ML19322A341
| ML19322A341 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/01/1979 |
| From: | Belvin E, Green H, Dawn Powell TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML19322A340 | List: |
| References | |
| NUDOCS 7909240337 | |
| Download: ML19322A341 (66) | |
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Task Tcree on helear Safety Tennessee Va.11ey /suthority E
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D ooE TO Leon E. Ring, General X:. nager r
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f S. David Free =an, Chair =an l FRO.M 1
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J Rictsrd M. Free =an, Director i DATE June 1, 1979
SUBJECT:
TVA NUCLEAR PROGRAM REVIEW We have reviewed the Task Force report entitled "TVA Nuclear Program Review." We approve its recom=endations and direct that they be undertaken at once.
We believe that this report should be given widespread distribution both within and outside TVA. We encourage TVA e=ployees to feel entirely free to discuss publicly the nuclear power and nuclear safety issues.
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??2 TACE This draft report was prepared by the special task rcree appointed by the TVA Board to -de recon =endations relating to TVA's nuclear program in
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T. accident. The task force light of the "hree Mile Island Nuclear Pla me=bers are:
David G. ?ovell, Executive Assistant to the General i
Manager - Chai:=an l
Ernest A. Selvin, Jr., Acting Director, Occupatione.1 Eealth and Safety f
E. J. Green, Chief, Nuclear Generation 3 ranch n
f
. Carlyle Michelsen, Principal Ingineer for Nuclear Systems Analysis Dd sht R. Patterson, Chief, Mechanical Engineering
Branch Sue I. Wallace, Chief, Planning and Analysis 3 ranch, Division of ?ersonnei A
u$8 WS lvG cuJ David G. Povell Caflyle Pf:^.elson a
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,w Ernest A. Selvin, Jr.
Jaight R. Patterson pW/
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On March 29, 19'T9, at the direction of the W A 3 card, the TVA General Xanager I
directed the TVA staff to folicv closely the Nuclear Regulatory Cc==ission's investigation of the Three R'.le Island Nuclear Plant accident, to review equip =ent, design, procedur as, and staffing in TVA's nuclear plants, and to report its findin6s to the Board as soon as possible.
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As a result, TVA's nuclear program has been under intensive review to deter-q
=ine the lessons ve could learn fro = the Tnree Mile Island accident, the cur-
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I rent s.atus of the TVA safety progra= in light of those lessons, and changes aI s
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which could be made to i= prove the progra=.
I Several i=prcve=2nts are recensended in organization and :=_nage=ent of the g
,t program. The =ost significant is the formaticn of an independent _safety review staff outside the pcVer, construction, and design organi:stions which has direct access to the WA Board of Oirectors.
Another very i=portant change is to create a _ separate organi:a-Q nuc' ear genera-ica within the l
Office of ?cver to concentrate on its unique proble=s, and to consclidate nuclear safety and nuclear engineering functions into a new nuclear engineering branch _in the design organization.
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Significant changes to the nuclear plant operator selection and training progra are recc==enled. 7nese chan6es vill require more stringent intelli-gence tests in the recruiting, of candidates, sore intensive training over
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.t several years, and an incre:.se in the salaries of operaters..: a level th.:
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g ill recognize the prorce w nal status of the nucles.: plant opera:cr.
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rent operators and trainees vill be required to =eet the new standards.
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!!uclear plant support vill be improved by the reco=endation that an e= ergs =.::7
. response tea = be dispatched to a plant experiencing an e=ergency to ass st in i
canaging operations and in ec==unicating with other TVA experts.
Ixposures of W A e=ployees to radiatic: in nuclear plants vill be reduced n
vith the reconmendation that the current TVA 11=it of 5 Rem per year be i
lowered to k Re= per year.
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9 Z=ergency planning vill be improved with the recon =endation that centingency l
planning for evacuating or sheltering people in the event of a nuclear accident be extended out to 10 miles.
l Several design changes are recc= ended in light of the Tnree Mile Island acci-i dent which vill i=; rove the safety of TVA nuclear plants.
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- ntroduenion "I
. Organization and Managenent of the 1
- b liuclear Power Progra
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'iuclear Safety Reviev Stah'f
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Plant Operations and Staffing 6
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hgineering Design Staffing t,
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Differing Staff Cpinions p.-
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C;erator Selection, Training, and Staffing neI C.cren Situation:
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Selection and '" raining 11 3.
Staffing 4
f Recc=endations :
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Selection and Oraining 12 1.
Selection 1
13 2.
Training 15 il 3.
Staffing
. 15 i
1.
h ergency Response Tes=
15 l
2.
Cc=unica icns 17
- . Eadiation Standards for hployees r
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I'.*. :'uclear P'. ant esign and Operation I
25 A.
Design Cher.ges to Shance Safe y i
1.
Status Monitoring of Main Line Process 5
e Conpenents 27 2.
Prina y Systen Venting 29 3
Primary Systen 'a'ater Level F.onitoring h.
Advanced Core Yenitoring for Ker=al Operation 31 32 j
5 Containnen: :sclation 35 6.
Sampling and Radia-ion Monitori5g Systens 37 7
Stuck-open Pressurizer Relief Va.lve
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-a-P Pr. e l
Design.v tters for Further Study - 5=all 3.
s Break Loss of Coo'ar.t Accidents 39 5
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Operational Feedback
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hergency Planning
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Evacuation Contingency Plans j
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Com.unications Facilities j
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h ergency Offsite F.nvircnmental Monitoring kT
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Public Reporting of Proble=s at Nuclear k9 Plants Appendix 3
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.r9 It sr Any nuclear pcver progra. cust be safety-ninded.
n TVA, the Offices of
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Pover and Engineering Design and Construction are charged with the pri=s. y
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"he TVA 3 card, however, bears the ulti= ate
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t responsibility for safety.
j In order t.o provide the 3 card with an independent review on safety, an
.k independent safety staff vill be formed. Such a s aff is needed because there is an inherent conflict between production cos.s and safety concerns, and the 3 card needs advice from exper s whose sole concern is safety in order to be sure tha, sr.fety gets the highest priority.
his Nuclear Safety Review Staff vill repor to.-he Board through the Manager of Ega'Ath and Se.ferv, and act i
independently of the design, construction, and power production organizations.
In the Office of Power, sanase=ent of nuclear plants vill be separated fro:
fossil and hydro ge:ieration canagement, which vill give -he nuclear progra more 51iect access o top management sad per=i a greater emphasis en safety.
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In the Divisica of F.ngineering Design, a new Xuclear Engineering 3 ranch vill A
be for=ed which vill strengthen and give greater managenent emphasis o nuclear
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=afety during desig of VA nuclear plants, by moving the function higher in a
i the organi:ation.
a Finally, staff members with technical or professional views which differ with those adopted by management vill be able to go directly to the independent Uuclear Safety ?.eviev Staff and the Board with their concerns.
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Nuciear Saf*3v Feviev Staff s
I Gature of the Issue:
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Muclear safety questions should be reviewed independently of the nomal engineering and operating divisions of TVA, and this reviev must be incor-porated into the decision =aking process.
Assurance cust be provided that ques, ions of nuclear safety receive para =ount consideratien over and above cost and schedule requirements or operational needs of the power system.
3e ce=:endatien :
To respond,o,hese needs, a Nuclear Safety Review Staff vill be established 1
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vithin the Office of Mr.agenen, Services. This staff vill act independently of TVA organi:ations conce=ed with the design, construction, operation, and support c2 nuclear pla.ts, and vill have broad authority to =onit.qr, reviev, and audit TVA's nuclea act W es.
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Its purpose vill be to advise the TVA 3 card on nuclear safety policy, report-ing through the Manager of Health and Safety and the General Manager, and to advise and assist in making decisions affecting the safety of TVA nuclear f
plants. The staff vill make recon =endatiens for changes to enhance the d
safety of TVA nuclect plan *3.
Tne Nuclear Safety F.eview Staff vill act independently to conduct onsite
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inspection: of all phases of WA's nuclear program, and vill be staffed 1
ade:Lustely to per. arm this function.
It may call upon other resources and ares.s of expertise within Health and Safety and other WA organizations.
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Specific functions of the Xuelear Safety Review Str.ff include:
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Independent review of nuclea plan, design.
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Independent ronitoring of nuclear plant construction, e,
3 Independent monitoring of nuclear plant operations.
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Review of nuclear plant e=ployee training.
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Review of radiological emergency plans.
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Review and audit of radirtion protection.
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Investiga:icn a.nd review of operating events or incidents at TVA plants, t
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Receipt and investiga:ica of e=picyee cencerns about safety issues no 4
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adequately addressed by line me.nage:ent.
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7j The si,aff vill advise the General Manager and 3 card (through the Manager of g
A Health and Safety) of its cpinion as to whether nuclear plant operations i
should be continued where there is an issue concerning the i=nediate health a
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and safety of the public or e=ployees.
C S e responsibilities of the staff do not recuee in any respect the respcasi-E bility of o-her 'NA organi:stiens in -he ongoing licensing, design, construc-Q
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tion, operatica, and scnitoring of nuclear plants for safe operation.
tt staff's purpose vill be to review probless and questions, and to provide an 3
independent check on nuclear safety pc'.icies and their implementation.
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l Se staff vill consist of senicr TVA staff members expert in various aspects of nuclear plant desig., const:;etion, and operatica.
It may call upon cen-E sultants as nee-ssary.
Resu~.:s of reviews and recc=nendations vill be
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Periodic l3 reported to the Board through the F.anager of Health and Safety.
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=eetings with the TVA Board vill be scheduled by the Manager of Heal.h and m
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Safety to advise on the adequacy of the overall nuclear safety program, 3e e,
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Plant Oterations and Staffing
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.g 14 Nature of the Issue and Current Situatics :
- l "he Divisien of Power Production is responsible for operation of all TVA The Nuclear
.1 power generati'n facilities--nuclear, fossil, and hydro.
t Generation Branch is one branch vithin the division.
The fundamental
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organi::ation and =anagement of that division have not changed since TVA 5
instituted its nuclear power program. The nuclear program has unique needs which =ust be dealt with in a nontraditional way, so that nuclear safety receives additienal emphasis.
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'ecc =endatiens:
I, TVA vill establish a new Division of Nuclear Generation within the Office of l l Power, to renove nuclear genera.icn frc fossil and hydro 6eneration manage-i and increase the nuclear progres's access to op manage =ent.
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L "his new division vill provide several opportunities to increase the emphasis l
I on safety through staffing and mar.agement controls, which provide the =ost direct = cans for ':"/A to ensure the safety of its nuclear plants, qualifica-tien requirenents and co=pensation of nuclear plant personnel vill be adjusted to attract and naintain a highly qualified operating staff so that these vill 6
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A detailed 6
s discussion on operator selection snd training is in Section II.
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Additional =anagement positions vill be added for better coverage on all o
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shifts at operating plants, and additicnal engineering and =enagement personnel r
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will be required to have training equivalent to that required for a senior
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reactor operator license in order to better understand the operating systems.
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A unifer=, computer-based nuclear plant doeuront control syste= for all plant
..t, syste=s a d ec penents vill be established which vill provide c.ll levels of
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plant supervision with 12:ediate access to infor=a. ion necessary for work r.
a planning and sanagement. This sys,e= vill be i=ple ented at 3rowns Fer./,
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Sequoyah, 'a'atts 3ar, and 3ellefonte Kuclear ple.nts within one year.
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A complete, cc=puter-based nuclear plant =anagement infor=ation syste= vill v.
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i be provided in each plant which vill contain informatien such as equipment h
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history records for essential safety ecspenents, =aintenance requests fer all ec=penents, and radiation exposure records for plant employees and areas.
This vill help provide an early varning systen for potential safety problems.
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A plant services section vill be established in each nuclear plan to canage s
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this systen, perform planning and scheduling functicas, and reliev plant section supervisers of reutine administrative duties.
This vill enhance plant relistility, availability, and nuclear safety and provide the plant a
staff with an integrated, au:cmated syste for =anaging the plant business.
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1, Several of these syste=s vill be placed a. 3rowns Fer:/ and Sequoyah inmediately.
The entire operational support syste= vill be in place at t.ll nucler.r plants by spring '980.
A similar system vill be designed for the Nuclear Generation central office to be compatible with the nuclear plants.
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Eneineering Desi n Staffine a
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..ature of the Issue and Curient Status:
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WA's design nuclear safety engineering staff has a key role in identifying l'
f and resolving potential safety problems during the detail design of WA's l'
nuclear ple.nts. This requires very experienced engineers in syste=s analysis A
and interaction. With the size of the WA nuclee.r progra=, this func-ion j j, F
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needs to be expanded and reorganized for greater =anage ent emphe. sis on nuclee.r
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safety.
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The Divisicn of Engineering Oesign vill strengthen its nuclear engineering E
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scie,y activi.ies by separating the approprie. e nuclear engineering activities
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a..d forming a new Nuclear Engineeri.g 3 ranch.
S.is branch vill he.e responsi-I h
bility fcr overall nuclea: safety of WA's nuclear plant design.
Specific e r,iven to =aintaining a highly cc=petent design staff to
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evduate safety issues.
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nifferin-staff oeniens l-e;[
- ature of the Issue:
1 Every professional and technical e=ployee should be able to have his or
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her professicnal or technical opinion heard at a high-manage =en: level,
.s vnen ' ne employee considers the issue significant and the opinien differs
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fru a =anage ent decision.
.i*:j Ourren: Situation:
TIA employees may nake suggestions and may infor= ally express differing l
i cpinions to =anasenent. However, there has been a need for clear expression j.
by top msnagenent that differing views are, in fact, encouraged.
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TIA -ill establish internal proc _dures which vill assure ';he expression of n'.
differing professional or technical opinions concerning substantive atters 1j that nay have potential impact en public health or salsty.
kk TIA recognir.es the value of differing views concerning substantive public 3
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health and safety =atters.
The agency's management believes that every It -
l responsible opinica is valuable and intends to assure that such views are i
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heard and appropriately censidered in all decisiontaking processes.
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encourages perceptien and voluntary expression of safety concerns associa ed I
with the design, construction, and operation of TVA nuclear plants. This policy vill be cec =unicated to all employees to encourage their cooperation a d 3
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Appropriate incentives and prctective d d to assure participation without fear of recri=ina-
=easures vill be inclu e P
g tion or retribution.-
,la 3-If-An employee may bring a concern to the Nuclear Safety Review Staff if it jg is not resolved by management.
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OFI?ATCP.SIlICTION, TRAINI:G, A O STAFF ::G
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't "atu e of the Issue:
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Tne availability of qualified and experienced operating personnel is one of
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Selection,
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the key factors in the safe operation of nuclear power plants.
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- t. raining procedures, anti training facilities =ust be adequate to provide
- 2. 5 Operator perfornance during the Three-j highly trained, cc=petent operators.
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- lle Island accident de=onstrated a need to review closely TVA's operator
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selection and training.
'i Cu ren: Situatics:
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Selection and Training i.
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7..e selection,and training of "'VA nuclear plant operators is a rigorous
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.i A =ini=u= of two and one-half years d
process, extending over severs.:. years.
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the time a student opera.or enters the train'ing
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of training is required fro P
A =inimu= of five years of h
pregrs= until he or she can operate a ree.ctor.
training and experience is needed before an operator can hold the tcp shift
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d Tne typical TVA shift engineer he.s 8 to 10 years' train-h engineer position.
p ing and experience.
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N Candidates fcr WA's Nuclear Studen Generating Plant Operator pregra= are 3
e required to he high school graduates and take the Oeneral Aptitude Test Trainees spend lo =enths in cle.ssrocn training at TVA's Power 3tc.tery.
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? reduction Orrining Center with formal course work in physics, mathematics, h
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chemistry, electrictl and instrument theory, and equip =ent design and opera-h h
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3efore advancement to the lowest rank of assistant unit operator, the student f.
,,6 devote six months to observation and hands-on experience in the nuclear
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=us Plant.
Before progressing to licensed reactor operator, the student must
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b spend a minimum of eight additional =enths as an assistant unit operator and
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si=u'ators at
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undergo training on sophisticated, cc=puterized centrol rec t
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.b the 3rcuns Ferry Huclear Plant and the Sec,uoyah and k'atts Bar Nuclear Plants.
ere Tne si=ulatorFoffer realistic training for both normal and emergency plan tey! -
6~l Additional simulators vill be added for TVA's other nuclear conditions.
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plants.
l A key feature of the si=ulator training is testing of trainees on ore than W
~his includes i
'00 energency events that night occur at an operating plant.
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V events such as open relief valves, loss of coolant accidents, and failure of I
4 secause of this in-dep:n training, I
varicus safe:y sys ens er ec=penents.
the operator not cnly learns to respcnd to these events, but also develops t
a fundamental knowledge of the system behavior that assists in assessing a bread rcnge of potential events.
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luring this progression, the operator not.only must pass the. Nuclear
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3egulatory C---4 ssion exa:inatien but also must successfully cenplete both
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cral a.nd vritten '"'VA examinations. The TVA examination includes non-nuclear, p
ij talance-of-plant equipment operation as well as reactor operation.
4r The licensed reactor operator and senior reactor operator =ust spend t o
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veeks a year at the Training Center undergoing requalification training.
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"he majority of this training utili es the nuclear plant si=ulators.
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f Operator trainees and operators undergo psychological testing at several 1
!k s ages in their careers. 1,pplicants for the operator training progra: are
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screened for medically disquCifying fr.c, ors. Testing is also done before
.I the operator's first licensing exa ine. ion and every two years thereafter.
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Staffing i
- /.inimu= staffing by licensed ope-cors on each shift at Browns Ferry iuclear i
1 Plant is indica ed by the folleving table:
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e Units in 0:eratien t:
i*C-Shif: ?csitien One Cvo Tnree M e of 'i?C License
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Shift Ingineer 1-1 1
Senior Reactor Operater u.
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Assis an: Shift 1
2 3
Senier Reactor Operator f
Insineer L
'Jni: Operator 2
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Feactor operator a
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.j Eoc Operater)
I.ta ro Ceveral disciplines are represented in :$.e ::upport staff cutside the centrol roc = cn each chift.
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The table shows that in addition to an NRO licensed reactor operator assic
.g to each unit and a licensed senior reactor operator in charge of the entire ij
. 1, 7/A requires an NRC licensed senior reactor operator on each shift
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- plant, for each operating unit. This 's not an NRO requirenent.
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- s. i,k sub-7..is review of operator selection, training, and staffing shows that s an.ial i=provements can be =ade.
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.t There is no provision for ge tiEg a tes= of sicilled professionals to assist
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in the control roon at a plant in the event of an accident, although an emergency control center is established in Chattanooga to coordinate respenses
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.*i tt i s, ll Fece nendations:
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I T/A vill revise its operator selection and training by inposing stringent
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intelligence testing, giving operators the equivalent of a college education
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'l through an intensive training progrn=, providing good pay during training, er f and paying sa' aries to operators that vill attract the best people into the i
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Selection and Training N
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- ntelligence vill be stressed as one of the nest inportant characteristics Intelligence distinguishes those who have of superior reactor operators.
nerely nenori:ed a series of discrete nanual operations frca those who can E
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think.hrough a problem and conceptuali:e solutions based on a funda=e'ntal
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understanding of possible contingencies.
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A reliable intelligence test vill be included in the selection screenin~g
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The General Aptitude Test Battery currently used predicts only progra=.
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academic performance while in training. An intelligence test measures
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both academic aptitude and = ore funda= ental ability. Intelligence test
.g scores and instructor evaluations of behavior while operating reactor si=u-1
-f lators during training are the best predictors of actual control roc =
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perfor=ance.
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Training This d
S.e student operator training program vill be increased to 26 months.
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jr vill per=it a more in-depth approach to academic subjects and vill per=it each student to receive more hands-on experience in syste= operation before r, -
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assu=ing the responsibility of a skilled operator.
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Tne prolonged for=al classroom training, the reactor si=ulator experience, 3
[J and on-the-job training vill provide the equivalent of a course of study A'
ji leading to a technical degree at the college level. TVA vill pursue a FI long-range goal of having the operator training program accredited as a IN q
program cu1=inating in a recognized acade=ie degree or certification.
Accreditation is i=portant to e=phasize the rigorous course of stuiy required to become an operator; recogni:e the status of power operations as a profes-
- ional discipline, and enhance the ability to attract highly qualifi~ed and I
i r--
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notitated candidates for the progra=, suited to the significant respcnsibilities t
([
..ey are asked to assu=e.
. 6:
I A nere rigorous training progra vill be established for those selected to
- {.
.' I '.
advance to the Unit Operator (reactor cperator) level. This vill require
_..e experience in plant operation with advanced training in electrical syste= operation; reactor theory; nor=al and e=ergency plant operating pro-t
-i !
cedres; a.i the interrelationships of te=perature, pressure, and saturation The time-in-grade require =ents for assistant
'{
points in the steam cycle.
cperators vill be increased by six =enths, frc= 8 =cnths to lh =enths,
-i r.i to acco==edate these additional training and experience require =ents.
- l
[-
? resent requalificatica training for licensed rettetor operators and reactor I!
operator candidates vill.loe expanded to include a unique si=ulator training
- .r.
This vill pernit broader training in de. ice for each ty,,e of "VA reactor.
[,,.
Additional class-t responding to nuclear plant abnormali-ies and e.ccidents.
roen training vill be required to cover nev =aterial being added to the
.q M t t.
l training progra=.
Retesting vill be required.
vill be required to take
,2 E_
All operators and students in the training progra:
the basic intelligence test once it star.s being used in the selection process.
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~
~;ernor salaries vill be increased to reflect the nore rigorous training and t
4 re:esting, and to reflect thc profess:.onal status of reactor operators.
- '.nn7 of the above reconnendations involve labor-ca.agenent relations and vill g
f he hcndled accordingly.
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3.
Staffing
.[
. ti.
- 8' I t-In addition to the personnel available at each plant, a proper response to 1
and more u accident may also require getting additional staff to the plant
- , [.
effective cocannications between the plant and TVA experts in Chattanooga
~.1 ;
and T.noxville.
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I ert anev Resnonse Team of skilled professicnals trained to provide addi-
- t.
O."A ill establish a tea:
tienal help and expertise in the centrol roo= of plants undergoing a. accident.
Tnese people vill be particu'.arly valuable in ec=municating with engineers
- n i
)1 in yr.cxville regarding specific problems and needs at the plant.
..l M.
A seven-passenger, two-pilot helicopter vill be be. sed in Chattancoga on
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- w.,
'I' 2 -hour stan6.by equipped with night and foul-weather flyf.ng eq. lip =ent to r
.i' i
quickly transport a tes: to the emergency site.
I,.I All nuclear plants vill be equipped with helicopter-landing facilities.
n ii
.it A ske eton duty tea vill be on 2L-hour call.
Each =e=ber, including the 1
'I Tne skeleton tes: can i _
pilot, vill be equipped with radio paging devices.
-g i
,vithin four hours /by the
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be cuickly located and dispatched to the scene'On...._.../
Civision of.uclear Gener:. tion Energency Director, while a = ore specialized t
T f -
tes: is assembled.
L 6
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4.
Oc sunications r
2e ?.cciologicni Energency Plan provides for establishing a Central Energency P
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t a
one of the c:.:r:1 Cen:er in Chat:anoega, at the cu:se. of an e=ergency at An area in the Edney Building is currently used as the CICC.
~. :leir plants.
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~ Tia vill install a nev control center in the Chattanooga office complex for 7.*A offices to be conpleted in the early 1960's.
This vill include the latest con =unications equip =ent for both internal TVA and externe.1 cc==unica-e-
tier.s, with redundant equipnent for cc=nunicating with each nucle ar plant,
?
i An emergency coc=unications center vill also be established in the TVA a
l office cenplex in Knoxville which vill ' rovide full access to all personnel p
i.
and infc rmation in the Kncxville area. Upon notification of an accident, team frcm the Division of F.ngineering Design vill be asse= bled
- a support ast,ist the plant and the emergency anter in Chattanooga.
0;erator selection, training, and plan staffing vill be independently soni-I tered and reviewed by the new Nuclear Safety Review Staff 6
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E RADIA~ ION STAN)ARDS FOR EM?1.OYEES III.
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- - !:;I Nature of the Issue:
- i J.
Exposure of e=ployees to radiation while working in TVA nuclear plants
't is of vital concern to TVA.
1 udent and safe operation of these facilities t
l'i demands that M1 radiation exposures to e= ploy = 2s be kept as low as reason-
'j ably achievable.
Current Situation:
i'.,
T.*A i= soc'". a li=itation in 1977 for its e=ployees which is substantially h.'
- ore stringent than that required by the NRC.
Under the current TVA limitation,
~VA a=ployee is permitted to receive a dose in any one year greater than no 1
the NRC standard permits an employee under certain cir-i!
5 Re=.
By contrast, 4
-t
'i cu= stances to receive up to 12 Ram annually. TVA makes a strong effort to 1
~
7; event an e=ployee from receiving the full 5 Ram, and no employee has ever
-t B
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reached the TVA standard of 5 Rem per year.
.?
~VA has a for=al program to keep radiation exposures to employees as low
- 'i I
as reasotably achievable.
This program includes:
1.
Assura: ce tha t a.uipment and f acilities are carefully designed to f-
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reduce exposures.
2.
Use o f good adiation erotection standards in planning.
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Use of proper equipment b: qualified, well-trained personnel.
1 4
Use of a for=al e=ployee suggestion plan which encourages all e=ployees to l.'
!.'i, -
taccc=end ways of doing tasks to reduce radiation exposures.
j The recent reorganization of TVA gives the Director of Occupational Health I'j i
et- ;.
and Safety the responsibility for assuring tha: e=ployees are protected
-i a.
The director establishes 6,
job hazards, including radiation exposure.
fro:
standards and conducts independent co=pliance audits to assure that manage-to
- w. e need to =ini=1:e exposure.
This k
=ent and e=ployees re=ain setsitiv new organization will significantly i= prove the effectiveness of =easures to control and reduce e=ployee exposures and ccncentrate attention on occupational t
I
-l safety issues.
~
-(. {
Reco==endation:
TVA will li=it exposures of TVA e=ployees to 4 Re= per year, a reduction a
of 20 percent fro = the current TVA limit, and below any standard being
.f l considered by NRC.
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NUC'ZAR PLANT DESIGN AND O?ER.ATION IV.
I I-The accident at Three Mile Island on March 28, 1979, began with a =alfunction that =ight be expected during normal operation of a nuclear power plant--
)
a loss of feedwater flov, But a series of other evence including a stuck-open relief valve and subsequent operator actions quickly turned this
..j I
rather coccon operating =alfunction into a much = ore serious proble=.
'i.
'I The accident raised a number of spec'.fic concerns about. tuclear plant design and operating procedures that should be satisfied in order to assure that TVA's nuclear plants are designed and operated in the safes: possible =anner.
.s i
should have been open
- )
At Taree Mile Island, auxiliary feedwater valves that
]
were closed, a fact that adequate syste= status enitoring equip =ent would
.I.
The plant operators, raced with an accident that f
- r. ore clearly disclose.
had not been adequately described in their training, were forced to rely on instruments which did not give a true picture of what was happening inside,
t-
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the reactor.
tv The operators had no instruments to indicate the level of water inside 6
6 the reactor vessel. There was no =eans for =easuring the water level in t
There was no way to sa=ple I
N the basement o f the contain=ent building.
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To further compound the proble=,
- f radioactivity levels inside containment.
l pu=ps were activated to remove radioactive water from the contain=ent build-
- I ~
ing to storage tanks in the auxiliary building, an action which ultimately.
led to the release of radioactivity to the environment.
~
. - i
. L The ability to communicate internally and with the public was inadequate t
following the release of radioactivity offsite.
A better means of providing information to the public concerning status of the plant, infor=ation on i
i t.dioactive releases, and other-rital matters in a timely and efficient way f.
is, required.
l Other questions arose. During recovery from an accident, how do you vent the reactor system so hydrogen c'an be released and the system refilled with cooling water? How can information displays be i= proved to per=it s
l the operator to deal with '. wider range of accident conditions?
l l
TVA had addressed cany of these issues prior to Three Mile Island. TVA has already considered problems of:
1.
the operator knowing water level inside the containment building (not f
i the reactor itself),
'.i 1
2.
capability to adequately Jtspose of hydrogen inside containment, I
(
2.
adequacy o f the feedwater syste=, and
[
4.
the availability of the pressuri:er heater following an accident.
l
=
These problems have all been previously considered by TVA and resolved by i
No further changes design features some of.which are unique to TVA plants.
j t
The appendix details actions which TVA i
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are needed to satisfy these concerns.
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4 1-
'I
' t
. i taken on these ite=s, and reflects that TVA has long been involved in nuclear
- 7
- over and has never hestrated to exercise independent judg=ent for safety in t
t the design of our plants over and above the legal requirements.
I t-j In fact, TVA has been actively involved with nuclear power since the early 1
, l 1950's, when a nu=ber of engineers were assigned to ongoing nuclear develop-I l
=ent and co==ercial progra=s at both U.S. and foreign ins tallations.
Coincidental with TVA's first nuclear power ce==1t=ent, 3rowns Ferry Nuclear
~ $
?lant in 1966, =any of these engineers returned to TVA engineering and operation f
organitations to provide the nucleus for TVA's staf f.
This experience has 1
i assisted in the developr. ant of =any featu::es to i= prove nuclear plant safety.
,f' The appendix identifies a nu=ber of these.
,s
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T. eve r th ele s s, the Three Mile Island accident did reveal additional =atters were TVA plant design could be further i= proved. Work by the TVA staf f points t
'[
out that because of funda= ental design differences between boiling water i
reactors and pressurited water reactors, the Three Mile Irland sequence of i
Ii events ccnnot be duplicated at 3rowns Ferry, t
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f f-Gar fi s e concern was the plant already in operation--Browns Ferry--which is a boiling water reactor (BWR), as contrasted to the Three Mile Island Plant t
t vnich is a pressurized water reactor (PWR).*
Car next =ost i==ediate concerns were Sequoyah and Watts Bar, which are ai :st co=pleted.
Several features of the Sequoyah and Watts Bar plants f.
- tith help preclude and =itigate an event si=ilar to that at Three Mile 3; nd are:
1.
- ore water in the pri=ary heat sink (the stea= generators),
anticipatory signals to trip the reactor following secondary syste =alfunctions, 3.
- ore redundany' by having four stesa generators (Three Mile Island has two) icr a pri=ary heat sink, i
additional anticipatory signals to the oackup water supply (auxiliary
'7 3
feedwater syste=) for the stea= generators, 5%R reactor systa=s are direct cycle t, do not have stea= generators.
I r 17R's, such as TVA's Browns Ferry Nuclear Plant, loss of feedvater will i
-: ip and isolate the reactor vessel, and =akeup water is provided by either l-
?f two high-pressure injection systa=s.
In the unlikely event of both O'?r.-pressure injection systa=s f ailing, the reactor =ay be depressurized J
~
?? tenting stea= through =ultiple relief valves to a large stea= condensing Ecol (corus) in order that one of several diverse low-pressure injecticn
' ' :ely in this condition with no adverse effects.
573 tens may be placed into service.
The reactor =ay be =aintained indefi-i h ?%R plants, the stea= generators serve as the pri=ary reactor heat sinks.
' 'erefere, loss of =ain fe'iwater and auxiliary feedwater deprives the reactor t
Cf its cain heat re: oval path.
Sequoyah and Watts 3ar Nuclear Plants are j
.;fessurized water reactors, with a dif farent vendor (Westinghouse) than m.
5 i
Tie Mile Island (Babcock and Wilcox). As in all TVA plants, the secondary.
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?Stens were designed by TVA.
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5.
high reliability valves with redundant pcwer sources for the
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auxiliary feedwater systa=, and
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prinary containment isolatien upon initiation of high-pressure
.e safety injection.
j
.'l *. Procedures at Sequoyah and k'stes Bar ensure:
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7l,
1.
proper alignment and availability of critical systens before e
reactor startup, 2.
adequate operating instructions and training to ensure operator s
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,- '[
recognition of, and response to, abnor=al conditions, such as loss oof heat sink, pri=ary systes depressurization, and natural I
circulation cooling, i -
...J3 ap;;opriate conditions to prevent accidentally pumping radioactive s
~
. ;l veter out of primary containment, and
' 4.
centrol of hydrogen inside contair;nent.
In view of these features, we believe Browns Terry Nuclear plant can continue
- t
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I tc eparate, and fuel can be loaded into Sequoyah Nuclear Plant and operation i
. I cennented on the basis of the current design of the plant.
i i
I
!?A has felt it essential, however, to review all TVA nuclear plants even
,g T-
)l beycnd the ongoing activities of NRC, the vendors, and TVA's continued i
h licensing activities with NRC.
f.4e This section of the report discusses a number of design concer=s, and TVA
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Tetennendations for sction to inprove safety.
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. T-e desii;n issues considered are:
w; Status sonitoring of =ain line process co=ponents r
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- 2.
?rd=ary system venting
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?ri=ary system water level conitoring Advanced core monitoring for normal operation 4.
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/.:l. 5.
Containment isolation Sa=pling and radiation monitoring systems I ~ 6.
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7.
Stuck open pressurizer relief valves.
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For the reader's convenience, a sf=plified diagrs= of a typical pressur-1
- T 1:ei water reactor is attached.
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E N.
Desien Chances to Enhance Safety A.
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The following design changes have been under consideration by TVA for so=a
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time and vill be implemented as indicated.
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>*I 1.
Status Monitoring of Main Line Process Cocoonents
'g I'h Nature of the Issue:
plant Carcain valves in the feedwater syster y
were closed for several minutes during the accident before the operator l.
This situation highlighted became aware of the condition and corrected it.
,{
a need for better status monitoring and infor=ation display for the plant E'
' v!.
operators.
TVA has been acutely aware of this need for several years.
i O
?,
,9 safety equip =ent is ready r.
The operator of a nuclear plant must be sure that J
it To assist the operator, for operatior when it is required for e=ergencies.
j equip =ent for monitoring the status of plant syste=s should be provided.
uj
[i should provide a display of infor=ation in the =ain control This ecuip=ent i
.?
roo= which keeps the operator informed of the status of plant safety syste=s.
Current Situation:
The desigt. ef all TVA nuclear plants except Browns Ferry already includes are used to =enitor the process status infor=ation
-digital computers that These computers use television monitor-type l
fro = plant safety syste=s.
h disp *ays to provide syste= flow diagrams t'o show the status of = sin line 4
The use of computer technology makes it possible
-S safety syste= components.
b to provide a great deal of data on concise displays to the plant operator.
l
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4 5
- . For exa=ple, the status =onitoring systa= at Sequoyah =onitors approximately 600 status points in each reactor unit. The operator is warr.ad of an abnor=al b
condition by safety systa= status lights, abnormal indications on the TV i
)
monitor diagrams, and by alarm messages on the computer printout.
-. e.
- L The syste= automatically infor=s the plant operator of the time remaining i
{.
to restore a safety sys e= to service. The computer also determines if
= ore than one plant safety system is affected by a single component being JL
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.I bypassed or inoperative.
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-; f Reco==endation:
.i TVA will add more status monitoring points to monitor additional cocponents t
'[
on those safety systems that are required to operate i==ediately after an
.i accident.
ThfE additional conitoring should provide further assurance the ficw paths for e=ergency core cooling will be available, if needed.
that i
"l At TVA's operating nuclear power plant, Browns Ferry, TVA will consider
- I isl those design i= prove =ents which are feasible to implement on an operating and that will enhante the operator's ability to quickly determine the plant status of each safety syste=,
.i each plant will be accomplished on the following ti=etable:
Improve =ents at the
'I pro' posed improvements will be complaced at 3rtwns Ferry refueling outage after July 1, 1981 e
next the first L'
the expansion will be completed at Sequoyth
)
'43:c.; 3:r
)
refueling outage F
f hellefonte
)
the expansion will be completed by issue of
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Mttesville
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I+ip?s Send )
operating license '
ici'.cw Creek )
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2.
Primarv Svs:e= Venting t
E Nature of the Issue:
If a s=all break <.r leak occurs in the pri=ary reactor coolan: system h
j which results in a net loss of coolant, gases will accu =ula:e in a void The the top of the reactor vessel and other high poin:s in the piping.
at
- 3 voids will be filled with steam and/or noncondensible gases (probably
,[
hydrogen). -If the accumulation is suf ficien:1y large, the wa'ter level in
" the reactor vessel can become so low : hat circulation of water is i= paired.
i Venting of these gases from the reactor vessel, pressurizer, and high points re= oval and aiding in :he piping =ay be i=por: ant to assuring continued hea:
in refilling the primary system f ollowing certain types of acciden:s, such as a loss of coolant accident from a s:uck-open relief valve or a very s=all 4
(
pipe break.
}[
Current Situatien:
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?
considered to be of concern before if Stec= and gas accumulations were no:
I the question is being reinves: iga:ed
- he Three Mile Island accident, but TVA does not now have pri=ary sys:e=
I by :he NRC and reactor suppliers.
T.
s ven:ing capabili:y.
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Rec:==encation:
the reactor pressure vessel, the TVA will provide the capability to vent pressurizer, and high points in the primary system piping of each pressur-l ized water reactor plant as a precautionary measure and as an extra margin The detailed of safety, even if it does not become an NRC requirement.
. ii design will vary from plant to plant since each nuclear steam supply system
.,?,
,]
vendors' pri=ary system designs are different. However, the general venting i :
all venting operations will be conducted by the
,[
capability will provide that 1[p.
operator from the control room, and the vent system will be designed in l
I' acccrdance with standard safety system design practices.
- [
.)
These improvements will be made as follows:
by end of second refueling h
'?
Sequoyah Unit 1 l'
m.
(j Sequoyah Unic 2
)
by end of first refueling
- atts 3ar Units 1 anc, 2 )
before operation 5el*efonte and Yellow Creek f
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3.
Primary Svstem Water Level Monitoring Nature of the Issue:
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It is essential to maintain sufficient wa:er in :he reactor vessel to
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keep the reactor core adequately covered during and after loss of coolant
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accidents, including accidents such as those caused by a s=all pipe break
~
1
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or stuck-open relief valve.
It also is i=porrant that the reactor operator 5
L.
be aware if water level in the reactor vessel is decreasing.
- J.
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Current situation:
f Tnere'are no indicators of reacto"r vessel water level available to the Before ch' operator in the control room for pressurized water reactors.
I
(
nree Mile Island accident, the slow loss of water level had not generally seen perceived as a proble=.
Rece==endation:
this need for bet:er information concerning the level of fluid in I.
To =eet L
f the reactor pressure vessel, TVA will proceed with the design tad installa-E tion of level measure =ent arrange =ents for all of its Pressuriced Water e
{-
Reactor plants.
Such arrange =ents will provide redundan: ins:ru=en:s that S
will =easure water level in the reae:or vessel down to the botto= of :he L.
T hot leg piping. This =easurement will be adequate to detect for:ation and v.
It will grcwth of a large s:aa= and/or ges' bubble in the reae:or vessel.
he sufficiently accura:e to provide guidance for the plant operators during g
certain abnor=al situations such as a very small pipe break or stuck-open f
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I relief valve resulting in los" f Coolant. Level indication is already i
l provided for boiling water :4.ctor plan:s, including Browns Ferry.
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,ater level indicator will alleviate concerns A reactor pressure ve"
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abou: misleading pressuri:er level indications which might develop during
( fj,-
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? 3 such abnormal si:uations.
Q. '.
Design of a level indication system will be completed for Sequoyah and Y
Wat:s Bar plant-by Nove=ber 1979.
If NRC approves the TVA design early
't i l
.. j in 1980, the 1: stalla: ion will be completed as follows:
ti (r
Sequoyah Unit 1 by end of firs: refueling outage prior to initial operation a
All other pressurized water reactors
..'s di 1{
Un:11 direc: reactor vessel level indication is provided for Sequoyah
.; i 1, safe opera:1on is permissible because safety injection will be j l Uni:
'I
{j ini:iated by low pressurizer pressure signals regardless of pressurizer i
level. Applicable ins: ructions will also require manual initia: ion at
.l
- he same actua: ion setpoints.
. i
, l, Opera:ing instructions and training will also ensure tha: :he operators i
do not override automatic operations of the engineered safety fea:ures When continued opera: ion of the ex:ep: under certain circums:ances.
t ca;incered saic:y feo:ures will result in unsafe plant conditions, oper-f.
Iters cay stop operation.
When the plant is clearly in a stable controlled i:
5t;ts and engineered safeguards are no lenger required, they nay be stopped.
t
'1 a ini:lon, the detailed instructions anc implementction will be carefully
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f*Vicwec by :;RC before reactor operation is.per=issible.
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i 4.
Advanced Core Monitoring for Noreal Oceration
$'j
.e Situation:
Nature of the Issue and Current 1
A large a=ount of information in the process computer of the Browns Ferry 0
1 j,
II Nuclear ?lant must be assimilated and assessed by the operator during both
- ['
This information is not readily
'I normal operation and anticipated transients.
?['I Because of fundamental design differences, this available in a usable form.
jE in pressurized water reactor plants.
l H
same problem does not exist
) !
I a
necensendation:
lh An adva'nced core monitoring system will be added to assist the operator at
' l:
3rowr.s Ferry Nuclear Plant during both normal and abnormal operations.
' n i
t.
This system will assimilate information about the status of the reactor f
information'on core power n.
r-It will provide in a more useful format i
core.
thermal limits, water level, flow distribution, t
distribution, coolant This infor=ation will be dis-water tenperature, pressure, and quality.
This played in a digested form on a video screen in th, control roo=.
d is included in the design of the Hartsville and Phipps 3en bw equipr.ent Browns Ferry within i
It will be added to all units at 1
E Nuclear Plants.
.-p one year.
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32-5.
Containment Isolation 5
Na:ure of the Issue:
j Nuclear plants are provided with a tight containment building which com-
' b. "
ple:ely encloses the reactor and reactor equipment. Its purpose is to
- L:
prevent escape to :he environment of any radioactivity which =ight be
't.
d; al
- l. i released from the reactor system following an accident.
This requires all openings which might provide a way for radioactivity to escape j
that
$1 are ou:ocacically closed (containment isolation) following an accident.
?I II This closure takes place as a result of accident conditions being detected
- t
- f however, radioac:ivity
.:y ins:ruments.
During the Three Mile Island accident,
.}
,j
- (
strue:ure into the environ =en:, indica:ing 11 did escape chrough :he contain=ent
- hat a review of containment isolation should be made.
n Curren: Si:uation:
TVA has reviewed the pri=ary containment isolation systes design features of its operating nuclear plant (3rowns Ferry) and plants under construction.
f
- j
- n essence, every piping system through the containment building wall is
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.i is sealed with double-gasketed t
previded with two separate barriers (i.e., it
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Isolation valves flanges or has two isolation valves in series in the line).
l of certain abnor=al condi-in series are closed automatically in the event I
The valves in series are operated by separate
- L1ns inside the con:sinment.
L insopendent power supplies for redundancy.
. b' The valves and the con:ainment as a whole are tested at high pressure
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ICre Operation and periodically thereaf:er to verify l_*ak tightness.
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E.I For all~TVA plants, the con:ain=ent automatically isolates on high pressure r
inside containment. The high pressure is caused by the release of steam
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and gases into the con:ainment from the reactor.
1 At all plan:s except Bellefence, the containment also isolates when an accident signal is received to operate emergency reactor core cooling v.j
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systems.
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A: all plants except Browns Ferry, if the signal that initiated e=ergency o
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core cooling returns to normal and control circui:s are reset by :he plant operator, the contain=ent remains isolated.
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~. t i.ecc-endations:
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,I A: 3eliefonte, changes will be made to ensure containment isolation when
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an accident signal is received to operate emergency core cooling systa=s.
re=ains I
A: Irevns Ferry, changes will be made to ensure the containmen i
isola:ed if :he signal that initia:ed e ergency core cooling returns to l[
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ner al and the con:rol circuits are reset to nor:.al by :he plant opera:or.
l' l'n:i'. :hese changes are =ade, operating procedures will ensure containmen:
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i.<cla : ion.
-t all. plan:s, TVA will add detectors which automatically close the lines t
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.a V ich carry radioactive wa:er from the con:ain=ent building (which houses t
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C ena reae:or) to the auxiliary building, when high radiation is detec:ed.
tf drain.
- 7. a e lines go to the floor drain sump and the reactor coolant (k
i' :entur'c will prevent accidentally pumping highly radioac:ive water s.
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24ide containment, and thus preserve con:ainment isolation.
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- The schedule for this work is as follows:
r first possible refueling outage upon receipt 3rowns Terry
)
Sequoyah 1
)
of hardware
?I Sequoyah 2
)
acts Bar
)
3ellefonte
)
prior to startup
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'dartsville
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.I Yallow Creek
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Sampling and Radiation Monitorina Svstems Nature of the Issue:
1 Following an accident in which fuel damage occurs, the primary system hi
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vater and water and air in the containment may be highly radioactive.
- l The sampling and radiation monitoring system must provide information on radioactivity levels and other information necessary for the operator to
' l-understand the postaccident plant conditions.
1
.i The scmpling system should provide the capability for obtaining post-accident samples of (1) reactor
- coolant, (2) water in the containment sump i
4 or residual heat removal system, and (3) containment atmosphere. These
- i samples should be obtal,nable with acceptable radiation exposure to the n.
' l a?crator.
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,1 Current Situation:
There are no NRC requirements to provide sampling capability following g.t t
accident. however, i= proved designs can provide sampling stations which ar2 accessible during a degraded accident condition
- vithout subjecting the c?erator to excessive exposure.
1, j
T:e radiation monitoring system should also be capable of monitoring the 1i iation levels inside containment with a degraded accident situation.
3 d is not a current requirement, but it can he accomplished.
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1 mnition described in NRC Document No. TID 14544 I
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?.ece mendation:
TVA will place a radiation monitor (s) on the residual heat removal 7,;.
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This will provide monitoring under degraded accident G
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p iping system.
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removal system is pumping fro = the conditions when the residual heat
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containment sump, il TVA vill place a radiation monitor outside containment which is d
2.
.i capable of conitoring the radiation levels inside the containment ar
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'I degraded accident conditions.
A monitor now exists which monitors t
71'sit less severe conditions.
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VA will make provisions for sa=pling water from the reactor cooling il 3.
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- I system and the residual heat re= oval system for the degraded accident I
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- *I TVA will install new lines with connections to the existing gaseous 4
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radiation sampling system for use in sampling the containment atmos-f:
phare for the degraded accident conditions.
Sample lines will be routed to a shielded sampling station in an
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accessible area and provide for taking samples which could be removed i
offsite for analysis.
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These items will be accomplished on the following schedule:
i by end of first refueling outage I
Browns Ferry Units 1-3
)
Sequoyah Unit 1
)
after equipment becomes available by end of first refueling Sequoyah Unit 2
)
Watts Bar Units 1 and 2
)
l Bellefonte
)
N II3#I8V111"
)
before, operation
)
Phipps Bend
)
Yellow Creek
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i 7.
Stuck-Ouen Pressuri:er Relief Valve i
Nature of the Issue.
The pressurizer relief valves at Three Mile Island stuck in the open position and re=ained open for a long tine without the operator being aware of this fact. The f ailure of the operators to recognize that the
'1 valve was stuck in the open position and to close the block valve was a
=ajor contributing f actor to the damage that resulted. Valves of the type
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used at Three Mile Island have a record of poor perfor=ance; that is, they
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sc=etimes leak and there have been instances other than Three Mile Island where these valves have stuck'in the open position. This type of valve 1
i is so designed and constructed that it does not permit a highly reliable r
re.ote indication in the main control room to tell the operator if the
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j valve is open or closed.
i Current Status :
Valves provided for Sequoyah and Watts Bar are of a different type than i
those which failed open at Three Mile Island, and have a better perfor=ance i
I record. They are equipped with a reliable indication in the main control t
roos which will tell the operator whether the valve is open or closed. !n t
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addition T7A has provided five other separate indications in the control f
roca that the operator can use as further evidence that the valve is open L
h er closed. The Sequoyah and Watts Bar abnor=al operating instructions direct plant operators to utilize these indications to detect an open i
p ressurizer relluf valve. The operator is further instructed to close i
t Oh O
- q is determined to block valve and thereby isolate any relief valve that have f ailed to reclose af ter the pressure which caused the valve to open i
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If has been suf ficiently reduced.
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the pres-Because of unique plert operating requirenents at Bellefonte, surizer relief valves provided by the reactor supplier vill be similar to
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those provided for Three Mile Island.
include pressurizer relief valves, but Yellow Creek plant design does not
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' f-the staff is evaluating the need for such valves.
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?.ecos=endation:
7or Sequoyah and atts Sar, TVA vill emphasize the i=portance of timely e
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closure of the block valve in series with the relief valve as the principal v',.
Thr: presently
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precautionary =easure against a stuck-open relief valve.
f provided indications for detecting an open pressurizer relief valve are
- i
- l for the operator to make a prompt decision.
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sufficient 8,
?rior to operation of Bellefonte, TVA vill provide similar indications and operating instructions for detecting an open pressurizer relief valve.
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- hat relie.f valves are needed.
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Design Concerns Recuirine Further Studv f
Small Break !.oss of Coolant Accidents jj, q:
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Nature of Issue:
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3:eaks of large piping which cause a large and rapid loss of water from the reactor primary system have been analy:ed completely and carefully.
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'1 Much of the nuclear plaht safety equipment is designed specifically to Small
-ll protect the health and safety of the public from such accidents.
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piping breaks have also been analyzed but only recently has concern been expressed that this analysis had not been done adequately and that certain f
s undesirable things could happen,' such as formation of volds in the reactor
?if system, i= proper level indication in some designs, and possible loss of Y
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natural circulation cooling. This is essentially what happened at Three II, Mile Island because of the stuck open pressuri:ar relief valve, which had
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- l the same effect as a small pipe break.
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?!A recognized the potential problems with small pipe break accidents and
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expressed those concerns in a letter to Babcock and Wilcox in 1978 and has
...t discussions and
.f been attempting to resolve these concerns in subsequent
-;. y exchanges of correspondence. The accident at Three Mile Island confirmed i s.-
T/A's concerns.
Carrent Situation:
The nature and consequences of small break loss of coolant accidents is now fully recogni:cd in the industry and Nuclear Regulatory Commission.
Three Mile Island has resulted in a much better understanding of this
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LO-accident and how it can be detected and handled without unacceptable results. Nuclear Regulatory Commission bulletins and other information have been sent to owners and to reactor vendors which contain require-ments on how to deal with such accidents as well as requiring written
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commitments and requests for information to ensure that each pressurized
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water reactor operator can safely operate its plants. These precautions permit the conclusion that pressurized water reactors can be operated
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with no undue risk to the health and safety of the public.
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L ig For the long term, there is a need for a more complete understanding of L
P t1 this kind of accident to determine if additional design and operating f eatures will provide even greater assurance that no unacceptable con-sequences result from such accidents.
Several features such as primary system ventin'g and pri=ary system level indication will provide greater assurance, but other features =ay be desirable.
Reco=cendations:
TVA will; Require nuclear steam supply system vendors to provide further analysis 1.
of such accidents for TVA plants.
Encourage NRC to develop a better understanding of such ac-idents by 2.
analysis, and by research and development if necessary.
Devote personnel necessary to follow closely these additional NRC and 3.
Industry efforts and assure that TVA's full concerns are resolved.
It appears that it will require six months to a year of intensive ef fort I
to develop this fuller understanding.
In the event this program identifies t
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.g design changes, the changes will be i=ple=ented as the inf ormation becomes
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factored into the existing operating procedures, then the TVA training simulators will be used to retain operators on small loss-of-coolant
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instructions and precau-i accident mitigation. In the meantime, current
.g tions are adequate to ensure that no unacceptable risk is involved in
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operating pressurized' water reactors, particularly those of the Sequoyah
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and *,.'atts Bar type.
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Ooerational Feedback _
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Nature of the Issue:
Experience from operating nuclear plants is one of the most ef f ective i!
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ceans for evaluating perfor=ance of plant design and operation for identi-u
! i f ying opportunities for improvement. TVA and other nuclear plant operators and maintain a large a=oun. of operating perfor=ance
.outinely collect and maintenance data on all operating plants.
ll Each time an abnormal event occurs during operation of a nuclear plant, a
G (LER) is filed with the Nuclear Regulatory Co==1ssion.
Licensee Event Report its causes, and its results. Through this pro-The LER describes the event, ce'ss, the NRC has accummulated considerable inf ormation on major and minor occurrences at nucle.tr plants.
The NRC is responsible for assembling and. verifying this information, reducing it to a usable form, and disseminating it to the utilities. This program to identify potential major events' and recurring minor events
)
I
L2-is hampered by the large amount of data to be collected, the inferior quality of reports, and lack of sufficient emphasis on the program.
More systematic and formal methods are needed to digest, int e rp re t, and report the large volume of data available to assess its implication on 3
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nuclear plant safety and radiation exposure to plant personnel.
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Current Situation:
TVA's Division of Power Production and Division of Engineering Design j*
have formed a joint Task Force on Availability and Reliability Improvement
- i l which is charged with coordinating TVA ef forts in this area and working
's;.
I with national organizations to develop a useful national data system.
Also, TVA's Divisions of Engineering Design, Occupational Health and i-Safety, and Power Production cuirectly havc a progra= which includes evaluation of operating experience and coordinating efforts to keep I
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radiation exposures as low as reasonably achievable.
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?!A already devotes substantial effort to review of licensee event reports
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and other operating experience through its 'icelear Experience Reivev Panel i
f in the Division of Power Production. Each branch within the division is f
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assigned pri=ary responsibility for review of specific sources of infor=a-s L
tlon.
f.
i The reviewers meet as a panel monthly to report on potential proble..s and i
e, each is reviewed at each subsequent meeting until the problem is satis-c -
factorily resolved.
From the items reviewed, the panel selects those which I
would be helpful in operator training, particularly those which =ay point g
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3 A review of the items and the possible relationships to operator error.
to a TVA plant is included in the licensed operator's requalification program at each planc.
1.
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Recommendation:
- ~
TVA's design and operating organizations will develop for use in design i.
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and operation of TVA plants a data system which gives a better and more t
ki effective way to digest and report the large anount of information from
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l TVA rnd other U.S. nuclear plants.
The data system will give specific e
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attention to nuclear safety and to radiation exposure to e=ployees. The results will be made available to the NRC and other institutions and
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interested persons.
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EfERGENCY PLANNING z
Nature of the Issue:
Effective e=ergency planning to deal with nuclear plant accidents is an j {
Critical elenants in k T.
essential part of plant e=ergency procedures.
~
If e:ergency planning include provisions for evacuating or sheltering the
.1 for co==unicating public in the i==ediate area surrounding the plant, Ib offsite, for e=ergency offsite monitoring of radioactivity, and for public
- !hf reporting of proble=s at nuclear plants.
- 4 f
A.
Evacuation Contineenev plans h
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Current Situation:
The basic TVA Radiological E=ergency Plan was co=pleted in 1973 and has I
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j been approved by NRC. TVA works closely with Alaba=a, Tennessee, anc
- q 4
F.ississippi in their e=ergency planning.
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of the TVA plan, and The state radiological e=ergency plan is a part describes those actions to be taken by all state and local agencies to the health and safety of the public, including plans for evacuat-protect ing and sheltering the public in the event of a nuclear accident requiring these actions.
NRC requires that each operating nuclear plant have a plan to evacuate This people fro = the " low population zone," as defined in NRC regulations.
zone is typically about a 3-=11e radius of the plant.
0 O 5 e l
4 L5-The ~VA and state plans have been exercised on six occasions at the 3rowns Ferry Nuclear Plant. Five of these were drills, and a sixth occurred during the Browns Ferry fire in March 1975. One drill has j 1L. been conducted at the Sequoyah Nuclear Plant and another is scheduled \\ at Sequoyah prior to startup. During the last drill at Browns Terry each home within a 7-=11e radius of the plant was visited to determine jh how much time might be needed to evacuate persons living in the area.
- g.
cC Tollowing the drill, it was estimated that evacuation could have been
- i' TVA and state and local agencies will iI accomplished within four hours.
f 4 J, continue to perform such drills to assure that if an emergency condition s L -f. does arise, prompt response vill be taken for the protection of the health .t j{ and safety of the public.
- 0. :N RecommendatioEs:
~ I -VA vill work with the states to expand the 3-=11e radius to include a .5 contingency plan describing the actions and resources necessary to evacuate .' Y ,' j or provide shelter for persons living within a 10-mile radius of the plant. TVA vill assist Alabama, Mississippi, and Tennessee in developing these i i e plan'J. L !n addition, ~VA through its Division of Occupational health and Safety l in vill provide a full-time employee to the State of Tennessee to assist and maintenance of radiological emergency plans. planning, development, Through its program of technological assistance to public agencies, TVA's Office of Community bevulepment will also provide technicr1 and, as j appropriate, financial assistance to local, agencies. This assistance will l e
L6-1.
- f... '
be used to develop or improve emergency warning systems, emergency operating .l. centers, training of emergency personnel, and emergency and disaster re- ,j. Such assistance vill be useful both for response to t sponse equipment. .- l.. i nuclear emergencies and natural disasters. 'i 3. Communications Facilities i y Current Situation: The com=unications systems in TVA nuclear plants are adequate for communi- ~ cations cithin TVA and with outside agencies. However, communication capability in the Site Environs Emergency Control location will be improved, This is the center where representatives of TVA and offsite agencies assemble and from which activities associated with of fsite consequences are directed. Recom.monda t ions : The following communications circuits will be provided at t.he Site dnvirons I Emergency Control Center at all TVA nuclear sites: Two dedicated telephone lines connecting directly to the Muscle Shoals ~ i for Browns Ferry Nuclear Plant i Imergency Control Center PBX, except i k'here radio systems now which vill use the existing radio system. .~ + s exist, redundancy will be provided. 4 A minimum of three TVA automatic telephone system dedicated lines for 5-I. 1 access to internal TVA communications circuits, including off:.ite micro-i ,j, A wave and powerline carrier circuits. {. A minimum of three public telephone ILncs to assure communications with t-I. l This service will.be provided directly from the outside f acilltes. a 4 -. A = v
_Ly. l public telephone systen without being routed through the nuclear plant, thereby strengthening the redundancy of the Site Environs E=ergency Control Center communfcations. These services will be provided on the following schedule: I' 3rowns Ferry Nuclear Plant ) ) Sequoyah Nuclear Plant ) --- Telephone service by 11/1/79 ) Radio service by 2/1/80 C(' k'atts Bar Nuclear Plant ) ,f Bellefonte Nuclear Plant by Fuel Loading .f. Hartsville "A" Nuclear Plant by Fuel Loading s ^ .?hipps' Bend Nuclear Plant by Fuel Loading Ye,llow Creek Nuclear Plant by Fuel Loading ? ?h C,. Emereency Offsite Environmental Monitoring 'l ?I Current Situation: s' is The ability to monitor the radioactive releases from a nuclear plant vital to the public health and safety, during both nor=al operation and ' L L accident conditicas. The Three Mile Island accident illustrates the uncer-1 { Environ-tainty that can result with inadequate environmental monitoring. = ental monitoring programs are established around all TVA nuclear plants L In the event and are carried out throughout the lifetine of the facility. of a nuclear emergency, these predesignated sampling locations are fully i I utilized in evaluating the radiological consequences of the emergency in the environment. .e h r 1 i l L I
- . C.
The atmospheric monitoring network is divided into three subgroups. Monitors are located at the site boundarv, at distances of 5 to 10 miles, and at remote locations about 20 riles from the plant. All monitors are equippped with particulate and charcoal filters. Rainwater and heavy particulates are also collected. Thermolumines, cent dosimeters are located at numerous points to measure the gamma exposure rates. TVA is the only operator of nuclear plants which provides a telemetry 1 system in the environmental monitoring stations to transmit data on air-borne beta-gam =a levels into the plant control room. This information is vital in the early stages of an emergency in determining radioactivity levels.. The telemetry system also permits voice communications with the control room directly from the telemetry stations. Public water supplies within five miles downstream of the plant are sampled continuously and periodically analyted. This provides an early warning system and p mits the water supplies to be isolated from radioactive contamination. There are also wells onsite which are continuously sampled in the event of a liquid release which might reach the ground water supplies. Additional monitoring is conducted by special monitoring teams dispatched to the affected area. The radiological analysis of environmental samples is presently carried in an environmental radicanalytical laboratory located in Muscle Shoals, out Alabama. In order to increase the capability to analyze environmental This l samples, TVA is building a second laboratory near Vonore, Tennessee. L l. D**]D *]D ~Th@ .oom oM.J.htn'l.a i i b.
f acility will begin operation in January 1980; it is located much closer to nuclear plants which will operate in the eastern portion of the TVA systa=. Reco=cendation: The TVA offsite environmental monitoring program is one of the most 1 4 significant in the country. The staff will continue to seek ways to imp ove the program. i. j D. Public Reoorting cf Problems at Nuclear Plants l Current Situation: TVA's policy is to inf or= news =edia pro =ptly, fully, and as soon as possible of any unusual events at nuclear plants considered to have potential significance to safety even though their significance in so=e cases =ay be cinor. Any event that would be " news" is made public. a Nuclear Generation Division in the Office of Power is responsible for notifying the Director of Infor=ation when a problem occurs at an operating, TVA nuclear plant. In the case of a plant under construction, the Division of Construction notifies the Information Office. The Director of Infor=a-i. tion infor=s the Seneral Manager and the Board and prepares a news release, If needed. Recommendations: At a minimum, a public announcement will be issued whenever one of the following events occurs: t
_5c_ l. Nouscheduled unit shatdowns regardless of cause. Shutdowns resulting from failure of or damage to safety-related .2. equipment. 3. Failure of, or damage to, safety-related equipment. Any unusual discharge of radioactive =aterials from the plant. l 4 any unusual exposure of plant personnel. 5. WitL.in the plant, i l I Any severe personal injury or fatality, whether related to nuclear i l :'[ 6. t if operations or not. fuel or radio-7. Any accident involving a carrier transporting spent s 4' .) =N The announcement active waste materials from a TVA nuclear plant. }j. Ir will be coordinated with state radiological hygiene agencies as
- f.f
- L necessary.
e Reporting ef fect--or no ef f ect--f rom flood, earthquake, tornado, or .j> 8. j f'. other natural event in the plant vicinity that could produce public E j j-
- V f k:
concern. i[ such as fire or explosion causing damage at the plant. 9. Any incident Ij such as t 10. Any abnomal event involving environmental concern, jy .L significant.hemical release. e P environ- .,i 11. Any significant curtailment of operations required to meet . V. .L mental requirements. all'-Laclusive, and other abnormal events will also be [ This list is not announced. Ir 'n addition to the above, each plant will have a resident information 0 y officer. D O i 90 I l. e 'u t
- )~..
Through attendance at the daily plant planning meetings the information officer vill be kept abreast of plant act ivities. The information officer vill serve both the plant superintendent and the Information Office, and vill be responsible for coordinating it.for=ation releases about plant and co==unicating I activities, arranging for all visitors to the plant, E With plant employees as well as the public concerning TVA progra=s and ? ,jI policies. !) 'I infor=ation of ficer vill be available during .{ In addition, the resident j the emergencies to disseminate infor=ation to the press and assist ' ? fr l P ant plant superintendent in handling inquiries from the news media, the public,
- ?.
~ a f i t i4 s tate and local agencies, and others. i .e- .c l,lr af. <c. e ?- .. d.. ? V~tr I I o l 4. I
i l N .' 1 1, 5 f iIi . t. i( Y-I' ,f .i. '1 { Appendix i . v. - \\. + t: '5 . k' ' .Conpleted TVA Actions in 2 Nuclear Plant Design to Improve Safety t .b
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? I f~ 3P 1 I i l 6 !i L i L !l . k
i 1 i L 1 l This appendix su==arizes actions TVA has co=pleted in the past to i= prove nuclear plant safety. Section I below lists those that are related to problens revealed by the Three Mile Island accident. Section II lists other actions which have i= proved safety in TVA nuclear i
- plarts, b
i ti I. ACTIONS RELATED TO THREE MILE ISLAND i, 9 t i Auxiliary Feedwater Svste 5 t ~ The Auxiliary Feedwater Syste= (AFWS) is designed to supply sufficient water to the staa= generators to allow the reactor to be cooled dcun if l ' ain feedwater is not available. Thus, the AFWS beco=es i=portant fol- = t "P ~ tupply. 'g lowing any incident which results in loss of the =ain feedwa I in At Three Mile Island, this systa= was not considered safety-related. .L
- 1
][ TVA considers the AFWS to be an essential part of those safety-related systens needed to protect the public health and safety, and has designed the systa=s accordingly. For exa=ple, TVA required Babcock and Wilcox to provide a fully safety-grade control system for the AFWS of 3ellefcnte including a safety-grade, redundant essential air systa= to power valves in this systa=. Since that cine, the NRC has requested other vendors to develop safety-grade syste=s i for these functions. i s %, ess \\ b(b D 0hk i l l 1
~ fl' ) 1 l Contai=:ent Water Level Nuclear plants are designed on the basis that water can be released to contain=ent in an accident without flooding essential safety equip =ent inside contain=ent. It is i=portant that the operator know what level as an aid in assess-i of water exists in contain=ent following an accident is ing the magnitude of the accident and ensuring that safety equip =ent in danger of being flooded. not TVA recognizes the i=portance of =enitoring water level inside containment l , j safety-grade, containment of ji and has provided on all TVA plants redundant, .g The instru=ents have a vater level indicators in the =ain control room. i range of indication in excess of the maxi =um design basis water level p i
- l
~ 1 inside contain=ent. b s E e pressuri:er Heaters The pressurizer heaters provide a water te=perature in the pressurizer .[ '8 that creates a stea= pressure to prevent boiling elsewhere in the pri=ary e l This pressute control prevents stea: bubble for=ation in the system. It is reactor vessel, steam generators, and pri=ary system piping. N these heaters are available to =aintain pressure in the 'f important that prinary systec and ensure circulation for cool down through the stea: TVA considers the pressurizer heaters to be an essential f generators. part of the safety-related syste=s and has designed its systems 2ccordingly. Evdrocen Inside Containment accidents =ay cause hydpogen gas to be produced Certain nuclear plant inside the reactor and also to be produced in?che contain=ent building.
_3 Hydrogen generated inside the reactor can be released to the contain=ent building as a result of the accident or it can be deliberately vented by the operator to containment following an accident. A sufficient quantity of hydrogen =ixed with the air inside the containment would become an j a i explosive mixture. Nuclear plants are designed to prevent hydrogen ex-plosions and most plants are designed with hydrogen reco=biners which burn 1 the hydrogen before the concentration reaches explosive mixtures. Sone l ,j desig.s provide for recombiners that are portable and which are sonnected .j to the contain=ent after an accident to draw air from the containment, ? i i recombine the hydrogen with oxygen in the air, and return the hydrogen-free .1 air to ccatain=ent. These designs ha*.e been acceptable to the NRC.
- However, such designs are questionable because considerable c1=e and effort are required to connect the systa= after an accident when radiation levels =ay Ne high.
Also, care =ust be taken that this operation does not allow radioactivity to 'f escape fro = containment building. TVA has recognited the problems with portable recombiners located outside { 4 I Browns Ferry Nuclear Plant has an inert atmosphere inside containnent. containment that prevents the possibility of a hydrogen explosion. At a 1 a.1 other plants, TVA has two separate reco=biners permanently installed j inside the containment. These are always ready for operation following l an accident that could release hydrogen. For TVA plants, this proble: has been resolved and there are no changes required. 'l 1 Stat *:s Monitorin:: Systems Operators of nuclear plants must be sure that safe ty equipment is ready 1-for operation when it is requited for COergencies. To 3sSist the operator, Lo0Q@0$$h) e A
6 f I s:atus =onitoring systa=s are installed to display infor=ation in the =ain control roo= in such a way that the operator is better informed of 'f I g the status of plant safety syste=s. Such syste=s can vary in the a=ount a t and =anner in which infor=ation is displayed. ,j
- I
'i ! When the Regulatory Cocsission first required status monitoring of safety .j l} systa=s in our Watts Bar plant. TVA voluntarily decided to include this sa=e J!j design' feature on the earlier Sequoyah plant. Realizing this was a feature i j that provided additional assurance that the plan vould perfor= safely in the .} of an e=ergency. TVA pursued a very co=prehensive design approach. event j 'l .1 This approach included using a digital co=puter to collect and process the status infor=ation. In addition, he co=puter trans=its the data to video
- ?
uni:s that have especially designed presentations to allow the operator to IE visualize the status of the safety syste=s. .i t 4
- {
Papers have been presented and discussed at technical conferences and TVA staff have discussed this design approach with engineers from various utili-l ties and architec:-engineering fir =s. TVA is recognized as a pioneer in using ..t 1 this co=prehensive design. } J surther i= prove =ents as a result of the Three Mile Island Accident will be made. See Secticn IV. A. of the report. h s o 9 i
-5 t-II. OTdER ACTIONS Auxiliary Control Roo: can occur in the =ain Tnere exists a re=ote possibility that so=e event control roo= which requires the operators to abandon the control roo= and
- )
ro safely shut the plc.at down fro another location. Starting with Browns ~ Ferry, TVA i= posed very stringent require =ents on the reactor vendors for All subsequent TVA plants design of an auxiliary or backup control roc =. '.- j have been designed to per=it safely shutting the plant down fro a re=ote have now beco=e NRC location. IVA requirements, for the most part, require =ents. Advanced Control Roo=s control roo=s contain a very great a=ount of infor=acion that ~ Nuclear plant O =ust be assimilated and interpreted by the operators in the course of per-TVA has for=ing =anipulations during no=al and abno=al plant operation. worked with suppliers to develop advanced control roca designs for Hartsville, Phipps 3 ends, and Yellow Creek plants. These designc use co=puter syste=s to process and analyze plant info =ation and then display it to the operator in Controls are designed and nore easily interpretable fort on video screens. arranged for easy access and operation. TVA is recognized as a leader in this 4 area and has presented at several professional =eetings papers describing TVA control roo= designs. Solid State Control Syste=s f the year 1973, solid state. controls were developed which were = ore I - About reliable than tr.e conventional relay syste=s in perfor=ing the increasingly D M OD TD'D h '. j l ungaAhe
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O e j 't c i conplex control actions required for nuclear plant design. TVA adopted }_ . this new technology and a Jolid state control system was developed for the 4 Bellefonte Nuclear Plant which would perform control and interlock actions. ,~ T' is type syste has since been adopted by other power plant owners and is h now widely accepted as a significant improvement in nuclear plant control. } It is used at all TVA nuclear plants after Bellefonte. d .' l. .- l Asolitation of Generator Breakers 4 '. l NRC requires that two physically independent sources of electric power be ~1 available to all nuclear plants from off-site. One of these sources =ust I ~ j be available to supply the plant equipment within a few seconds if the plant Each of the in-j suddenly shuts down and no longer generates its own power. dependent sources =ust be available in ti=e to prevent any unsafe conditions l 1 in the plant. heneratorbreakersarefastandreliable. TVA has used these 3 i generator breakers to quickly cut off the plant turbine generator from the 1 outside lines if it trip s. This ensures that there is no interruption of i i power to the plant eqdipnent which permits nor=al shutdown with no unusual } 'l l or energency actions required. i, l Turbine Missiles 3 .j Stea= turbine-generators have, on very rare occasions, failed by disinte-1 gration, causing large pieces of the machine to fly off as missiles. 1 } Nuclear plants must be designed such that plant safety will not be jeopardited '.t fron turbine missiles. 1 .I All TVA turbine generators are oriented to mininite the probability of 2 rissiles hitting vital parts of the plant. TVA was one of the industry i .l 4 8 f
leaders in use of site arrangement to reduce the turbine missile hazard. TVA was also one of the industry leaders in the use of probability analysis to indicate that the turbine missile hazard is an acceptable risk in a properly arranged plant, s 4 Tornado Generated M.issile protection !!~ j Nuclear plants =ust be designed to withstand a tornado hitting the plant. -i I This includes flying debris and missiles carried along by the tornado which I .I
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might strike vital parts of the plant including buried pipes and cables. .I There were no criteria in existence for deter =ining how f ar missles, such i as steel pipe and telephone poles, would penetrate the earth. .j To correct for this lack of informaticn, TVA conducted tests by dropping cissiles from helicopters onto concrete slabs, crushed stone, and earth. .l. -j Eigh speed photography was used to record data and penetrations were i The results were used by TVA to design underground pipes and i measured. 9 , f electrical ducts which,will not be damaged by tornado missiles. l, .j Contain ent Purce Line Isolation It is permissible in sone plants for operators to enter containment during 1 plant operation. Before entering, it is necessary to circulate purge air 1 This =eans >}. through these parts of contain=ent chere access is per=itted. that fairly large air ducts are open during plant operation. If a pipe l 3 rupture occurs during this ti=e, the valves which automatically close of f J 3 I i the purge air lines af ter an accident.nast be designed for the large forces l l t I and possible debris leaving through the opening. TVA apparently recognized f this as a safety proble= before it was recognized by NKC and designed its j. NRC now recuires designs to acco: odate these conditions. i s 5 g plant accordingly.
g .e. i k kiM Oc )j g t Use of Reflective Insulatien -A hot piping inside contain=ent must be insulated to mininize loss of heat. s, .t ribrous insulation was widely used because it is cheap and efficient.
- (
However, during pipe ruptures inside contaic=ent, fibrous insulation can J'lj be blown of f and may clog strainers, pumps, or otherwise inpair operation ij of safety systems. TVA was one of the first to recognize this potential 'lj problem. All piping insulation inside containment is metal reflective
- 1 1}
insulation. NRC now requires that nuclear plant designs consider the 1 4 potential hazards caused by use of fibrous insulation inside containment. -4j e' N Stainless. Steel Cracking Boiling water reactors use stainless steel piping for the reactor pri=ary There has been considerable cracking of stainless steel piping in systen. ,J operating boiling Oater reactors. Early during the design of Browns Ferry, ~ ~ I(i evidence indicated that certain kinds of stainless steel catarial (furnace
- t r;a sensitized) might be suspect. At considerable expense, TVA decided to
'l el1=inate all furnace sensitized stainless steel from its reactor designs. 4d '] Very recently there has been some further evidence that an inproved =aterial a .a '3 is available which provides better assurance that cracking will not occur t during the life of the plant. Consequently, we have decided to change all stainless steel piping at Hartsville and Phipps Bend to the improved material. I: i This latter decision is not a safety decision, but the decision was weighed i i heavily by the f act that it has high probability of reducing repair and-
- sintenance and of considerably reducing personnel exposure to radiation.
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_g- ~ j Ud Contain=ent Sorav Additives Contain:ent spray systems are used to cool containment af ter an accident Chemicals are added to the spray I by spraying water inside the building. .I for ', i water which collect radioactive iodine and, thus, reduce the potential g The chemical used at some plants 9 iodine to escape following an accident. ij TVA took the lead in working with the vendors in developing is corrosive. is still' effective in absorbing .) a new chemical which is less, corrosive but q?.s }i iodine. .i- 'l l ,'] Insoection of 3edrock Under Structures The con-Toundation design is an L:portant aspect of nuclear plant safety. l{ -} dition of $oundations at all nuclear plant sites is determined by core j However, this does not
- 4 drilling and re-oving the cores for exa=ination.
k provide conclusive evidence for deter =ination of open or clay-filled ,e4 cavities below the surface of rock foundation for safety-related structures. .4 1 d TVA pioneered in the use of small celevision cameras for inspecting the W walls of drill holes and in providing a photographic record of such in- .i1 ?j !!o l.] spections. ,a 1 k N 1: il f d 4 t 1 ? 4 4 f p
UNITED STATES OF AMERICA NUCLEAR REGULA10RY CC:'. MISSION In the Matter of Docket No. 50-320 METROPOLITAM EDISON CCMPANY et al. Three Mile Island Nucleab Station: Determination regarding Extra-i Unit 2 ordinary Nuclear Occurrence SUBMISSION OF INFOPRATION, MOTION FOR LEAVE TO INTERVENE, AND REQUEST FOR HEARING 1. The persons submitting information herein (Informants) are as follows: Gerald S. Fantasky and Vincenta L. Fantasky James A. Good and Bonita R. Good James E. Gormley Dynamics Products Corporation Modagraphics Corporation John Glise, Inc. The Red Baron of America, Inc. James D. Derr, Inc. Robert T. Dunn and Annette Dunn Katherine Shirilla Michael Lyons and Judith Lyons Terrill Schukraft Constance Krebs Kenneth E. Stoner, Jr., and Linda Stoner Giant Food Stores, Inc. White Shield, Inc. Komet Co., Inc. First Edition Book Stores, Inc. Wolowitz, Inc., d/b/a " Young Image Shop" Free Car Wash, Inc., d/b/a " Gas and Wash" Cumberland 5kadium, Inc., d/b/a "Cumberland Skadium" Harry Cramer, Inc., d/b/a " Harry Cramer Oldsmobile" Aero Corporation, d/b/a " Budget Rent A Car" Michelle smajda and Terry Smith Earl J. Markle and Dorothy Narkle William Gorman and Beverly Gorman Russell C. Carhart and Grayce Earhart Herbert M. Packer, Jr. John W. Griffith and Jean B. Griffith LeRoy I. Sykes m,,o j wa=- Q; D ( g' \\ ~< /)6 ^
Monte H. E. Parfitt and Rose Marie Parfitt I Walter J. Lachowitz, Jr. American Vanguard Systems, Inc., t/a Mil] house Restaurant Samuel W. Fleck and Louise E. Fleck Davic A. Barbarette Leor.ard J. Bourinski and Joyce E. Scurinski Joan E. Bret: Gary F. Ditto William E. Dunham and Patricia Dunham Espenshade Meats Gilbert Freidman Mountainview' Thoroughbred Racing Assn., Inc. Penn Photo, Ltd. Pennsylvania National Turf Club, Inc. The Sport Nit, Inc. C. Robert Larsen and Marie K. Larsen Peter Davis and Carol A. Davis William Shields and Susan Shields Barry Buck and Toni Buck All of the foregoing reside, resided, were or are located on March 28, 1979 within 25 miles of Three Mile Island Nuclear 5,tation Unit 2 (TMI), and on March 28, 1979 several reside, resided or were or are locatedintheimmediatevicinityofsa'kdUnit. All are persons with-in' the meaning of 10 CFR S140.3 (g). The foregoing constitute all of the Plaintiffs in the consolidated class action naming the Licensee. of TMI and others as defendants filed in the United States District Court for the Middle District of Pennsylvania, No. ' 79-432. Said class action relates to the nuclear incident which took place on or about and after March 28, 1979. 2. On July 8, 1979, the Nuclear Regulatory. Commission (Ccmmission) initiated the making of a determination as to whether the above nuclear incident constitutes an extraordinary nuclear occurrence (ENO) and invited interested persons to submit any information in their possession relevant to this determination. Notice of this action was published in the Federal Register Vol. 44, No. 142, on July 23, 1979, and appeared in media announcements. l 2
s The notice published in the Federal Register stated, inter alia, that further provisions for public participation will be announced I at a later date. To the best of Informants' knowledge and belief, such provisions have not been announced. In addition, Informants believe that at least one application has been made to the Commission by other persons to make an ENO determination. 3. Informants are interested persons because either they and their properties were exposed to radiation or to radioactive materials from the nuclear incident, because they lost the use and value of their properties, or they found'it necessary to take protective action such as evacuation to reduce or avoi;d exposure to radiation or to radioactive materials. ' Informants are interested persons because they are named Plaintif.fs in the above mentioned class action on behalf of all individuals and entities within a 25-mile radius of TMI.- Important substantive and procedural rights in the class action may be affected by the determination as to-whether or not there is an ENO, which rights are found in portions of the Atomic Energy Act. See, 42 USC S2210(n). 4. Informants presently possess the following information rel-ative to the criteria set forth in 10 CFR S140.84(a) and (b) : O O O 5 O e 6 0 e 6 a 3-
During the incident, in placo monitors within the plant went off scale for three days and otherwise gave erroneous measurements, exceeding their capacity. for measuring relcases of radioactivity and radioactive materials. This and othe'r facts led the Lessons Learned Task Force to report that: ... sampling of-plant gasecus-effluents, with laboratory analysis of samples subsequent to release, is the only valid technique for monitoring accidental releases of radiciodines and particulates." NUREG-0573 p. A-38. 4 Published calcul'ations to date have relied on a limited number of dosimiter readings, have not given sufficient weight to the maximum dosimiter r'eadings observed, the margin of' error in'such measuring devices or the conflict of interest of the Commission's contractor, Radiation Management Corporatio,n. Said cotporation is part owned and financ'sd by General P,ublic Utilities, the parent company of the Licensee of TMI. Published calculations do not give weight to any estimated, observed, possible or calculated stack,,, vent and other releases applied to the meteorological dispersal formula for TMI, e.g., release of 13,000,000 curies of Xel33 and ' readings of 3,000 mr/hr above vent stack observed on March 29. 9 e 4 0 o D S S O 4
i 5. In addition, it is believed that the Commission is in error in its statement at Vol. 44, No. 142, Federal Register, page 43130 that: l + " Based on the information available to the NRC Staff at this time, it appears that neither part of Criterion I is satisfied. Both personal, exposures and property contamination are presently considered to be far below the levels specified in the tables set out above. In the period March 29-April 7, the approximated upper limit on whole body dose to a person in a populated area offsite has been calculated to be 100 millirecs. For the most part,
- property contamination levels measured approximated
' minimum detectable activity' levels." The Commission may further be in error by not givins sufficient weight to its words in 10 CFR 5140.84 (a), to wit: "...could have been or might have been exposed" to the doses. stated thereafter. Published articles indicate that the actual releases and doses i-received may never be known. 6. Informants presently possess the following information relative to the criteria set forth in 1*0'CFR S140.85: d e 6 O' S S .8 5.
While the consolidated class action filed by Informants, in accordance with the Federal Rules of Civil Procedure, does not state the amount of damages claimed, several of the actions which have been consolidated originally pleaded damages in excess of 560 million dollars. It is possible that all damages could exceed such amount. Such damages include those outlined in 10 CFR S140.85. Payments of approximately 1.2 million dollars have heretofore been voluntarily paid to evacuees. This does not include loss of wages or any expenses of evacuees in families which did not have pregnant women or pre-school children. The latter expenses are of great magnitude. The insurers of the Licensee and others have indicated a willingness to~ pay loss of, wages and are negotiating with Plaintiffs' liaison counsel in the class action for further sums to be paid in settle. gent of other portions of the claim. A notice of class action will soon be sent to all members of the c. lasses and subclasses which are estimated to be'approximately two million people for the purpose of indicating their willingness to participate in the suit and to indicate their damages.
Response
to this notice will be extremely valuable in indicating damages suffered by victims of the incident. S 4 e O e G 6
'/. 7. In addition, it is believed that the Commission is in error in its statement at Vol. 44, No. 142, Federal Register, page 43131 tha t: " Based on the~idformation available to the NRC staff at this time, the only category of Criterion I II damages possibly sacisfied by the Three Mile Island accident is defined t t (4), namely financial loss resulting from protectile actions such as evacuation, appropriate to reduce or avoid exposure to radiation or radioactive caterial." The Commission will be in error if it dues not interpret damages suffered by Informants and others to include loss of use of affected property and possibly total cost necessary to put affected pror ity back into use. See, 10 CFR S14 0.85 (b) (1) and (2). 8. In view of the fact that Informants and those who they represent will be affected by the within proceeding, Informants desire to participate as parties and he'reby petition for leave to intervene pursuant to 10 CFR-52.714, as well as any other procedures determined by the Commission for participation in this determination. 9. Informants wish to intervene'as it ; elates to the submission,and consideration of doses of and ekposures to radioactivity and radioac:ive materials, submission and consideration of damages to persons and property, as well as interpretation and affect of law and ef the Commission's Regulations. ~ c 10. Because of the importance of this determination, Informants also recuest that a hearing be held in the vicinity of TMI for the purpose of allowing Informants and other interested parties to participate. The' Commission is also recues ted to extend its 90-day deadline (10 CFR 5140.33) so that it can make an ac ual determination and not a determination by def ault. e 6 7
l 4 ~ ~ ~ ~ V- % David Yerger -l. 'Raym7hd L. Hovzs 1622 Locust Street 35 South Duke Street Philadelphia, Pennsylvania 19103 York, Pennsylvania 17401 Attorney for Informants Attorney for Informants Dated this 28th day of August, 1979. Service is to be made on the above attorneys at each of the cbove addresses. 6 t p 8 9 am
ce COMMONWEALTH OF PENNSYLVANIA:
- SS COUNTY OF YORK 9
Before me, a Notary Public in and for said Corrr.onwealth and County, personally appeared JAMES A. GOOD who is a petitioner herein, who being duiy sworn according to law, ^ deposes and says that he is authori::ed to make this affidavi$ on -behalf of petitioners, who are also acting as informants, and that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information and belief. 1 'A.mMJ.f/_. _-t 7 SWORN and subscribed to beforemethis.8Iday of 1979. / ; W/l/ J ./ ) N* g/ ~~ ' Nota'ry ~Publi~c' ' ' ~ ~ " AiY CCMMISSION EXP!RES DCTOSER 24,1931 Y.DR$,1CRK CO., PA. e 4 e 9 + t e e 9 e
UNITED STATES OF AMERICA NUCLEAR REGU~ STORY COMMISSION d In the Matter of I Docket No. 50-320 METROPOLITAN EDISON COMPANY et al. Three Mile Island Nuclear Station Determination regarding Extra-Unit 2 ordinary Nuclear Occurrence NOTICE OF APPEARANCE The undersigned does hereby appear on behalf of the following informants and petitioners in the above captioned proceeding: Gerald S. Fantasky and Vincenta L. Fantasky James A. Good and Bonita R. Good James E. Gor = lev Dynamic Products Corporation Modagraphics Corporation John Glise, Inc. The Red Baron of America, Inc." James D. Derr, Inc. '9 Robert T. Dunn and Annette Dunn Katherine Shirilla Michael Lyons and Judith Lyons Terrill Schukraft Constance Krebs Kenneth E. Stoner, Jr., and Linda Stoner-Giant Food Stores, Inc. White Shield, Inc. Komet Co., Inc. First Edition Book Stores, Inc. Wolowitz, Inc., d/b/a " Young Image Shop" Free Car Wash, Inc., d/b/a " Gas and Wash" Cumberland Skadium, Inc., d/b/a "Cumberland Skadium" Harry Cramer, Inc., d/b/a " Harry Cramer Oldsmobile" Aero Corporation, d/b/a " Budget Rent A Car" Michell Smajda and Terry Smith Earl J. Markle and Corothy Markle William Gorman and Beverly Gorman Russell C. Earhart and Grayce Earhart Herbert M. Packer, Jr. John W. Griffirh and Jean 3. Griffith LeRoy I. Sykes Monte H. E. Parfitt and Rose Marie Parfitt Walter J. Lachewitz, Jr. American Vanguard Systems, Inc., t/a Millhouse Restaurant e e e O N Nu
i o Samuel W. Fleck and Louise E. Fleck David A. Barbarette Leonard J. Bourinski and Joyce E. Bourinski Joan E. Bret: Gary F. Ditto William E. Dunham and Patricia Dunham Espenshade Meats Gilbert Freidman Mountainview Thoroughbred Racing Assn., Inc. Penn Photo, Ltd. Pennsylvania National Turf Club, Inc. The Sport Nit, Inc. C. Robert Larsen and Marie K. Larsen Peter Davis and Carol A. Davis William Shields and Susan Shields Barry Buck and Toni Buck The addresses of the foregoing are various and for purposes of this notice may be deemed the same as the undersigned. The undersigned is an attorney-at-law.' admitted to practice and P in good standing in the following Courts: United States Supreme Court; United States Codrts of Appeals for the First, Third and Ninth Circuits; United States District Courts for the Middle and Eastern Districts of P'ennsylvania; The Supr , Court of Pennsylvania; and other C'curts in the Commonwealth of Pennsylvania. O' pV - - J David Berger 1622 Locust Street Philadelphia, Pennsylvania 19103 9 4 1
UNITED STATES OF AMERICA ' NUCLEAR REGULATORY COMMISSION en ' I In the Matter of Docket No. 50-320 METROPOLITAN EDISON COMPANY et al. 'Three Mile Island Nuclear Station Determination regarding Extra-Unite 2 ordinary Nuclear Occurrence NOTICE OF APPEARANCE The undersigned does hereby. appear on behalf of the following informants and petitioners in the above captioned proceeding. Gerald S. Fantasky and Vincenta L. Fantasky James A. Good and Sonita R. Good James E. Gormley Dynamics Products Corporation Modagraphics Corporation John Glise, Inc. The Red Baron of America, Inc. James D. Derr, Inc. Robert T. Dunn and Annette Dunn Katherine Shirilla Michael Lyons and Judith Lyons. Terrill Schukraft Constance Krebs Kenneth E.
- Stoner, Jr., and Linda Stoner Giant Food Stores, Inc.
White Shield, Inc. Komet Co., Inc. First Edition Book Stores, Inc. Wolowitz, Inc., d/b/a " Young Image Shop" Free Car Wash, Inc., d/b,'a " Gas and Wash" Cumberland Skadium, Inc., d/b/a "Cumberland Skadium" . Harry Cramer,.Inc., d/b/a ' Harry Cramer Oldsmobile" Aero Corporation, d/b/a " Budget Rent A Car" Michelle Smajda and Terry Smith Earl J. Markle and Dorothy Markle William Gorman and-Severly Gorman Russell C. Earhart and Grayce Earhart Herbert M. Packer, Jr. John W. Griffith and Jean B. Griffith LeRoy I. Sykes m
Monte II. E. Parfitt and Rose Marie Parfitt J Walter J. Lachewitz, Jr. American Vanguard Systems, Inc., t/a Millhouse Restaurant Samuel W. Fleck and Louise E. Fleck -David A. Barbarette Leonard J. Bourinski and Joyce'E. Bourinski Joan E. Bret: Gary F. Ditto William E. Dunham and Patricia Dunham Espenshade Meats Gilbert Freidman Mountainview Thoroughbred Racing Assn., Inc. Penn Photo, Ltd. Pennsylvania National Turf Club, Inc. 'The Sport Nit, Inc. C. Robert Larsen and Marie K. Larsen Peter Davis and Carol A. Davis William Shields and Susan Shields Barry Buck and Toni Buck Thd addresses of the foregoing are various and for purposes of this notice may be deemed the same as the undersigned. The undersigned is an attorney-at-law admitted to practice and in good standing in the.following Courts' United States Sup$eme Court, United States Court of Appeals for the District of Columbia Circuit, United States Distric.t Court for the Middle District of Pennsylvania, Supreme Court of Pennsylvania, and other courts in the Commonwealth of Pennsylvania. In addition, the undersigned.has practiced before the Nuclear Regulatory Commission since 1973 at both the Atomic Safety and Licensing Board and Appeals Board levels. i l /} R'ay' mon'd L. Hovis' 35 South Duke Street York, Pennsylvania 17401 (717) 843-8871 e 4
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