ML19322E679
| ML19322E679 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/21/1980 |
| From: | Singer L, Tourtellotte J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19322E677 | List: |
| References | |
| NUDOCS 8004020107 | |
| Download: ML19322E679 (18) | |
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llll NRC 03/21/80 o
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAPD In the Matter of METROPOLITAN EDISON COMPANY,
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(ThreeMileIsland, Unit 1)
SUPPLEMENT TO NRC STAFF POSITION ON NEED TO CONSIDER CLASS 9 EVENTS Pursuant to an Appeal Board decision which noted that the Commission had requested the Staff to " bring to [its) attention, any individual cases in which [the Staff] believes the environmental consequences of Class 9 acci-dents should be considered,"1 this Licensing Board issued an order directing the Staff to inform the Board and the Conaission wbather or not (and the reasons therefor) any specific accident sequence, which has a reasonable nexus to the TMI-2 accident and which heretofore may have been regarded as a Class 9 accident, should be considered in the analyses of the acceptability of returning TMI Unit 1 to operation.
First Special Prehearing Conference Order at 17 (December 18,1979).
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Pub'ic Service Coroany (Black Fox Station, Units 1 and 2), ALAB-573, 10 NRC (December 7,1979) (slip. oo. at 31).
The Appeal Board also asked the Staff to advise the Consission whether the conse-quences of Class 9 accidents should be considered in the Black Fox proceeding.
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- In compliance with the Board's order, the Staff submitted on January 31, 1980 a response entitled "NRC Staff Position on Need to Consider Class 9 Events."
In this document the Staff explained that after its review of the TMI-2 accident and close analogs to that accident it expected "...to be able to determine whether to impose additional requirements on TMI-1 so that, together with those requirements already imposed, such scenarios would not represent credible accident sequences at TMI-1 should that facility be permitted to restart." M. at 3.
The Staff thus concluded "...that no other specific accident sequences which heretofore may have been regarded as Class 9 accidents need be considered in the analysis of the acceptability of returning TMI-1 to operation." M.U During the second Special Prehearing Conference hcid on February 13, 1980, the Board expressed its desire for additional information on accident scenarios and on " fixes" required by the Staff.
In response to the Board's inquiry, the Staff offered to supplement its earlier Staff position on the need to consider Class 9 events by providing a summary of activities ongoing in the NRC that will have the effect (1) of reducing the likelihood of Class 9 events; and (2) of mitigating events such as those that occurred at TMI-2.U y
The Staff also discussed its position on the environmental consequences of TMI-2 type accident scenarios.
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The technical infonnation in this paper was provided by the technical staff pursuant to a request from the legal staff.
I.
ORIGIN AND GENERAL DISCUSSION OF THE NRC ACTION PLANS Subsequent to publication of its August 9,1979 Order and Notice of Hearing, CLI-79-8,10 NRC 141 (1979) (Order), in which the Commission established this Atomic Safety and Licensing Board to conduct the TMI-1 suspension hearing, the Commission initiated its long-term response to the recommenua-tions of the President's (Kemeny) Comission.O In November 1979 the Commis-sion compiled its preliminary views in a document entitled "NRC Views and Analysis of the Recommendations of the President's Comission on the Accident at Three Mile Island," NUREG-0632. Contained within NUREG-0632 is a letter Frank PressN rom Comission Chaiman Joseph M. Hendrie.
to a.
f In that letter Chairman Hendrie explained the actions that had been or would be taken by the Comission as a result of NRC's internal reviews of the TMI-2 accident including the intention of the Comission to form action plans for its TMI related activities. Letter dated November 9,1979 to Dr. Frank Press from Joseph M. Hendrie.
To identify and consolidate all TMI-2 related activities, the Staff has pre-pared NUREG-0660, "NRC Action Plans Developed as a Result of the TMI-2 y
NRC's response to the recommendations of the President's Comission was requested by Dr. Frank Press, Director of the Office of Science and Technology Policy, Executive Office of the President. Dr. Press is the Chaiman of the interagency panel assigned by the President to review the Kemeny Commission report.
See Memorandum for all NRC employees from Lee V. Gossick, Executive Director for Operations, re: NRC Views and Analysis of the Recomendations of the President's Comission on the Accident at Three Mile Island, dated November 20, 1979.
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See note 4, infra.
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Accident" (Action Plans).b Relevant portions of Draft 2 of the Action Plans are attached as Attachments 1-4.
This document, which is undcr review by the Commission, identifies TMI-2 related activities ongoing in the NRC, l
including task objectives, task description, current schedule, and applica-bility to plants under construction and operating reactors.E It groups activities in four major categories: Operational Safety; Siting and Design; i
Emergency Preparedness and Radiation Effects; and NRC Organization, Management, Practices, and Procedures.
The great majority of fully defined requirements that could apply to TMI-1 are included in the Order of Augast 9,1979.
For example, analyses required in Section I.C (operating procedures) of the Action Plans are the same as those required by the Order.
However, there are some items in the Action Plans that are not included in the Order.
The Staff intends that in general these items are applicable to plants in con-struction and to operating plants.
These items are being considered by the Staff for implementation at TMI-1, but a decision on their implementation, either before or after restart, has not yet been made.
Items required for operating reactors will also be proposed by the Staff for TMI-1 by restart or by the schedule as it eventually appears in the Action Plans finally approved by the Commission.
6f In addition, on March 11, 1980, the Staff provided the Commission with its views on the future treatment of Class 9 accidents under the National Environmental Policy Act.
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Draft 2 does not include items in the Rogovin Report. These items will be added in Draf t 3, v5fch will be available soon.
Draft 3 will also include items in IE Bulletins.
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II.
DISCUSSION OF ACCIDENT SCENARIOS AND PREVENTIVE AND MITIGATIVE MEASURES Since the TMI-2 accident, special attention has been drawn to severe core accidents, including core melting (so called " Class 9" accidents).
The Staff has therefore proposed to the Commission that additional efforts be made to mitigate the consequences of such events. Task II.B describes activities ongoing within the NRC in the area of degraded or melted cores.
It should be noted that Items II.B.1 (reactor coolant system vents), II.B.2 (plant shielding to provide access to vital areas and protect safety equip-ment for post-accident operation), and II.B.3 (post-accident sampling) are included in the Order (Item 8:
Category A recommendations as specified in Table B-1 of NUREG-0578).
Items II.B.6 (features to cope with core melt accidents in reactors at sites with high population densities) and II.B.7 (containment inerting) are not in the Order. Other items eventually decided to be applicable to the generic class of reactor or containments represented by TMI-1 will be applied to that plant on a schedule consistent with other operating reactors.
During the deliberations of the NRC groups and of the other organizations that have reported the results of their reviews,8_/ the TMI-2 scenario and related specific and generalized scenarios were considered, including numerous 8_/
Af ter the accident at TMI-2, offices within and organizations outside the NRC reviewed the safety of nuclear power plants in order to reduce the probability of a TMI-2 accident or other similar accident in the future. Within the NRC, these efforts were focused in the Bulletins and Orders (B&O) Task Force, the Lessons Learned Task Force, the Special Inquiry Group (Rogovin), and the Advisory Committee on Reactor Safeguards (ACRS). Outside the NRC, the President's Commission on the Accident at Three Mile Island (Kemeny Commission), various industry groups, and several Congressional committees have worked and are still working toward that end.
variations on initiating events and subsequent failures. Specific design and procedural changes were recommended to make these initiating events and subsequent failures less likely and to improve measures to deal effectively with and to mitigate the consequences of these scenarios even if they were to occur.
In addition, recommendations were made in the areas of management and technical competence, operator and other staff training, quality assur-ance, staffing, health physics, maintenance, and emergency preparedness.
These recommendations were necessary to improve plant safety in general and to address TMI-2 related scenarios.
As a result, further efforts were required of the licensees and reactor vendors to improve the analysis of transients and accidents as well as the procedures for handling such events.
With the exception of the items discussed in the Kemeny and Rogovin reports, which were published after the Order, the recommendations of these groups were considered for inclusion in the Staff recommendations to the Commission for incorporation into its Order regarding the TMI-1 license suspension.
The recommendations of the Director of NRR were identified as the eight short-term and four long-term requirements in the Coramission's Order.
The scenarios considered may be summarized as those clear and close analogs of the TMI-2 accident that involve combinations of initiating events including feedwater transients and small break LOCAs, and subsequent failures including loss of auxiliary feedwater, loss of all feedwater, loss of ECCS, and small break LOCAs. Some of these combinations could result in inadequate core
- cooling and possible subsequent serious core damage or core melting with substantial hydrogen generation and significant release of radiation.
The following are examples of scenarios examined:
1.
Loss of feedwater plus loss of auxiliary feedwater plus a stuck-open PORV plus a loss of HPI (this scenario corresponds to the TMI-2 event without operator action to restore safety systems or to close the PORV).
2 Small break plus loss of all ECCS (HPI and LPI).
3.
Loss of feedwater plus.oss of all auxiliary feedwater.
4.
Small break plus loss of all feedwater.
These scenarios were chosen to be representative of those that result from combinations of the initiating events and failures discussed above. The first two scenarios, which involve multiple failures, would be expected to lead to substantial core damage or core melt.
The third and fourth scenarios, also involving multiple failures, are not likely to result in core damage since the high pressure injection system can be used to assure core cooling.
As required by Item 8 of the Order, specifically 2.1.9 in NUREG-0578, further analyses by the licensee are continuing for small break LOCAs, inadequate
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core cooling, and transients and accidents. Additional scenarios may be identified in the future through the reliability engineering and risk assess-ment program recommended in Task II.C.1 (reliability engineering and risk assessment) of the THI-2 Action Plans currently under review by the Commission.
Those measures required by the Order that prevent or reduce the probability of initiating events, that prevent or reduce the probability of subsequent failures and that permit dealing effectively with and mitigate the conse-quences of a degraded core or core melt, are identified in the following list. Also listed are items that are not mentioned in the Order. These items are continuing to be evaluated by the Commission and the Staff in the context of the TMI-2 Action Plans.
Measures Which Prevent or Reduce the Probabilitv of Initiating Events Action Order Item Other Reference 1.
ICS failure modes and effects analysis 1 (long-term) 2.
Retraining of operators 1
3.
Requirement for licensee review of operating experience 8
Action Plans I.C, I.E 4.
Operational quality assurance program 6
5.
Verify management and technical capability 6
Action Plan I.B.1 6.
Verify capability of safety review and 6
operational advice 7.
Review training of operations staff 6
Action Plan I.A.2 8.
Review facility procedures 6
Action Plan I.C 9.
Review plant maintenance 6
10.
Requirement for shift turnover procedure 8
Action Plan I.C 11.
Requirement relating to shift manning Action Plan I.A.1 12.
Requirement for upgrading operator training and qualifications Action Plan I.A.2 13.
Revisions to scope and criteria for operator licensing examinations Action Plan I.A.3 14.
Systematic assessment of licensee safety Action Plan I.B.2 15.
Requirement for an onsite safety engineering group Action Plan I.B.3 16.
Requirement for a control room design study Action Plan I.D 17.
Required changes to PORV setpoint 2
18.
Anticipatory reactor trips 2
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Measures Which Prevent or Reduce the Probability of Subsequent Failures Action Order Item Other Reference 1.
EFW timeliness and reliability 1
2.
Independence of EFW from ICS 1
3.
Reactor trip on loss of main feedwater (reduce challenges to PORV) 1 4.
Program of analysis, procedures and training related Action Plan I.C to small breaks, transients, and accidents 1
5.
Required review of the TMI-2 accident 2
6.
Required review of plant transients 2
7.
Required valve position review 2
8.
Required containment isolation review 2
9.
Required safety related valve positioning procedures 2
10.
Required EFW train operability review 2
11.
Required safety-related system operability review 2
12.
Required personnel awareness of action taken during TMI-2 accident 2
13.
Required natural circulation procedures and training 2
14.
Required safeguards termination criteria 2
15.
Required manual termination criteria for HPI 2
16.
Required changes to PORV setpoint 2
17.
Required manual reactor trip procedures 2
18.
Required anticipatory reactor trips (to reduce challenges to PORV) 2 19.
Required prompt reporting procedures 2
20.
Required reactor coolant pump trip 2
21.
Required small break LOCA analyses 2
Measures Which Prevent or Reduce the Probability of Subsequent Failures (Continued)
Action Order Item Other Reference 22.
Required guidelines for operator action covering RCP trip 2
22.
Required emergency procedures and training for reactor coolant pump trip 2
23.
Required emergency procedures and training for inadequate core cooling 2
24.
Required automatic RCP trip design 2
25.
Required review of licensee management and technical capability 6
Action Plan I.B.1 26.
Review capability safety review and operational advice 6
27.
Review training of operations staff 6
Action Plan 1.A.2 28.
Review operational quality assurance program 6
29.
Review facility procedures 6
Action Plan I.C 30.
Requirement for a subcooling meter in PWRs 8
31.
Instrumentation for inadequate core cooling (short-term) 8 32.
Requirement for unambiguous indication of inadequate core cooling 8
Action Plan II.F 33.
Requirement for a shift technical advisor 8
Action Plan I.A 34.
Requirement for clear definition of shift supervisor responsibilities 8
Action Plan I.C 35.
Requirement for control room access procedures 8
Action Plan I.C 36.
Requirement for shift turnover procedures 8
Action Plan I.C 37.
Requirement for an onsite technical support center 8
38.
Requirement for an onsite operational support center 8
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l Measures Which Prevent or Reduce the Probability of Subsequent Failures (Continued)
Action Order Item Other Reference 39.
Requirement for review (by licensees) of operating experience 8
Action Plans I.C. 1.E 40.
Testing of relief and safety valves 8
Acticn Plan II.D 41.
Direct indication of relief and safety valve position 8
Action Plan II.D 42.
Requirement relating to shift manning Action Plan I.A.1 43.
Requirement for upgrading operator training and qualifications 6
Action Plan I.A.2 44.
Revisions to scope and criteria for licensing examinations Action Plan I.A.3 45.
Requirements related to simulator use and development Action Plan I.A.4 46.
Requirements relating to criteria for licensee organization and management capability 6
Action Plan I.B.1 47.
Systematic assessment of licensee safety Action Plan I.B.2 48.
Requirement for an onsite safety engineering group Action Plan I.B.3 49.
Requirement for NSSS vendor review of emergency procedures Action Plan I.C 50.
Long-term program for continuing improvement to plant emergency procedures Action Plan I.C 51.
Reliability engineering and risk assessment program (IREP)
Action Plan II.C.1 52.
Program to decrease the frequency of challenges to ECCS Action Plan II.E.1 53.
Research program on ECCS effectiveness (LOFT, etc.)
Action Plan II.E.2 54.
Systems interaction program (OSI-A-17)
Action Plan II.C.1 55.
Program to evaluate and improve auxiliary feedwater system reliability Action Plan II.E.1
- 13 Measures Which Prevent or Reduce the Probability of Subsequent failures (Continued)
Action Order Item Other Reference 56.
Requirement for indication and automatic initiation of auxiliary feedwater Action Plans II.E.1, 8
II.E.2 57.
Requirement for emergency power for pressurizer equipment 8
Action Plan II.G 58.
Requirement for plant drills for emergency procedures Action Plan I.A.2 59.
Requirement for review of shift supervisor duties 8
Action Plan I.A.1 60.
Correct defective welds in safety related systems DDR activities 1
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. Measures to Deal Effectively With and Mitigate the Consequences of a Deoraded Core or Core Melt Action Order Item Other Reference 1.
Upgrade of emergency plans to satisfy Regulatory Guide 1.101 3
Action Plan III.A.1 2.
Establishment of an emergency operations center 3
Action Plan III.A.1 3.
Upgrade of offsite monitoring 3
Action Plan III.A.1 4.
Assessment of state and local emergency plant 3
Action Plan III.A.1 5.
Requirement to conduct a test exercise of the emergency plan 3
6.
Review of managerial capability and resources 6
Action Plan I.B.1 7.
Review capability of safety review and operational advice 6
8.
Review training of operations staff 6
9.
Review facility procedures 6
10.
Review plant maintenance 6
11.
Program on radiation source control Action Plan III.D 12.
Siting policy rulemaking Action Plan II.A 13.
Requirement for post accident sampling capability 8
Action Plan II.B 14.
Requirement for shielding to allow post-accident access to vital areas 8
Action Plan II.B 15.
Requirement for training to mitigate core damage Action Plan II.B 16.
Program to upgrade state and local government preparedness Action Plan III.B 17.
Program for improved radiological effluent monitoring Action Plan III.D.1 18.
Program to study radioiodine pathways Action Plan III.D.2 19.
Program to study liquid pathways Action Plan III.D.3 20.
Program to study offsite dose monitoring and calculations Action Plan III.D.4
. Measures to Deal Effectively With and Mitigate the Consequences of a Degraded Core or Core Melt (Continued)
Action Order Item Other Reference 21.
Program to upgrade licensee emergency preparedness 3
Action Plan III.A.1 22.
Program to upgrade licensee emergency support facilities 4
Action Plan III.A.2 23.
Program to maintain supplies of thyroid blocking agent Action Plan III.A.3 24.
Long-term program to improve licensee emergency preparedness (amend 10 CFR Part 50 and Appendix E) 4 Action Plan III.A2.1 25.
Program to improve NRC emergency preparedness Action Plan III.A3 26.
Requirement for dedicated hydrogen recombiner penetrations 8
Action Plan II.E 27.
Requirement for improved containment isolation dependability 8
Action Plan II.E.4 28.
Plan for criteria for gross containment integrity check Action Plan II.E.4 29.
Requirements and restr'ctions on containment purging Action Plan II.E.4 30.
Research on phenomena associated with core degradation and fuel melting Action Plan II.B.5 31.
Requirement to comply with CSB Technical Position 6.4 DDR activities 32.
Environmental qualification program for containment isolation valves NRR Program 33.
Addition of hydrogen recombiners voluntary addition 34.
Required emergency procedures and training for inadequate core cooling 2
35.
Improvement in post accident monitoring II.F.B.3 36.
Improve filter Tech Specs DDR activities
- 37. Automatic switchover to ECCS receive mode 00R activities 38.
Improve uneven drawdown cf RB spray system DOR activities
Task II.B.8 (rulemaking proceeding) has been revised for Draft 3 of the Action Plans and is attached separately as Attachment 5 for informational purposes. The overall rulemaking, which will consider both an interim rule and a long-range revision of NRC requirements, is estimated to be completed one to two years after publication of the interim rule.
The Action Plans and the Staff recommendations for rulemaking will be placed directly before the Commission for its consideration.
Respectfully submitted, blf k.
TL0?]
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Lisa N. Singer Counsel for NRC Staff
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James R. Tourtellotte Assistant Chief Hearing Counsel Dated at Bethesda, Maryland this 21st day of March,1980
T UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMISSION In the Matter of METROPOLITAN EDIS0N COMPANY,
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(Three Mile Island, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of " SUPPLEMENT'TO NRC STAFF POSITION ON NEED TO CONSIDER CLASS 9 EVENTS" and ATTACHMENTS 1-5 in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Conmission's internal mail system, this 21st day of March,1980:
- Ivan W. Smith, Esq.
Ellyn Weiss, Esq.
Atomic Safety & Licensing Board Panel Sheldon Harmon, Roisman & Weiss U.S. Nuclear Regulatory Commission he50 Washington, D. C.
20555 Washington, D.C.
20006 Dr. Walter H. Jordan Mr. Steven C. Sholly 881 W. Outer Drive 304 South Market Street Oak Ridge, Tennessee 37830 Mechanicsburg, Pennsylvania 17055 Dr. Linda W. Little 5000 Hermitage Drive Mr. Thomas Gerusky Raleigh, North Carolina 27612 Bureau of Radiation Protection Department of Environmental Resources
'T,borge F. Trowbridge, Esq.
P.O. Box 2063 Shaw, Pittman, Potts & Trowbridge Harrisburg, Pennsylvania 17120 1800 M Street, N.W.
Washington, D. C.
20006 Mr. Marvin I. Lewis 6504 Bradford Terrace Karin W. Carter, Esq.
Philadelphia, Pennsylvania 19149 505 Executive House P. O. Box 2357 Metropolitan Edison Company
.Harrisburg, Pennsylvania 17120 Attn:
J. G. Herbein, Vice President P.O. Box 542
' Reading, Pennsylvania 19603 Honorable Mark Cohen 512 E-3 Main Capital Building Ms. Jane Lee Harrisburg, Pennsylvania 17120 R.D. 3; Box 3521 Etters, Pennsylvania 17319
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.. Walter W. Cohen, Consumer Advocate Holly S. Keck Department of Justice Anti-Nuclear Group Representing Strawberry Square,14th Floor York Harrisburg, Pennsylvania 17127 245 W. Philadelphia Street York, Pennsylvania 17404 11s. Karen Sheldon Sheldon, Harnon, Roisman & Weiss John Levin, Esq.
i 1725 I Street, N.W.
Pennsylvania Public Utilities Comi.
Suite 505 Box 3265 Washington, DC 20006 Harrisburg, Pennsylvania 17120 Ms. Frieda Berryhill, Chairman Jordan D. Cunningham, Esq.
Coalition for Nuclear Power Fox, Farr and Cunningham Plant Postponement 2320 North 2nd Street 2619.Grendon Drivo Harrisburg, Pennsylvania 17110 Hilmington, Delaware 19808 Ms.KathyMc0aughin Three Mile Island Alert, Inc.
Atomic Safety and Licensing Appeal Board 23 South 21st Street o
U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17104 Washington, D. C.
20555 I$ M rie M. Aamodt Atomic Safety and Licensing Board Panel Rb 0
U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Coatesville, Pennsylvania 19320 Docketing and Service Section Senator Allen R. Carter o
Chairnan U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Joint Lenislative Comnittee on Enerc.
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Post Office Box 142
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Suite 513 Senate Gressette Building Columbia, SC 29202 Robert O. Pollard
'609 Montpelier Street
- Samuel J. Chilk, Secretary Baltimore, Maryland 21218 Office of the Secretary of the Comission Chauncey Kepford U.S. Nuclear Regulatory Commission Judith H. Johnsrud Washington, D.C.
20555 Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 I
m rLach A
James R. Tourtellotte Ass'istant Chief Hearing Counsel
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