods of many hours to record a significant exposure. The small added time it any, required to process these TLD's offsite should have little effect on the regulatory use of these data. The TLD data generally allow two types of calculations to be made_ The amounts of radio-active material that are being released can be estimated. If there are very large arounts being released, other detectors will given instantaneous warnings.. The other type of calculation concerns the doses received by the population and the directions in which the doses occurred. The TLD data can be used only'to calculate doses after they occurred and cannot be used in a predictory ' fashion as t'he wind direction and meteorological disperson characteristics can change from minute _ tol minute. In conclusion, it is not necessary; to have the TLD data processed immediately.

.i -. Question 4-3 Does there exist a time limit within which Licensee must inform state and local authorities about radiation ' exposures which are 'resulting from'an accident. If.so, identify the limit and its . source. Does~ Licensee have the capability of meeting these limits? R_esponse

A specific quantative time limit has not been established.

The Staff F - has required the licensee to promptly~ inform the offsite authorities of certain events as soon as discovered. See Tables 20-23 of the licensee's ~ - emergency. plan. These tables meet the objectives of NUREG-0610. The licensee has communication systems that allow him to promptly inform 'o f fsite. authorities. See the Status Report Section C.3. e I i k ~~ = ~ -. -. ~. r

Question 4-4 Is Licensee required to have radiation monitoring devices at the following distances and, if so, what is the basis'for determining the number, type, and radial distribution of these monitors: 5-10 miles,10-20 miles, 20-50 miles?

Response

The licensee must meet the dosimetry requirements of Table 1 of the Radiological Assessment Branch Technical Position for the Environmental -Radiological Monitoring Program. This position requires 40 stations with two or more dosimeter or one instrument for measuring and recording dose rate continuously to be placed as follows: (1) an inner ring of stations in.the general area of the site boundary and aa outer ring in the 4 to 5 mile range from the site with a station in each sector of each ring (16 - sectors x 2 rings = 32 stations). The balance of the stations, 8, should be placed in special interest areas such as population centers, nearby residences, schools, and one to three in an area (s) to serve as a control station (s). 4 T v

A Question 5-1 According to NUREG-0578 at page A-37, "A recent survey of existing gaseous effluent monitoring capabilities of operating plants shows that less than 20 percent of operating plants have monitors that would have stayed on scale under the conditions of the TMI accident. It can also be shown, however, that the potential releases.from postulated accidents may be several orders of magnitude higher than was encountered at TMI. Under such circumstances, none of the effluent monitors now in service at any operating plant would remain on scale." With regards to this quotation from the Lessons Lear.ned Task Force, answer the following questions: A. What is total amount of radiation released during the. Unit 2 accident?- B. What is the total amount of radiation released in the first 24 hours of the Unit 2 accident? C. What is the maximum release 4 ate (in Ci/sec) during the Unit 2 accident? D. Identify the postulated accidents in which the releases of radiation may be several orders of magnitude higher than the Unit 2 accident and identify the estimated quantities which could be released as well as an estimate of the maximum release rate. E. Did the effluent monitoring system for Unit I display any off-scale readings during the Unit 2 accident? If so, specify. F. Does Licensee now have in place at Unit 1 effluent monitoring systems which are capable of stayln'g on-scale under conditions of a Unit 2 accident? G. If not, will such systems be required as a precondition of restart? If they will-not, why not?-

Response

A. See ' response 1-4 above. B. For noble gases approximately 39 to 45% of the dose received by the population' occurred during the first 20 hours into the accident (see Figure 3-6 of-NUREG-0558). -As the Staff calculated the XE-133 total

release' to be 13 million curies, this means that roughly 5 to 6 million curies would have bun released during the first 20 hours since the population dose is proportional to release rate for similar meteorological conditions. For the iodine releases, approximately 0.2 curies were released during the first 15 hours and approximately 3.9 curies were released during the next 48 hours. (NRC memorandum from R. C. DeYoung as noted above.) Neither the noble gas releases nor the iodine releases were estimated for the first 24 hour period. C. For iodines, the maximum release rate occurred during March 30, and was about 20 Ci/sec. (NRC memorandum from R. C. DeYoung as noted .above.) For the noble gases, the maximum population dose rate occurred during the first 20 hours of the accident (see Figure 3-6 of Reference 3). If about 6 million curies were released during this period, the average - release rate would be about 80 Ci/sec. D. ~ Answers will be provided.by March 17, 1980. E. Answers will be provided by March 17, 1980. F. Answers will be provided by March 17, 1980. G. Answers will be provided by March 17, 1980. .hf w

i. Question 5-2. What is Staff's _ position regarding compliance of TMI-l with GDC 64? Explain your answer. . Response An answer will be provided by March 17, 1980. ~ ' Question 6-1 What is Staff's position regarding when the high-range effluent ronitoring system must be installed?

Response

An answer will be provided by March 17, 1980. Question: 6 Does: Staff' plan.to require design changes to' TMI-1 to counter the.five features listed in Contention #67: If not, why not? If so,1specify.

Response

.;A response will be-provided by March 17, 1980.

1 c ,uestion 7-1 Q Does Licensee now' comply with 10 CFR 50 Appendix X requirements? If not, specify shortcomings. Response. A response will-be provided by March 17, 1980. Question 8-1 .Can Licensce's Emergency Plan.be fully evaluated without reviewing the Energency Plan Implementing Procedures? Explain your answer. 315P1ng _ Prior,to restart as part of the long-term program the Staff will review the_ Emergency Plan Implementing Procedures. See the Status Report section C-3. Question 8-2 - Does Licensee's Emergency Plan contain sufficient information about -the Ingestion Exposure Pathway EPZ? If not, what information is . lacking? EElponse - The ingestion exposure EPZ_ is' part of the long-term program and outside of the scope of' the Commission's Order. (Question 8-3 Identify _ any. requirements regarding the need for updating letters of _ agreement and_ understanding of the type which are appended to Licensee's-Emergency Plan. 325Ponse n Regulatory' Guide 1.101'Section 8.2 provides for the review and update 1 of'all written agreements at.least.every two years. F l .~.

4-Question 8-4 Has Licensee sufficiently justified his choice of a 10-mile circular EPZ for Plume Exposure in his Emergency Plan? Explain your answer.

Response

The licensee has selected a plume exposure EPZ that meets the objectives - of NUREG-0396 and the Commission's Policy Statement of October 18, 1979. See licensee's emergency plan section 4.2.1.5. Question 8-5 Does Licensee's Emergency Plan take sufficient note of Class 9 accidents as per discussion in NUREG-03967 Explain your answer. LResponse The licensee has followed the guidance of NUREG-0396 and NUREG-0610 and -therefore, the Staff considers that the licensee has taken sufficient note of Class 9 accidents as discussed in NUREG-0396. Question 8-6 .What is Staff's position regarding the need for a larger than 10-mile Plume Exposure EPZ due to the large population within ~10 miles of THI? . Response- .See 8-4. i i E t r

{e, W Question 8 ' Can Licensee meet the 15-minute time. limit for notifying the .public in the event of an emergency at the Unit 1 reactor? E -Response' ? The time limit. for notifying the public in the event of an emergency'is part of the long-term program. The Staff will report on this subject prior to. restart. Question 8-8 What is ' Staff's position on the reliability of the means which - Licensee has chosen to control access to Exclusion Area for TMI-l .2(i.e., notification of Coast Guard)? -Response 1The Staff does not-doubt the reliability of the U.S. Coast Guard to provide response to an emergency at TMI-1. 7 -Question 8-9. Does Licensee's emergency classification scheme meet the criteria ~ 'specified lin~ NUREG-06107 - ' Response zThe. licensee's. emergency classification scheme meets the requirements of .hUREG-0610. See licensee's emergency plan Tables 20-23.

,e-Question'9-1 ' Identify documents which show the locations of the radiation monitoring devices dtilized in the Licensee's Radiological Environmental Monitoring Program.

Response

The locations of' the radiation monitoring devices are detailed in the Special Inquiry Group (Rogovin) Report Volume II, Part 2, pp 78 a,b,c. ..This report can be found in the local public document rooms. Question 9-2 -Does Licensee now have the capability of rapidly deploying additional radiation monitoring devices in the event of an accident at Unit 17 If not, specify shortcomings.

Response

The' licensee has the capability of deploying several radio-equipped radiation monitoring teams. See licensee's emergency plan section 4.6.2.3.2 and-4.6.2.4. J I- [ y 4 e-+ g. w

..; ~ "' Question 1 Has Staff evaluated the impact of Unit 2 decontamination procedures =on activities at Unit I? If r.ot, why not? If so, specify which activities were evaluated and the outcomes of the evaluations.

Response

A' response will be provided by Merch 17,Il980.

Question 10-2 Will ' total separation of Units 1 and 2 txt required of the Licensee.as a. precondition of restart?

Response

A response ~will be provided-by March 17, 1980. 2

~ Question 11-1 How much hydrogen was produced due to clad metal-water reaction and radiolysis during the Unit 2 accident? _ Response The exact amount of hydrogen produced due to the clad metal-water reaction, and radiolysis during the Unit 2 accident has not been determined. It has been generally concluded that radiolysis'had a negligible effect on the net production of free hydrogen in _the containment atmosphere. Different . investigations using different sets of assumptions have estimated the hydrogen produced between several hundred pounds to approximately a thousand pounds. The_ estimated percentaga of the clad metal that reacted to form hydrogen ranges from approximately 40 to 50%. The following references detail independent analyses that estimated the total amount of hydrogen produced and the percentage of clad metal that reacted during the.TMI-2 accident: 1. Memorandum from W. R. Butler to R. L. Tedesco dated April 25, 1979, "Three Mile Island, Unit 2: Analysis and Evaluation of Selected Containment Related Issues". 2. Appendix HYD to EPRI Report #NSAC-1, " Analysis of Three Mile-Island, Unit 2 Accident,"-dated July, 1975. 3. " Technical Staff Analysis-Report on Chemistry," by Robert E. English dated October, 1979 presented to the President's Commission on the Accident at:Three Mile Island-(Kemeny Commission). 4. NUREG/CR-1219, " Analysis of_ the Three Mile Island Accident and Alternative g Sequences," dated January,1980.

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.r-. 1 e Question 11-3 What.is-the maximum pressure the reactor vessel can withstand without, catastrophic failure (for. Unit 1)?

Response

The.NRC ' Staff objected to this' question in its February 25, 1980 pleading - entitled "NRC Staff Objections to Discovery Requests" because it is

?

. identical to Question 3-2 which has been answered by the Staff. 1 i. 5 h ' t-i: ( ~ ! :-j-j

- a: Question 11-4 DoesL there now exist a hydrogen gas control system which could have prevented the hydrogen combustion which occurred during - the Unit 2 accident? If so, specify each such type of system. R_esponse The buildup of hydrogen due to the metal-water reaction was too rapid for hydrogen recombiners to control. The only hydrogen gas control system that the Staff is aware of that could have ' prevented the hydrogen combustion at TMI-2 is a system that inerts the containment atmosphere. 'Inerting systems have their own characteristic limitations and disadvantag s e. An example of such a system would be the nitrogen inerting systams typically found-in BWR Mark I containment.- f l t 4 4

t. 1 Question 11-5' ' Will the licensee be required.to install hydrogen recombiners at Unit 1 as a precondition of restart? If not, why not? . Response The Staff ' as not required the installation of hydrogen recombiners at n TMI-l because recombiners do not have the capacity to prevent the rapid buildup of hydrogen and the subsequent hydrogen combustion that is believed to have occurred during the Unit 2 accident. The licensee, however, has voluntarily installed hydrogen recombiners at the Unit 1 facility. - In response to Item II.B.8 of the, "NRC Action Plans Developed as a Result of the TMI-2-Accident," Draft 2,-NUREG-0660, January, 1980, the Staff is preparing for a rulemaking proceeding on the subject of degraded or melted cores, which will include hydrogen management. b .s d ed eM y+ W e-q g e

.+ 4 i l Question 12-1: When will' Staff's Environmental Impact Assessment be completed? tResponse A ~ schedule.for the_ preparation of an Environmental Ap,iraisal has not .been set..The Staff does not know when-such a report v ll be completed.- i W / e 9 e J ~ u I f -i).-, 1 Y h Y g -{- 'y -p- +y g a w c-w,- e- ,= =F-99 r-+-35-e

. v. 1 s Question 13 -Identify all requirements within NRC regulations relating to the Unit 1 computer.

Response

'NRC Regulations'do not require a plant computer. -Question 13-2 For each requirement listed in response to interrogatory 13-1, assess Licensee's compliance.

Response

Refer to Item 13-1. r Question 13-3 ^ Has Staff required computer systems at naclear reactors to meet-GDC 13 requirements? If so, specify, particularly with respect to Unit 1. If not, why not?

Response

I The Staff has not required computer systems at nuclear power generating ' stations to meet GDC-13. The Staff requires. compliance.with the general - design criteria but does not specify designs 'to effect compliance. Generally,. and for TMI-l explicitly, GDC 13 is met by using dedicated, hardwired ~ instrumentation and control-systems arranged on the main control. board. T 9-awr

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' L-e . Question 13-4 Will Licensee be required to meet GDC 13 criteria for Unit l's computer prior to restart? If not, why not?

Response

The licensee will. not be explicitly required to meet GDC 13 for the plant computer. As stated in response to item 13-3, GDC 13 must be satisfied; however, the licensee has not opted to use the plant computer for this purpose. Question 13-5 Will Licensee be required to provide for redundancy in Unit l's computer and printout capabilities prior to restart? If not, why not?

Response

The licensee. is not currently required to provide any major upgrading of the plant computer system as a prerequisite to restart. The licensee is undertaking a major upgrading of the Unit 1 plant computer capabilities under its own initiative. The Staff has initiated studies dealing with man-machine interfaces which is a more encompassing effort than just plant computers. These studies are part of long-term Lessons Learned and therefore, resulting requirements will be applied generically to all nuclear power generating stations including TMI-1. l a u --. _. - __. _ m

-Question 14-1 ' Identify documents which list all NRC Inspection Reports and LER's with regard to Units 1.and 2, and if possible, provide copies.of such documents.

Response

-The documents which list all NRC Inspection Reports and LER's with

regard to Units 1 and 2, are:

1. NUREG-0568 Rev.1 Title List Publicly Available Documents TMI-2 Cumulated to June 30, 1979. 2. NUREG-0568 Rev.1, Supp.1, _ Title List Publicly Available Documents TM1-2 July 1,-1979 to October 31, 1979. 3. huREG-0631, Title List Publicly Available Documents TMI-1 Cumulated to November 16,=1979. l l Copies of these documents have already been sent to all Intervenors in this proceeding. Question 14-2 Define the phrase " management and administrative capabilities."

Response

Management and administrative capability, in our context, is the ability to manage and integrate the functional activities that are important to the safe operation of a nuclear power facility. This is a judgment based on the organizational structure,;1ines of authority and communications, ~ snd the experience level of persons assigned to perform the re' quired ' activities. t.

-Question 15-1 According to tiUREG-0616 at page 3, " Human factors played a key role in the precursor events, in t b accident scenario, in the response to the accident, and in many other related aspects. Human factors are involved in the perception of the precursor events in the man-machine interface, and in the operators' response to the event. Human factors appear to be a fertile area for consideration. Training and technical qualifications are the most commonly used approaches to influencing human factors. This area, which is not well understood, should be better developed." With regards to this quote, respond to the following questions: A. Identify all f1RC Staff and contractor / consultant work in the arca _ of-human factors, specifying both past and present work, and identifying all such work by principal investigators and the availability or preliminary and final reports on such work. B. Is the Standards Development branch of fiRC or any other branch of fiRC contemplating regulatory guidance in the area of human factors? If no, why not? If so, explain. C. Identify by name and branch within t1RC persons with specialization in the area of human factors, including human factors operators)g, psychology (as it relates to perceptions of reactor engineerin , man-machine interface specialists, and control room design specialists. D. To what extent have the persons named in "C' above participated in reviews of Unit 1 either for Operating Licensee or for the Restart Report documents? Be specific as possible.

Response

A response will be provided by March 17, 1980. 4

w Question 15-2 Is Staff aware of the EPIR report involved with Human Factors Engineering in reactor control rooms (EPIR Report

1. NP309)?

If so, to what extent does Staff feel that. this report identifies possible problems in the design and layout of the control room at Unit I?

Response

A response will be provided by tbrch 17, 1980. Question 15-3 NUREG-0616 identifies Recommendation 2.7-3 on page 72-73 of NUREG-0616. Does Staff plan to implement this recommendation? If not, why not? If so, in what manner?

Response

A response will be provided by March 17, 1980. Q,ues tion '15-4' In NUREG-0616 at page.9 it is stated, " Increased emphasis -should be placed on understanding. human factors as they relate to safety and security...". Specify the manner (s) which human factors impacts upon security considerations. Response. -Afresponse will be provided by March 17, 1980. F

Question 16-1 Identify all studies underway or completed which deal with security (Internal security) at Three Mile Island Unit 1. Include authors names and. titles of reports.

Response

The Division of Safeguards has an' ongoing technical assistance project that provides_for the systematic analysis of TMI, Unit 1, to identify ,those specific areas and combinations of areas in which sabotage actions could~ result in radiological exposures to the public in excess of 10 C.F.R. Part 100_ limits. This study is being conducted by Los Alamos Scientific Lab. The pending results of the contractor's analysis, and the licensee's security plan, are information of the type specified in 10 C.F.R. 62.790(d) and are accordingly withheld from public disclosure. Two additional security-related studies (that were prepared at the request. ~ of the Staff of the President's Commission on the Accident at Three Mile Island)arepubliclyavailable: I. Pre and Post-Accident Security' Status at Three Mile Island," Donald G. Rose, Los Alamos Scientific Laboratory. II. "Three~ Mile Island' Sabotage Event Analyses," Claiborne, Cubitt, Haarman, and Rand, Losl Alamos Scientific Laboratory.

m m-Question 16-2 Will Licensee be required to implement the "two-man rule" prior to restart? If not, why not?

Response

- The Commission and the Staff have under consideration the possible implementation of several alternative security measures related to protection against insiders at nuclear power plants (see 44 g 47758, - August 15, 1979, and the prior FR issuances referenced therein). The Staff has a research program underway to provide a comparative analysis of the effectiveness of these alternative measures. Any recommendation regarding - the use of visual surveillance ("two-man rule") procedures in vital areas at TMI-1 will be based on the Staff's evaluation of the potential effectiveness and associated operational impacts of such procedures.. P + 4 &9 q, W

Question 16-3 There is.in the NRC local PDR at the State Library in Harrisburg a file which contains a " Routing and Transmittal Slip" dated 4/20/79 from A.L. Eiss to R.G. Smith with copies to R.B. Minogue, G.A. Arlotto, K.R. Goller and A.L. Eiss. Under remarks, this memo states, " Enclosed are scopes prepared by the SD Staff on ~ Categories A and B Regulatory Guides that are being considered for revision based on the TMI incident". One of the items within this packet of information submitted with this memo is a document entitled, " PROJECT PRIORITIES FOR SAFEGUARDS STANDARDS BRANCH" which lists several_ planned studies. These studies are: A. "TA contract to provide standards for psychological assessment of security personnel." B. "TA contract to provide standards for a Continuing Observation Program" to provide an industry useable behavioral observation program. C. " Personnel Access / Exit Control of Authorized Individuals at Huclear Power Reactors". D. " Secure Communications to Nuclear Fixed-Site Facilities". Have these. studies commenced? Have they been completed? Identify who is working on these studies, their expected completion dates, and the availability of preliminary or final reports on these studies.

Response

A. The contract to provide standards for psychological assessment was let to Assessment Designs, Inc., Orlando, Florida in October 1979, to be completed by October 1980. No reports are available as yet. B. The contract to provide standards for a continuing observation program was let to Personnel Decisions, Inc., Minneapolis, Minnesota in October 1979, to be completed by October 1980. Reports are not yet available.

C. This project " Personnel Access / Exit Control of Authorized Individuals at Nuclear Power Reactors,".is still in the planning stage. Startup or completion dates have ~not been determined. D. This project, " Secure Comunications to Nuclear Fixed-Site Facilities," is also still in the planning stage. Startup or completion dates have not been determined. 4 1 em 'l

Question 17-1 To what extent has Staff's accident analysis procedure ' included analysis of Class 9 accidents?

Response

A response.will be provided by March 17, 1980. -Question 17 Define Class 9 accidents.

Response

In the' Salem Unit 1 proce: ding, the Staff in a pleading adopted the language of the proposed Annex to 10 CFR Part 50, Appendix D in l defining what constitutes a Class 9 accident. ("HRC Staff Response to -Board Question No. 4 Regarding the Occurrence' of a Class 9 Accident at ThreeMileIsland," dated 8/24/79,p.2). A copy of the' Staff pleading 'is attached.

Question 17-3 Is consideration of Class 9 accidents, including the specific scenarios in Contention #17, included in the Staff's Environmental Impact Assessment of the TMI restart?

Response

The preparation of an Environmental Appraisal has not been started. The Staff has not yet decided whether Class 9 accidents will be considered in the report. Question 17-4 To what extent have the following features been included in Staff's accident analysis for Unit 1: A. Multiple failures, esoecially multiple failures of engineered safety features. B. Deliberate acts of sabotage by insiders. C. Operator error in responding to accidents and transients?

Response

A response will be provided by March 17, 1980. Respectfully submitted, /l Lucinda Ltx Swartz Dated at Bethesda, Maryland this 29th day of February,1980.

p.; UNITED STALES OF A". ERICA NUCLEAR REGULATORY C0!iMISSION BEFORE Tile ATOMIC SAFETY Afl0 LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, Docket No. 50-289 LT AL.. -(Three Mile Island, Unit 1) CEP.' > ~' ATE OF SERVICE I hereby certify that copics of "NRC STAFF RESPONSE 10 INTERVENOR STEVEN C. Sil0LLY FIRST SET OF INTERR0GATORIES", dated February 29,1980 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 deposit in the Nuclear Regulatory Commission's internal mail system, this 29th day of February,1930: Ivan W. Smith, Esq. Mr. Steven C. Sholly Atomic' Safety & Licensing. Board Panel 304 South Market Street U.S. !!uclear Regulatory Commission Mechanicsburg, Pennsylvania 17055 Washir.gton, D. C. 20555 Mr. Thomas Gerusky Dr. Walter H. Jordan Bureau of Radiation Protection i 881 W. Outer Drive Dept. of Environmental Resources Oak Ridge', Tennessee 37830 P.O. Box 2063 liarrisburg, Pennsylvania 17120 Dr. Linda W. Little 5000 Hermitage Drive Mr. Marvin I. Lewis Raleigh, North Carolina 27612 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 George F. Trowbridge, Esq. Shaw, Pittman, Potts & Trowbridge Metropolitan Edison Company h -1800 M Street, N.W. Attn: J.G. llerbein, Vice President Washington, D. C. 20006 P.O. Box 542 Reading, Pennsylvania 19603

Karin W. Carter, Esq.

505' Executive llouse Ms. Jane Lee P.O. Box 2357 R.D. 3; Box 3521 Harrisburg, Pennsylvania 17120 Etters, Pennsylvania 17319 !!onorable Mark. Cohen Walter W. Cohen, Consumer Advocate 512 D-3 Main Capital Building Department of Justice Harrisburg, Pennsylvania 17120 Strawberry Square,14th Floor liarrisburg, Pennsylvania 17127 g

f t. 4 John Levin, Esq. Pennsylvania Public Utilities Conn. Box 3265 liarrisburg, Pennsylvania 17120 Jordan D. Cunningham, Esq. Fox, Farr and Cunningham John E. Minnich, Chainnan 2320 North 2nd Street Dauphin Co. Board of Commissioners liarrisburg, Pennsylvania 17110 Dauphin County Courthouse Front and Market Sts. Theodore A. Adler, Esq. Harrisburg, Pennsylvania 17101 WID0FF REAGER SELK0WITZ & ADLER Post Office Box 1547 Atomic Safety and Licensing Appeal Board Harrisburg, Pennsylvania 17105 U.S. Nuclear Regulatory Comnission Washington, D.~C. 20555 Ms. Ellyn R. Weiss Sheldon, Harmon, Roisman & Weiss Atomic Safety and Licensing Board Panel 1725 I Street, N.W. U.S. Nuclear Regulatory Conunission Suite 506 Washington, D. C. 20555 Washington, D. C. 20006 Docketing and Service Section Ms. Karen Sheldon U.S. Nuclear Regulatory Commission Sheldon, Harmon, Roisman & Weiss Washington, D. C. 20555 1725 I Street, N.W. Suite 506 Robert Q. Pollard Washington, D. C. 20006 Chesapeak Energy Alliance 609 Montpelier Street Ms. Marjorie M. Aamodt Baltimore, Maryland 21218 R.D. #5 Chauncey Kepford Judith H. Johnsrud Environmental Coalition on Nuclear Power 433 Orlando Avenue f~ State College, Pennsylvania 16801 Ms. Frieda Berryhill, Chairman ' Coalition for Nuclear Powcr Plant a J' Postponement 2610 Grendon Drive -Counsel for NRC Staff Wilmington, Delaware 19808 - Holly S. Keck JAnti-Nuclear. Group. Representing York 245 W. Philadelphia Street York,- Pennsylvania 17404 w

o UNITED STATE 5 0F AMERICA NUCLEAR REGULATORY C0K4ISS10N BEFORE THE ATOMIC dAFETY AND LICENSING BOARD In'the Matter of ' METROPOLITAN EDISON COMPANY, et al. Docket No. 50-209 (Three Mile Island, Unit 1) AFFIDAVIT OF DOUGLAS Y. PICKETT I, Douglas V. Pickett, being duly sworn, do' depose and state: ~ 1. I am a Containment Systems Engineer in the Division of Systems Safety. Office of Nuclear Reactor Regulation of the United States Nuclear Reou-latory Commission. I am responsible for reviewing the containment re-lated systems of assigned nuclear power plants, including Three Mile Island, Unit 1 Restart Program. My professional qualifications statement is attached. 2. The answers to Steven C. Sholley's Interrogatories 1-1, 1-2, 1-3, 'n -1, 11-2, 11-4 and 11-5 were prepared by me. I certify that the answers given are true and accurate to the best of my knowledge. 1%k V k Douglds V. Pickett Subscribed and sworn to before me.this d f day of Qi /7h .U kl O). lf iNotary Public' /' 'My, Commission expires: F e p--w-e ena 1se -5 e. -agisen p mas 9.., p--memen - e

PROFESSIONAL QUALIFICATIONS Douglas V. Pickett I am a Containment Systems Engineer in the Containment Systems Branch of the Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Comission. In this position, which I have held since October 1975 I am responsible for the review and technical evaluation of containment related aspects for PWR applica-tions for both construction permits and operating licenses. Among the plants for which I have or have had this responsibility are Davis Besse Nuclear Power Station, Unit 1; Arkansas Nuclear One, Unit 2; Erie Nuclear Plant, Units 1 and 2; Virgil C. Summer Nuclear Station; Shea'ron Harris Nuclear Power Plant, Units 1, 2, 3 and 4; Midland Plant, Units 1 and 2; RESAR 414; and Haven Nuclear Plant, Units 1 and 2. l From June 1973 to October 1975, I was employed as an engineer in the Power Divi-sion of Stone and Webster Engineering Corporation, Boston, Massachusetts. My re-sponsibilities included subcompartment analysis to establish design criteria for both PWR and HTGR containments, preparing answers to AEC requests for additional information concerning containment spray systems and supm design and writing the appropriate SAR sections. In addition I wrote technical specifications for field -equipment purchases. During.the sumer of 19,72 I was ' employed as a technician for Nuclear Fuel Services in Rockville, Maryland. Here, I assisted in the development of-computer codes which predicted the fuel depletion rates for both pressurized and boiling water reactors. My academic trainino includes a Bachelor of Science in Nuclear Enginnering from the University of Virginia in -1973 followed by a Master of Mechanical Engineering froh'the Catholic University of America in 1978. m. u,- % he - e es, -e -w.emommme see-w,m

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UNITED STATES 0F AMERICA NUCLEAR REGULATORY COM'4ISSION BEFORE THE ATOMIC SAFETY AND LICFNSING BOARD .In'the Matter of ) - )- . METROPOLITAN EDISON COMPANY, et _al. ) Docket No. 50-289 ) 'Three Mile Island, Unit 1) ) AFFIDAVIT OF WALTER PASCIAK I, Walter Pasciak, being duly sworn, do depose and state: 1. I.am employed by Division of Site Safety and Environmental Analysis,:0ffice of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission. 2. The answers to Sholly Interrogatories 1-4, 5-1 (A-0) were prepared by me. -I certify'that the answers given are true and accurate to the best of my knowledge. } dl Walter'P

iak Subscribed 'and sworn to before me'this

, ' day of 'i -q<. 1980. .< yl, }f -hotary Public. /- My Commission Expires: -lu / / lD .iy ) t ^ i2g k e.+m-.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) METROPOLITAN EDISON COMPANY, e_t al. ) DOCKET NO 50-289 t ) (Three n le Island, Unit 1) ) AFFIDAVIT OF ROBERT'G FITZPATRICK I, Robert G. Fitzpatrick, being duly sworn, do depose and state: 1. I am a Senior member of the Power Systems Branch in the Division of Systems Safety, Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission. I am responsible for the electrical aspects of the safety review of assigned nuclear power plants, including Three Mile Island, Unit 1 Restart Program. 2 The answers to the. Steven C. Sholly Interrogatories 2-1, 13-1, 13-2, 13-3,13-4, and 13-5 were prepared by me. I certify that the answers given are true and accurate to the best of my knowledge. Robert G. Fitzpat ' Subscribed and sworn to ha fore r.ie this_ /kday of / GA ilotary Public [j /iES My Commission expires :

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 l(Three Mile' Island, Unit.1) ) AFFIDAVIT OF BRUCE A. B0GER I, Bruce A. Boger,-being, duly sworn, do depose and state: 1. I_am employed by the Operator Licensing Branch, Office of Nuclear Reactor . b quiation of the United States Nuclear Regulatory Commission. 2. The answers to Sholly Interrogatories 3-1 and 3-3 were prepared by me. I certify that the answers given are true and accurate to the best of my . knowledge. ll<gk Bruce A. Boger / Subscribed and. sworn'to before ~ meLthis', . day of K.,_.1980. } / 'h-C'L-?;'

Notary Public-

_J. - ) 7J d- . My Commission' Expires:- -, f e L

UNITED STATES OF A' ERICA '~- NUCLEAR REDUIATORY CO:2CSSION BEFORE THE ATOMIC SAFETY AND LICENSIfG BOARD i In the Matter of METROPOIITAN EDISON. COMPAlff, et al. Docket 'No. 50-289 (ThreeMileIsland, Unit 1) i AFFIDAVIT OF ROMUALD E. IlPII' SKI I I, Romuald E. Iipinski, being duly sworn, do depose and state: 1. I am employed in the Stzuctural Engineering Branch of the Division of Systems Safety in the Office of thclear Rea'ctor Regulation of the United States !'uclear Regulatory Commission. My professional qualifica-tions Ststement is attached. 2. The answer to Sholly Interrogatory 3-2 was prepared by me. I certify that the answer is true and accurate to the best of my knowledge. hY 'h '* Romuald E. Iipinski V Subscribed and. sworn to beforemethis/d-dayof Wux.a~ /1Fo k n b jf Jh. & Notarf Public My Commission expires: ./, /7 ['

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ROMUALD E. LIPINSKI PROFESSIONAL QUALIFICATIONS STRUCTURAL ENGINEERING BRANCH I am a Structural Engineer in the Structural Engineering Dranch of Nuclear Regulatory Comission. I am responsible for the review and / . evaluation of adequacy of criteria used 1n the structural design and l i ..ana ys s of Seismic Category I structures, systems and components of nuclear power plants assigned to the branch. I received a B.S.-degree in Civil Engineering in 1957 and the degree of Master of Science in Civil Engineering in 1961, both from the Newark College of Engineering,' Newark, N.J. from 1954 to 1955 I worked as a designer-draftsman on the des'fgn of highway bridges under the employment of the consulting fim of Proctor. Urquhart and Beavin in Newark, N.J.. My duties were related to design and detailing of highway overpasses and checking shop draw-ings. From 1955 to 1956 I worked as a designer in Ebasco, Inc., (4 months) and Parco Inc., both of New York, N.Y.. My duties were in design, checking and detailing of yarious parts of chemical plants ,and hydro-electric power generating plants. ~ From 1956 to 1965 I was emplofed by the Public Service Electric and Gas Co., Newark, N.J. as a structural designer. My assignments were in design and preparation of layout plans and detailing of t various portions of conventional power generating plants, switching stations and substations. From 1965 to 1969 I worked as a structural engineer for the Naval Facilities Engineering Command, Electronic Support Branch. My duties consisted of reviewing structural designs and plans and preparation of designs and specifications of radio communication a'ntennas. My ass'ignments involved also supervision of similar tasks ~ perfomed by others nilated to design of communication facilities. .s e!

a From 1969 to 1972 I was' employed as a structural engineer by the U.S. - Atomic Energy Concission, Di. vision of Materials Lie.nsi.ng. My duties involved review of' structural designs of shipping casks for transportation of irradiat'ed fuel elements or other radioactive ma terial s, From 1972 to'present I have been working as a member of Structural Engineering Branch. In that capacity I have participate.! in devel-oping criteria for structural design and. analysis of seismic Cate-gory I~ structures in nuclear power plants, p'erforme'd evaluation of technical reports concerning structural behavior under various loading conditions and reviewed ~ the safety analysis reports of nuclear power plants of Millstone Unit 2. Nine Mile Point, Davis Besse Unit 1, Beaver Valley Unit 1, Alvin W. Vogtle etc. in the areas relating to ~ the design and analysis of sei'mic Category I structures. I am a s merber of the American Society of Civil Engineers, I am also a member of the ACI-ASME 359 Technical Comittee on Concrete Pressure Components for Nuclear Service and I participated i.n the development of ACI Standard; Code Requirements for Nuclear Safety Related Concrete Structures (ACI-349). I am a registered professional engineer in the states of New York and New Jersey and a. fallout shelter analyst certified by the Defense Civil Preparedness Agency. t to \\ ( I, h - -1:

T- / UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE Tile ATOMIC SAFETY AND LICENSING B0ARD In thS Matter of -) METROPOLITANEDIS0NCOMPANY, eta _1 Docket No. 50-289 (Three Mile Island, Unit 1) AFFIDAVIT OF JACK W. R0E I, Jack W.-Roe, being duly sworn, do depose and state: 1. I am an Emergency Preparedness Analyst in the Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission. I am responsible for the review and evaluation of nuclear power reactor emergency plans. 2. The answers to Sholly Interrogatories 4-1, 4-2, 4-3, 4-4, 8-1; 8-2, 8-3, 8-4, 8-5, 8-6, 8-7, 8-8, 8-9, 9-1, and 9-2 were prepared by me. I certify that the answers given are true and accurate to the best of my knowledge. 1 e \\ Ek d b ack W. Roe -Subscribed and sworn to before

me' this S oday of 7 4,1980, Ifu

. J /). hd$ Notary Public /# My Cornission Expires:' h J. / /f/ 7 ~ (,. ()

-UtlITED STATES OF AMERICA NUCLEAR-REGULATOP.Y CGMMISSION BEFORE THE-ATOMIC SAFETY AND LICENSING BOARD In the Matter.of ) ) METROPOLITAN ~ EDISON COMPANY, et a1. ) Docket No. 50-289 ) (Three Mile Island.. Unit 1) ) 1 AFFIDAVIT OF JAN A. iiORRIS I, Jan A. Norris, being duly sworn, do depose and state:

1. I am employed by the Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission.

I have been assigned to prepare an environmental appraisal for the proposed restart of TMI-1.

2. The answers to Sholly Interrogatories 12-1 and 17-3 were prepared by me.

I certify that the answers given are true and accurate to the best of my knowledge. \\,nLLL-j \\ J.Lw. o s Jan. A. Norris Subscribed and sworn to before me this 4 7," day of / /7A ,' / )) L .sc p; Notary Public ' ' ~~ My Cerr.T.ission' expires: a l y..

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 ROBERT W. REID I, Robert N. Reid, being duly sworn, do depose and state: -1 I am the Chief of the Operating Reactors Branch #4 in the Division of Operating Reactors,-Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission. 2. The answers-to Sholly In ;rrogatory 14-1 was prepared by me. I certify that the answers given are true and accurate to the best of rqy knowledge. 'h' Ar R6b'ert' W. Reid' Subscribed and sworn. to beforo - . me this y '! day of A-6 1980. L. - .,y-j'_'_j^.: j,lO7 % <-, Notary Public. S My Commission Expires: J 1. <. /,' 5 Jb

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) METROPOLITAN EDIS0N C0ftPANY, et al. Docket No. 50-289 -(Three Mile Island, Unit 1) ) AFFIDAVIT OF ROBERT F. SKELTOI I, Robert F. Skelton, being duly sworn, do depose and state: 1. I am employed by the Physical Security Licensing Branch in the Office of Nuclear Material Safety and Safeguards of the United States Nuclear Regulatory Commission. 2. The answers to Sholly Interrogatories 16-1 and 16-2 were prepared by_me. I certify that the answers giv'en are true and accurate to the best of rqy knowledge. / IN Y k SA & Robert F. Skelton Subscribed and sworn to before me this.. ?" day of N>~ e y 1980.

i. '.

i u_ d_M s.w_, Notar,yPublic - My' Comission Expires: Mr Can 2%n rai!m Tuly 1,19s2 - t l f

.i; ' . n: ?, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4 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 LUCINDA LOW SWARTZ I,-Lucinda low Swartz, being duly sworn, do ' depose and state: ~1. LI am an. attorney in good standing admitted.to practice before the Courts of the' District of Columbia. I hold the position of Staff Attorney in the Office of the Executive Legal Director of the United States Nuclear Regulatory Commission'and serve as Staff Counsel in this proceeding.

2.. The answer to. Sholly Interrogatory 17-2 was prepared by me.

I certify that the answer given is true and accurate to the best of my knowledge. Mzh ' 41d[/l a2 ( 'Lucinda Low Swartz p Subscribed and sworn to before. me this 28th. day of Feb.,1980. c<2 , ckt - 4'/Wf Notary Public My Ccmission -Expires: July 1, 1980-

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~ UNITED STATES OF AP. ERICA 8/24/79 ~ NUCLEAR REGULATORY C0;ISS10N BEFORE THE ATOMIC SAFETY A"D LICENSING P.0ARD s 1 In the Matter.of ) 1 PUBLIC SERVICE ELECTRIC & Docket No. 50-272 GAS COMPANY ) Proposed Issuance of Amend:nent ) to Facility Operat-ing License J (Salen Nuclear Generating ) No. DPR-70 Station, Unit No.1) ) g-NRC STAFF RESPONSE TO BOARD QUESTION NO. 4 REGARDING THE OCCURRENCE OF A CLASS 9 ACCIDENT AT THREE_ MILE ISL A'!D During the course of the present proceeding, the Board made inquiry of the Staff as to whether the accident at the Three Mile Island facility was a Class 9 accident. Specifically, the Board directed that the Staff respond to the following series of questions regarding this occurrence: The proposed Annex to Appendix 0,10 CFR Part 50, appears to define a Class 9 accident as a sequence of failures which are more severe than those which the safety features of the plant are designed to prevent. The sequence of failures at Three Mile Island produced a breach of the con-tainment and a release of radiation which could not be prevented by the safety features. Was the occurrence at ~ Three I;ile Island therefore a Class 9 accident? Was the risk to the health and safety and the environment " remote in probability" or "extren:ely low" at Three Mile Island, as those-terms are used in the Annex? 'The Staff has now completed its response to the Board's inquiry, and submits its views herein. DUPLICATE DOCUMENT i Entire document previously entered into system under: ANO l No. of pages: '-w'. s.- .,-...m..,.,,

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7, AUG 1 G 1979 .. A. 'f il0TE T0: Guy H. Cunningham, III, Acting Deputy Chief ifearing. Counsel FRO.?1: Roger J. flattson, Director, Tit!-2 Lessons Learned Task Force

SUBJECT:

BOA.".0 QUESTION CONCERNIllG CLASS 9 ACCIDEllTS 1 In response to your request of July 27, 1979, I have attached our response to the Salem spent fuel pool Coard question on Class 9 accidents. i D7)h ot RogerJ,f[sttson, Director Till-2 Lessons Learned Task Force

Enclosure:

As Stated cc: Barry 5:aith i Janice !'oore i Gary Zech i Walt Pasedag Robert Tedesco John Vogicuede John Guibert Fred Anderson \\. i I l DUPLICATE DOCUMENT Entire document previously entered into system under: h ANO No. of pages: h 9 wn ,.,e.,-,w--m ,----we -m-- -m ,}}