ML20039C258

Response to ASLB 811216 Order Re HPI Questions on NRC Oct 1981 Operator Exams.Questions,Examinee Answers,Nrc Answer Key & Relevant Emergency Procedures Are Significant & Relevant to Ucs Contention 10.W/Certificate of Svc

ML20039C258
Person / Time
Site:	Three Mile Island
Issue date:	12/24/1981
From:	Jordan W, Weiss, Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:
References
NUDOCS 8112290137
Download: ML20039C258 (9)

Text

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. 4 q* tbtKETED UsuM' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION &g 7g gg) g6

,s1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ;E?,2 DEh i[j}yf In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

• (Restart)

)

(Three Mile Island Nuclear )

Station, Unit No. 1) ) g UCS RESPONSE TO BOARD ORDER ON HPI QUESTIONS AND ANSWERS Introduction By its Memorandum and Order dated December 16, 1981, the Board adopted as its order the proposal by Licensee in its letter of December 16, 1981, relative to the High Pressure Injection (HPI) questions and answers on the TMI-1 operator license examinations. The portion of the Licensee's letter applicable s s to this filing is item number 3 beginning on page 2 of the December 16, 1981, letter:

On or before December 24, 1981, any party may file with the Special Master and the Board comments on this proposal, on the significance of previously distributed answers to the HPI question and on the relevance of such answers to the reopened hearing or to any other issues in the proceeding.

Such comments may include a request by any party that the record of the hearing on non-cheating issues-be reopened for receipt in evidence of the above listed documents and/or that witnesses be called to address such documents.

- Such comments shall be hand delivered to the Board, the NRC staff, Licensee, UCS and Sholly by those parties having counsel or offices in the District of Columbia metropolitan area. Other filings may be made by regular mail on or before December 24, 1981.

The "above listed documents" referred to by the Licensee are:

1. The NRC answer keys (including any revisions) to the HPI questions; O$dOh% 0\

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2. The answers of all examinees to the HPI questions; and

3. Licensee's Emergency Procedures relevant to the question of throttling or terminating HPI. 1 On December 17, 1981, Licensee distributed to the Board and a

parties the following emergency procedures: EP 1202-6B, Revision 7, dated 03/19/81; EP 1202-6C, Revision 7, dated 03/31/81; EP 1202-2, Revision 7, dated 06/29/81; and EP 1202-5, Revision 13, dated 08/11/81.

UCS's Comments and Requests for Additional Information and to Reopen the Record UCS concludes that the . operating license exam questions on emergency operating procedures, the answers to those questions by all examinees, the NRC answer keys to those questions, and the Licensce's emergency procedures relevant to those questions are significant and relevant to UCS Contention No. 10. Therefore, UCS requests that the record be reopened to receive this information into evidence.

However, UCS does not believe that the documents previously distributed by the Staff and Licensee represent the complete set of all such information. Furthermore, we question whether the versions of the emergency procedures distributed by the Licensee are the appropriate revisions. The issues of significance, relevance, completeness, and appropriateness are discussed more fully below.

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Completeness The Staff has distributed'information only on question E3 on the "A" reactor operator examination, question E6 on the "B" reactor operator examination, and the oral examinations. These three examinations were administered in October 1981. UCS believes that, at a minimum, the identical scope of information concerning the written and oral examinations administered in April 1981 should be distributed and received into evidence. For example, question F.5.c on the "A" reactor operation examination administered in April 1981 was as follows: "Under what conditions may HPI be throttled after ESAS initiation during a LOCA?" 'Nhile -bot identical to the wording of questions E3 and E6 on the October exams, perusal of the answer key and the grading of the answers to geustion F.5.c on the April exam shows that the questions are, for a l'1 practical purposes, identical.

In addition, UCS has been served with no information concerning the content or results of the oral examinations administered in April 1981, all of which have a bearing on the adequacy of operator training and the validity of the operator examinations themselves, as discussed below.

Therefore, UCS requests that the relevant question (s), answers of all. examinees, the NRC answer keys, and the relevant oral examinations administered in April 1981 be served on the Board and the parties.

We also belive that the Board or the Special Master should inquire into the reasons for: 1) Shifting the HPI question from Category F, " Standard and Emergency Operating Procedures," on the April exam to Category E, " Safety and Emergency Systems," on the October exam and 2) changing the value of the question from 1 out of

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14 points on the April exam to 3 out of 13 points on the October exam.

A brief review of the exams shows that if the HPI question had remained in Category F (the appropriate category in UCS's view) on the October exam, the results of the exam would have changed from passing to failing for at least one examinee (e.g. individual "AA") regardless of whether the point value was 1 or 3. We also believe that repeating f

a question from the April exam in the OctobLc exam casts doubt on the "alidity of the re-exam. Furthermore, considering the TMI-2 accident, the subsequent operator training, and the fact that the identical question was asked on two sequential exams, we believe that any individual who still does not know under what conditions it is permissible to throttle HPI is not qualified to be a reactor operator or a senior reactor operator regardless of his grade on the exam.

Appropriateness UCS questions whether the versions of the emergency procedures distributed by the Licensee are the appropriate versions. We believe that the versions of the Energency Procedures that should be distributed to the Board and parties are the approved versions in l effect at the time the exam was administered and the latest approved ver'sions. The former is necessary to judge whether the answers are correct and the latter is necessary to judge the extent to which the training and operator knowledge conform to the actual emergency l

l procedures now in effect for TMI-1.

EP 1202-6B', Revision 7, dated 03/19/81 is already in evidence as Licensee Exhibit 48. Licensee should specify whether this is the

latest' version and, if not, the latest version should be distributed and received into evidence.

EP 1202-6C, Revision 7, dated 03/31/81, EP 1202-2, Revision 7, dated 06/29/81, and EP 1202-5, Revision 13, dated 08/11/81 are all marked "For Infcirmation Only" (which does not appear on Licensee Exhibit 48) and all lack the stamp "Rev. Review Book Controlled Copy" (which does appear on Licensee Exhibit 48). EP 1202-6C also lacks the stamp " Controlled Copy for Use in Unit 1 Only" which appears on the other three emergency procedures distributed by Licensee.

Furthermore, EP 1202-2 and EP 1202-5 postdate the April 1981 exams.

Therefore, UCS requests that, for each emergency procedure which Licensee believes is relevant t$ throttling or termination of HPI, the version (s) that was (were) fully approved at the time the April and October 1981 exams were administered and the latest fully approved version be distributed and received into evidence. It is possible that from one to three versions of each relevant emergency procedure are the appropriate versions to be distributed aand received into

. evidence.

Relevance The material discussed above is relevant to UCS Contention No.

10. In essence, UCS argued that a lesson learned from the TMI-2 accident is that safety systems at TMI-l should be designed so that the operator can not terminate operation of a safety system until its safety function' has been completed. Licensee and Staff argued, in essence, that the operator can be relied upon not to terminate prematurely the operation of a safety system, in part, because of the m -

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add iti'onal training given since the TMI-2 accident. Licensee and Staff also asserted that operators would be capable of assessing unforeseen accident sequences and taking correct action.

UCS believes that the information discussed above is relevant because it demonstrates that the arguments advanced by the Licensee and the Staff are not valid.

f Significance The significance of the HPI questions, answers, answer keys, oral examination notes, and emergency procedures is that they provide the most valid basis available. for"judgirig the adequacy of the operators' knowledge'concerning safe operation of TMI-1. The record to date only contains evidence which is primarily of a hypothetical or theoretical nature concerning the extent to which' operators will perform correctly during future accidents at TMI-1. Whether the actions taken since the TMI-2 accident are sufficient to provide reasonable assurance- that operator action will be correct during f.2ture accidents is an important issue in this proceeding and the best available evidence should be in the record.

UCS believes that the HPI documents in question raise a "significant safety (or environmental) issue" which would have led to "a different result . . . had the newly proffered material been considered initially." Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plants, Units 1 and 2), ALAB-598, 11 NRC 876, 879 (1980). The premature termination of HPI during the TMI-2 accident was unquestionnably a majot factor in the accident. The TMI-2 accident has been the subject of intensive study by the Licensee and

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others' for the last three years. Operator training conducted since the accident has emphasized the conditions which must be achieved prior to throttling or terminating HPI. An identical question was asked on both the April and October 1981 examinations concerning this subject. The exam results indicate'that some candidates for Reactor Operator and Senior Reactor Operator licenses still do not know under f what conditions it is permissible to throttle or terminate HPI. The signilicance of the HPI documents in question is that they would change the decision on UCS Contention No. 10. Furthermore, this demonstrates beyond reasonable doubt the futility of information hoping that operators will be able to analyze and take proper corrective action during unforeseen a'ccident sequences. Thus, one of the principal arguments advanced by the Licensee and the Staff against the TMI-1 design advocated by UCS is shown to be without merit.

Accordingly, the record must be reopened to receive the HPI documents identifed above.

December 24, 1981 RESPECTFULLY SUBMITTED, DATED:

[ W f d//a ,

Ellyf R. Weiss f /

AM&s WilliameST Jo'rdan , III Harmon and Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 Counsel for UCS l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '81 DEC 28 All :56 BEFORE THE ATOMIC SAFETY AND LICENNSING BOARD- . '

NChiiid[kI5fbCE i;RAICH In the Matter of )

) -

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 ,

) , (Restart) ~

(Three Mile Island Nuclear

) .

Station, Unit No. 1) ) x s

CERTIFICATE OF SERVICE I hereby certify that copies of "UCS RSSPONSE'TO BOARD. ORDER ON )?

HPI QUESTIONS AND ANSWERS" have been served on the .following -persons by deposit in the United States mail, first clas's postage prepaid this -

24th day of December 1981. .

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Nunzio Palladino, Chairman *

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U. S.. Nuclear Regulatory Atomicf$afety and Lic,ensing Board Panel

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Commission .

Washing ton , D.C. 20555 881 We'st Ou6er Drive Oak Ridge, Tennessee'37830- -

Victor Gilinsky, Commissioner _

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U. S. Nuclear Regulatory **Dr. Linda WQctittle Commission Atomic Sifety;tnd Licensing -

Washing ton , D .C . 20555 . Board Panel' 5000LHormitage Drive Peter Bradford, Commissioner Raleigh,; North Carolina 27612 U. S. Nuclear Regulatory ~Y

,,s h ' l - p Commission *

• Pro fessor Gary '.L.'lMi,lhollin -

Washington D.C. 20555 1815 Jefferson Streete2 ,

Madison, Wisconsip 53711 s John Ahearne, Commissioner (Tj Judge Gary J. Edles,j,Chaidman U. S. Nuclear Regulatory ~

Commission Atomic Safety an6 LicCnsing r T'

Washington, D.C. 20555 Appeal Board %F U. S. Nuclear Regulatory p" s s

Thomas Roberts, Commissioner Commission '_ - w ;  ; w ,.

U. S. Nuclear Regulatory Washington, D.C. 20555 ff .y '

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Washington, D.C. 20555 Judge John H. Buck- : ' - '

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Robert"Adlet ,j Es,q. .? J [, _. Q. , .

Assistant-Attorney General tMr . Steven ..C. 3 holly

'505 Executine' Hor.se'C ' Union of Cpnce'rned Scientists i P.O.J. Box ~2,357 1725.Ey'eN Gte, N.W., Suite 601

, Harrist?brg N ennsylvania 11120 Wash i'ngon ,) D. C . 20006

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! Louise Biadfof:d

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Walter W. CohenfEsq N Washin D.C. 20555

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[ T [ gton, 's e 1425 Strawberry bquare' *Gerge F. Trowbridge, Esq.

Harrisburg, P annsylvani:i l'U 27 s 'Sh hw , .1)i ttman , Potts &

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Jordan D.? Cunnirigham, E s q . ' ' - 180'O ' M St'r e e t , N.W.

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'2 Hat t.istf ulg', Pennsylvania 1, s , DocR/atir[and Service Section 1 , .

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' Deputy / Attorney Gene 1~31/ . .

H Y ,Divicion of; Law - Room 316' WashingtCn,*D.C. 20555

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C- Dr. Judith Hi Johnsrud A

- ' ' Dr. Chauncey Kepford _b _ #CMM

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• Hand delivered December 24, State College, PA 16801 1981. Staff copy delivered'to

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• William S. / Jordan, I I I ,- Esq.

b' Ha'rmon & Weiss * ** On advice of Doris Moran,

[,1'i 1725 Eye St. DN.W., Suite 506 the Board and Special' Master Washington, D.C. 20006, . copies will be hand delivered early a.m. on Monday, December s

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John A. Levin, Esq. -C 28, 1981.

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T Assistant Counsel , ,

< Pennsylvania Public Utility Commission P.O. Box 3265 Harrisburg, Penngylvania 17120 n

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