ML20033C483
| ML20033C483 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/20/1981 |
| From: | Thornburgh D PENNSYLVANIA, COMMONWEALTH OF |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8112030305 | |
| Download: ML20033C483 (14) | |
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Co M MoNw cALTH Or PENNSYLVANIA ornec or Tsc covc=Non 81 NOV 30 P2:33 HAmmessumo THE GOVERNOR November 20, 19Eil h (S-j's
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Dr. Nunzio J. Palladino Y /1
'h Chairman U.
S. Nuclear Regulatory Commission f
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Washington, JC 20555 DEC2 1981 I
Dear Mr. Chairman:
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It is my understanding that the Nuclear Regulath.rg
,y Commission is nearing a decision on whether tho. undamag;ed i e.
Unit 1 generating station on Three Mile Island should be returned to active service.
As you are aware, I have been involved in an effort to address a serious and lingering health and safety concern on Three Mile Island.
That concern has to do with the dangerous levels of radiation that continue to contaminate the crippled Unit 2 facility, and with the need for a clear consensus and financial commitment for the safe, timely and total removal of that contamination.
On July 9, I advanced a national cost-sharing proposal for achieving the cleanup of TMI-2, a proposal which presently appears to be our best hope for removing what the entire spectrum of scientific and technical experts agrees to be a
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genuine health and safety hazard.
954' At the time, I was concerned about the possibility 'that J
Unit 1 might be reactivated without regard to resolving a
" crisis of commitment" to funding the cleanup of Unit 2.
I do
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not believe these two questions should be considered separately.
Because the cleanup funding task requires the use of
- revenue that would be realized from a newly-active Unit 1, I have announced my intention to support restart of the undamaged facility only if two conditions are met:
(1)
Development of a consensus for a realistic plan for Unit 2 decontamination.
(2)
Receipt of adequate. assurances that Unit 1 can be operated safely.
8112030305 811120 PDR ADOCK 05000289 P
.i Dr..Runzi'o J. Palla"dino November 20, 1981 Both of these conditions reflect my paramount concern for the health and safety of the people who live within the shadow of Three Mile Island, as well as the environmental integrity of the area.
Considerable progress has been made to date toward building the kind of consensus and financial commitments we need in order to deal with the. Unit 2 hazard.
The other condition can only be met, however, by the NRC itself.
Your agency has the exclusive jurisdiction over all questions regarding the safe operation of this, or any other, nuclear power plant in the country.
It would be foolish of me, as a layman, to attempt to substitute my judgment for yours on this matter.
However, I continue to believe it to be in the public interest for the NRC to fully address the views of a variety of sources on matters of such obvious importance to public i
health and safety.
It is in that spirit that I am forwarding for your e
review correspondence I have recieved from the Union of Concerned Scientists (UCS) and from U.S. Rep. Morris K.
Udall, chairman of the House Committee on Interior and Insular Affairs.
You will note that these letters raise several technical and procedural questions concerning the safety of a Unit 1 restart.
T urge you to conduct a careful and objective review of these concerns. If there are, in fact, any Unit 1 safety questions that have yet to be satisfactorily addressed, I suggest that now is the time for the NRC to address them.
I would appreciate a written response from you or your staff reflecting NRC's view of the various points raised by UCS and Rep. Udall.
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Govern r Attachment l
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== D 6 ww.k Honorable Richard Thornburgh.
Governor of Pennsylvania State Capitol Harrisburg, Pennsylvania 17120
Dear Governor Thornburgh:
This regards the strategy for funding the cleanup of Three Mile Island Unit 2 that you proposed on July 9, 1981.
I appreciate your thoughtful recorrendations on this matter as well as your commitment to working for a solution to this difficult problem.
As Chairman of the Cormittee in the House with primary jurisdiction over the Nuclear Regulatory Cornission (NRC) and the regulation of the commercial nuclear i,ndustry, I have been deeply involvec in inquiries into various aspects of the Three Mile Island accident. I have also actively participated in the ongoing national debate over where responsibility should lie for funding the cleanup of TMI-2 and any future reactor accidents. On May 4 and 5 of tnis year, the Subcoraittee on Energy and the Environment held hearings on the financial implications of the TMI accident; your proposed strategy-for funding the cleanup is a welcome addition to the record the Subcormittee has compiled on this matter.
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I would like to share with you some thoughts regarding the portion of your July 9 statement wherein you state l
that " contingent upon adequate safety assurances" from the NRC, you are prepared to support a decision to restart TMI Unit 1.
This statement is consistent with my own position on the restart of Unit 1.
In my view, the conditions established by NRC as prerequisites to any decision by the Commission to allow Unit 1 to go back on line have not been fulfilled.
I infer from the Office of Policy and i
Planning report appended to your statement that you agree with my assessment that Unit 1 is not physically ready to t
operate.
In particular, that report says that you would l
urge the postponement of restart of TMI-l until:
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2-The Babcock and Wilcox reactor design flaws which say have contributed to the accident in Unit 2 have been fully discovered and corrected in Unit 1.
(Report on the Cleanup of Three Mile Island, prepared by the Governor's Office of Policy and Planning, i U page 7.)
In view of your position on this matter and in light of GPU's urging in the strongest terms that TMI-l he permitte'd to resume operation, it is noteworthy to find continuing' resistance by GPU to requirements instituted for purposes of correcting deficiencies revealed by inquiries into the accident.
Among such deficiencies was the lack of instruments that would permit control room personnel to readily detect-that water was being lost from the primary cooling system and that the system was approaching a condition of inadequate core cooling (ICC).
Had there been a device, for example, to indicate water level above the core, the TMI opera, tors,would likely have continued to pump water into the system rather than taking actions that led to a loss of coolant over a period lasting more than two hours.
A constant theme that runs through the reports prepared in the wake of the accident is one noting the lack of instrumentation that would permit the TMI-2 operators to readily determine that a loss of coolant accident had occurred. A report of the staff of the President' Commission I
on the Accident at Three Mile Island states that instruments operators.{onofinadequatecoolingwouldhavehelpedtheThe Report of t for detect states that a design weakness was, "The lack of instrumentation 2
-to measure water level in the reactor vessel directly."
The report of the NRC's Special Inquiry Group states that, reactorcoolantinthemainreactorvessel."jngthelevelof "The plant did not have instrumentation shou
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The need for water level instrumentation was stressed as ear'ly as April 7, 1979 in a letter'to Chairman Sendrie fror. URC's.
i Advisory Committee on Reactor Safeguards (ACRS):
The Committee believes that, the analyses recommended l
above will demonstrate, as has the accident at l
l Three Mile Island, that additional information regarding
-i the status of the system will be needed in order for the plant operator to ' follow the course' of an accident and thus be able to respond in an appropriate manner _.
l l
1The President's Commission on the Accident at Three Mi'le Island, l
Report of the Technical Assessment Task Force, Vol.
I,
- p. 37.
1 2 Nuclear Accident and Recovery at Three Mlle Island, p. 10.
3NRC Special Inquiry Group, Vol.
I, p. 126 l
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, 3, 1tt s Asua, minimum, and in the' interim, it would be prudent t
tciconsider expeditiousl'y the provision of instrumen-tation that will provide an unambiguous indication of the livel of fluid in the reactor vessel.
Early n
consideration should be given also to providing remotely, controlled n.eans for venting high points
'x in the reactor' system, as practical.
1 The, latest' version of NRC's TMI Action Plan contained
- requirements'(Item II.F.2) for instrumentation to provide indications of inedequate core cooling.
This instrumentation y
kas te be described'in. -report submitted by January 1, 1981 l
. and to be installadi by :Ja'nuary 1,1982.
Subsequent to the'irposition o'f theseirequirements,' the ACRS in a June 9
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l; letter to the ERC Exe'cutive Director raised questions as to L'
'whether the implementation dates were premature in light k
of unanswer)ed questions as,to whether the proposed ICC instrurentation was actually needed, as to the conditions under"which it would be used,'and as to whether ICC instrumentatica night actually mislead the operators.
I On July 14,.after hearing from NRC and GPU officials, the ACRS concluded that ICC instrumentation should be l
installed..and that the MRC and GPU "should act promptly to establish'a, basis for selecting a suitable monitoring system" taking into account the reservations expressed'by
-the E RS'in its June 9 letter.
h At the Nee ^ ting leading to the' July 14 ACRS letter, URC staff reportedRto the ACRS that the staff would be willing to recommend, allowing TMI-l to operate without additional ICC instrumentation providing they obtained " evidence of reasonable progress" toward the installation of such i,
[2 instrumentation.
The staff reported to the ACRS, however, that there had been no such demonstration of " reasonable progress" j,
toward the installation of ICC instrumentation, and that t'
. up,tc this point (July 10, 1981) at least this
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q applicantLhas taken the position that they don't essentially, to be blunt, that they don't need a (ICC instrumentation) system and they're not going to install
~An.d.this is in spite of a staff indication.
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a,t least a year and a half ago, that that position was
' totall'y unacceptable."
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GPU has presented variousrexplanations for its failure to procsed with ICC instrumentation.
They have, in effect,
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' told the ACES that they did not perceive what this instrumen-r, tatien would add to that which already existed and they l~
ha,ve suggested that curren'tly available water level l instrumentation designs were inadequate.
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i 2 Uh11e in the eyes'of the'NRC staff GPU has not made suf-ficient progress toward fulfilling the requirement for ICC instrumentation, the staff has noted that commitments have been made to install ICC instrumentation at some 27 plants.
NRC staff, in fact, reported to the ACRS that GPU has been among the least responsive utilities on this matter, and that GPU has failed to provide the NRC evidence of having conducted an in-depth study of available equipment and that furthermore they have not indicated why such equipment would not be appropriate for TMI-1.
- 1. )
In sum, the picture that emerges is one wherein GPU has resisted implementing a requirement based upon a widely I
held engineering judgement which, while not unanimous, holds that ICC instrumentation would make a significant contribution to safety.
The NRC staff is in this case demonstrating a commendable commitment to compensate for unanticipated defects in pressurized water reactor systems.
The r~eluctance of GPU to meet the NRC requirement, to say nothing of its failure to go the extra mile, suggests that the current TMI management, as did its predecessor, holds that tne plant systems as they exist are adequate to cope with anticipated events; the.y appear to believe that unanticipated events simply will not occur.
This is of course the same line of thinking that led to GPU's present predicament.
The record of the ACRS meetings on TMI-l restart contains additional information on the readiness of TMI-1 which is not adequately summarized in the ACRS letter of July 14 to Chairman Palladino.
The record indicates, in fact, that less progress has been made toward satisfying the i
Commission's post-TMI requiremerts than is implied by the ACRS letter.
I commend this record to your attention for the light it sheds on the situation.
Sincerely, 2
A.0 L
anis usna.
C. airman 4
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1eo SCisNTISTS
'81 L'0V 30 P2:34 October 19, 1981 gj,,
Honorable Richard Thornburgh Governor Commonwealth of Pennsylvania Harrisburg, PA 17120
Dear Governor Thornburgh:
In a statenent you issued en July 9, 1991, you indicated a willingness to support the restart of the Three. Mile Island Unit 1 nuclear plant as a 2.
passib'.e neans of partis:1y financing the cleanup of the damaged Unit i
t
.n ycur statement, you made your support for Unit 1 restart "ccnt ngen Iupon adequate safety assurances."
UC3 has serious reservations about the safety of restarting as proposed by the GPU Nuclear Corperation and the Nuclear Regulatory TMI 1 These reservations sten from UCS'; participation in the Connission Staff.
NPC hea-ings on restart of Unit 1, as well as our centinuing review of the Our implementation of the " lessons learned fren the TMI-2 accident.
concerns may be broadly expressed as follows:
1)
After identifying many cf the safety issues raised by the 1MI-2 accident. NRC has largely fccused its attention and resourecs cr. quick, cheap These fixes have generally ignored the more fixes.
serious problems revealed by the accident.
As a result of restrictions in the scope of 2)the TMI-1 restart proceeding before NRC's Atonic Safety and LicensinC Board, important questions about the safety of rectarting TMI
- were not considered in the NRC hearings.
GTV's positi,,n -- that TMI-1 should be allowed to 3)restart unless it poses unique safety problems --
reduces NRC's standard of safety to the lowest ec-nOn denominator.
NRC has repeatedly extended its own deadlines for 4)implementing the P1I-2 " lessons learned" requiremer.ts at and other nuclear powerplants after continued TMI 1 pressure from the nuclear industry.
Cennitnents made by the NRC Staff and GPU Nuclear 5)
I during the hearing process have since been retracted or
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substantially modifisd.
Some of the e cernitments involve hsrdwcre improvcmsnts or plant staffing level upgradings wh'ich are directly related to the ca Mes of the TMI-2 G0LMETED accident.
UNC
- 1) NRC's Emphasis on Quick Fixes 81 NOV 30 P2':34 4A4 U.C3 has drawn from its participation in the TMI 1 restart heari'ngs;qrg ;p,.
firm conviction that " adequate safety assurances" have not been provided b"yN!Cz either the NRC Staff or GPU Nuclear.
If TMI-1 is restarted as presentlp "
proposed, it will be without adequate assurance that another accident more severe than the THI-2 accident cannot occur at THI-1.
Many factors contribute to this conclusion, but they can perhaps be summarized by the general observation that the initial impetus for serious reform in the immediate aftermath of the TMI-2 accident has been supplanted by a retreat to " business as usual."
'n'hile " business as usual" might arguably be an appropriate posture if the NBC and the nuclear industry had learned and applied the lessons from the TMI-2 accident, the unfortunate fact is that in many important respects they have not. Nuclear industry spokespersons frequently claim that all of the significant safety problems associated with the THI-2 eccident have been solved.
This is patently untrue.
Although the NRC's so-called
" Action Plan" does a relatively good job of identifying these safety problems, NRC's progress toward resolving then has been glacial at best.
In determining the priority assigned to implementing Action Plan items, the NRC used a 210-point rating systen. Only 100 points were based on safety significance.
The majority of the points were assigned for such factors as cost (both to NRC and the industry), the time required to solve the problem, and whether the item involved hardware modifications or improvements in the man-machine interface.
This approach has directed the NFC's attention to quick cheap fixes, rather than problems with high safety significance which involve more complex technical questions and require more time and expense to resolve. (A copy of the NRC's priority ranking system is enclosed for your reference.)
Today, two and onc-half years af*.er the TMI-2 accident, some of the nost serious safety issues (identified by all independent investigations of the accident) have not even begun te ta sdiressed in a neaningful way.
In Mnreh le81, NRC listed three new' gen.-i-safaty issues that sten directly fren the TMI-2 accident.
NRC dces not plan to resolve these issues until April, 1080 Based on NRC's past record, we have good reason to expect l
that schedule to be extended by nany years, t'FC is continuing its practice of classifyinc safety problems as generic as a way.to effectively postpone decisions en difficult technical questions. The hydrogen cont.rol and degraded core issues are two prime. examples. While tha NRC has spent literally thousands of man-hours finding ways to speea up the approval of new operating licenses, it is unwilling to adopt the same standards of expedition in setting deadlines to resolve these and nany other important safety problems that plague currently operating reactors, l
- 2) The Issues Ignored in *!:e Restart Hearings A decision authorizing restart of TMI-1 by the Atomic S'afety and Licensing Board and the Commission itself would not constitute a full endorsement of the safety of that unit. We say this because the scope of the restart hearings was legally restricted in a way that allowed t.he Board to consider only the precise sequence of even*.s that occurred at IMI-2 or very close analogs.
In essence, the Connission quite deliberately refused to look at other safety issues not directly involved in the TMI-2 accident.
This contrasts sharply with the current requirements for a reactor to receive a construction permit, an operating license, or an upgrading from provisional to full-term license. In each case, NRC rules require the utility and the NRC Staff to denonstrate publicly that each of the so-called " generic unresolved safety problems" has been resolved on a plant-specific basis or that conpensatory safety measures have been adepted.
This review has never been done for TMI-1, because it was criqinally licensed before the generic unresolved safety problems were public1y disclosed.
~
In the TMI-1 restart hearings, the Commission's refusal to look at safety issues beyond those directly involved in the TMI-2 accident amounts, in UC3's view, to deciding that safety problems will only be dealt with after they have caused an accident, if then. While NRC may have the legal right to limit its proceedings in this way, such restrictions cannot be justified on technical or common sense grounds.
One issue conceded by all parties to da directly involved in the TMI-2 eccident was effectively barred frem the hearing.
This is the issue of hydrogen gas control.
During the TMI-2 accident, large amounts of explosive hydrogen gas were generated when the reactor e, ore became heavily danaged and partially nelted.
The ancunt of hydrogen generated during the accident was 6 to 10 times larger than the maxinun credible amount cacified in NRC regulations.
As a result, a hydrogen explosier. occurred during the accident.
While that explosion did not breach the containment, no one yet knows whether the explosion danaged other equipment important to safety.
Neither the NRC nor GPU Nuclear has evel examined the safety equipment inside TM!-1--a much older plant than TMI-2--to determine whether a hydrogen explosion would compromise the safety of that plant.
GPU's only response to the hydrogen control issue has been to install a hydrogen recombiner in TMI-1 that is incapable of coping with the amcunt of hydrogen actually generated during the THI-2 accident, i
UCS had sought a fuller inquiry into the hydrogen issue.
- However, l
bercre the.estart hearin6, the Commission (by a 2-2 vote) refused to waive its existing hydrogen control regulation.
This pre-TMI-2 regulation bases the design of hydrogen control systems on the assumption that the maximun j
I anount of hydrogen generated will be only 1/6 to 1/10th the amount that was actually generated during the accident.
In a later decision, two NRC Commissioners bluntly explained the effect of the Connission's ruling:
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4-TMI 1 The Bcard [in this case) found ' relying en th in view of new instrur* ions to reaeter rsling] that, operators and other inprovements, er event whi.ch actually
' credible', and that, occurred two years ago was no longer tScrefore, there was no need to pursue possible remedial It is a finding that could only have been made by a group schooled in the arcane subtleties of nuclear steps.
No ordinary person is capable of such' foolish-tegulation.
After the TMI experience, this review of the ness.
' credibility' of an accident involving hydrogen has been a waste of the parties', the Board's, and the Connissien's It can only contribute to public cynicism about time.
nuclear regulation and the role of public hearings in the Duke Power Ce.
(Willian B.
decisionmaking procees.
and 2). Order (June 29, McGuire Nuclear Station. Units 1 Separate Views of Commissioners Gilinsky and 1981),
Bradford, slip opinion at 10.
is especially ironic to apply such tortured reasoninC to THI Ka he'.iave it it: elf.
Ar.othar issue that was severely restricted in the restart proceedings is the question of whether the equipment needed to safely shut down the in an accident has been qualified to survive the accident The NRC Staff's testinony was limited to the ability of the ri ar.t ecuirnent to survive a snall break loss-of-coolant accident of much smalle anvironment.
dimension than the TMI-2 accident on the remarkable grounds that an Mor did the NRC ever accident as severe as TMI-2 cannot happen again!
review for the restart proceedings the ability of safety-related equipment te survive other types of serious accidents, such as main stean line and high-energy line breaks.
Because o,f these limitations This is far from a theoretical problem.
en the scope of the hearings, UCS was prevented from presenting evidence to have not Board that many safety-related components in TMI 1 The NBC Staff and GPU Huelear the Licensin6 been qualified to survive serious accidents.
prenised to address these questiens by July 1982, but not in a way that Nor is there any reason to allows open hearings.or public participation. A large nunber of utilities expect the July 1982 date to be a firn one.have already applied for a 13-mnnth We have little doubt but that, after the sac-s parfectly will.ing to grant.
purlic attention that accompanied the restart hearings is over, line tha.uly 1992 " deadline."
The Lowest Common Denominator is not the Apprcpriate Standard 3)
_o_f Safety There are a large number of other issues that were covered during the restart hearings in which UCS believes that the company and the NRC have proposed to compromise safety in order to get TMI-1 back on line and toBecaus keep other reactors in operation. issued a decisien on design issues, we can It is therefore prenature to the company's and the NRC Staff's positions.
discuss these issues in'datail; however, if you or your. staff would like to.
be brie' red on them, we would be pleased t do so.
A few exanples of these issues are: whether the relief valve (PORV) which caused the TMI-2 accident should be. classified as a component.
important to safety and required to meet strict standards of design and construction; whether the method of supplying electric power to the pressurizer heaters jeopardizes the power source for all in-plant safety systens, thereby making THI-1 nere dangerous than it was before the'TMI-2 accident; and whether the reacter operators must be provided with positive indication when valves in safety systems are not in their correct positions (the THI-2 operators were unaware that two emergency feedwater valves were closed).
In each case, GPU and the NRC Staff argued against the imposition of stricter requirements.
(UCS recently moved to reopen the hearing on sone of these design issues because the NRC Staff failed to disclose that sone Staff menbers recomnended that certsin stricter safety measures advocated by UCS be adopted, contrary te. the Staff's testimony during the hearing.)
UCS has been astonished at the attitude consistently exhibited by GPU Nuclear throughout the restart hearin6s.
CfD has time and again responded to safety issues by taking the position that if any other plants are operating with similar problens, TMI 1 should likewise be permitted to oparate.
This reduces the standard of public protection to the lowest common denominator--a " standard" dictated by considerations of expediency and accidents of history.
It substitutes for reasoned judgment the croposition that the worst shall set the pace for all.
On the contrary, GPU Nuclear should, we believe, exhibit the strongest commitment to leadership in safety after its experience at TMI-2.
- 4) NRC's " Deadlines" are Infinitely Flexible Another consistent, very troubling pattern emerged during the TMI-1 l
restart hearings:
NRC's so-called " deadlines" for achieving compliance with T!!I-?-related requirements are not true deadlines, but instead are infinitely flexible.
Virtually all of the decdlines have already been extended.
Many requirements originally had implementation deadlines of January 1900 or January 1981 In successive issuances, the NRC has For postponed these deadlines to July 1981, and beyond in some cases.
l example, the deadline to upgrade the emergency feedwater systen to meet l
NRC's requirer.ents for systems important.to safety was originally January 1
1991, was extended to July 1981, and is being considered now for an additional delay.
The NRC Staff announced during the restart hearing that all deadlines cecurring after June 30, 1981 are subject to reconsideration.
These deadlines cannot in any Jense be called firn.
Thus we have no basis for believing that any promises of future action by specific dates will be NRC's history clearly demonstrates that the convenience of the f
kept.
licensees will take precedence over strict enforcement of safety l
requirements, including those requirements that sten directly from the THI-2 accident.
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- 5) GPU's Commitments Have Been Withdrawn For example, durin5 Ncr can GPU Nuclear's con.itnents be relied upon.
the TMI-2 accident noncondensible gas and steam accumulated in the reactor coolant systen, biceking the circulation of water needed to cool the core.
Circulation of coolant was established only by the use of the reactor coolant pumps, which are not considered important to safety and therefore need not meet NBC's requirements to ensure the reliability of safety In order to provide a reliable method of reroving noncondensibic systens.
gas and steam, GPU originally "conmitted" to installing new vents for this purpose at TMI-1.before it restarts. However, GPU has since abandoned this When TMI-1 restarts (assuming the Licensing Board so rules) it comnitnent.
will be in essentially the same condition as VII-2 was during the accident.
The vents will not be installed until many months in the future.
~
In concluding, we must emphasize that the specific issues mentioned here are only a very few exanples of the safety problems that remain As you recognized when you asked UCS to provide an unresolved at TMI-1 independent technical evaluation of the krypton venting, these questions and become entangled with econonic and political are complex considerations. We advised you then that the venting wauld not pose a This time our significant radiological health hazard to the public.
conclusion is the opposite:
restart of TMI-1 in the condition proposed by GFU Nuclear and the NRC Staff would not provide adequate assurance of j
safety to the people who live around it.
NRC's decisions are strongly influenced by its regulatory history and I
its extreme reluctance to take any action that might suggest to the pub 11e l
Tnus, each time NRC that currently operating reactors are less than safe.
l exaninos the safety of a particular plant, its response is colored by l
considerations of how its action might highlight past mistakes or req, ire chances in other plants. Your jurisdiction is much clearer:
you must consider only the interests of your constituents. UCS firmly believes that l
rest art of TMI-1 as currently proposed is not in their interest.
One more point deserves your attention.
Your cost-sharing proposal for the cleanup of Unit 2 appeared to rely on the restart of Unit 1 as the We basis for raising almost one-third of the remaining cleanup costs.
agree with you that the cleanup of Unit 2 is necessary and should not be We also believe that your cost-sharing proposal represents the
' delayed.
most pronising approach developed.thus far toward br?aking the cleanup l
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While, as you have pointed out, the two issues -cleanup of Unit 2 and restart of Unit 1-- are interrelated, we hope you will not link them so tiShtly thr.L the result is two, rather than one, unsafe nuclear plants at ThreeJiile Island.
Sincerely, Q.l He'nry W. Kendall Chairman Board of Directors
//
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Robert D. Pollard Nuclear Safety Engineer
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5,.{
g Ellyn R. Weiss General Counsel Enclosure e
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A TABLE B.1 Tl'! ACTf 0N PLAN PRIORITY RI'. KING SYSTEM Rank I.
Safety Significance 100 High....................................................,.......
50 Medium..........................................................
'O Low.............................................................
i II.
Type of Improvement 20 Improves the human element......................................
10 Fixes the hardware...............................................
III.
Utilization of Resources 20 Project is ongoing, and resources would be wasted if stopped....
A.
10 Project has not yet been initiated..............................
B.
Staff resource requirement:
Total - 550K = 1 my 20 Small (< 2 my)..................................................
10 Medium (> 2 < 10 my)............................................
O Large (> 10 my).................................................
C.
Industry resource requirement:
Total per unit over 40 yr life - 1 my = $50K 20 Small(<$1.0$).................................................
O Large (> $1.0M).................................................
l Timing of Improvement (i.e., how quickly will the expected benefit IV.
begin to be realized after initiation of task) 30
.Short-term (within one year)............................
20 Near-term (within two years)........
10 Long-term (within three years)..................................
0 Extended beyond three years.........
8.1-1
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