ML20039D097

Opposes Restart of Facility

ML20039D097
Person / Time
Site:	Crane
Issue date:	12/23/1981
From:	Huber M AFFILIATION NOT ASSIGNED
To:	Palladino N NRC COMMISSION (OCM)
References
NUDOCS 8112310313
Download: ML20039D097 (8)

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QCEER5 TESTS j

October 19, 1981 j

l Hsnorable Richard Thornburgh jl Governor

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Commonwealth of Pennsylvania.

Harrisburg, PA 17120

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Dear Governor Thornburgh:

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In a statement you issucc on July 9, 1981, you' indicated a willingness I

to support the restart of the Tnree Mile Island Unit 1 nuclear plant as a possible means of partially financing the cleanup of the damaged Unit '2.

In your statement, you made your support for Unit 1 restart " contingent upon adequat.e safety assurances."

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UCS has serious reservations about the safety of restarting TMI-1 as proposed by the GPU Nuclear Corporation and the Ndelear Regulatory Commission Staff.

These reservations stem from UCS's participation in the NRC hearings on restart of Unit 1, as well as our continuing review of the implementation of the " lessons learned". from the THI-2 accident. Our concerns'may be broadly expressed as follows:

1) After identifyiitg many of the safety issues

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raised by the TMI-2 accident, NRC has largely focused its attention and resources on qui.ci:, cheap fixes.

These fixes have generally ignored the more serious problems revealed by the accident.

l 2)

As a rasult of restrictions in the scope of the THI-1 restart proceeding before NRC's Atomic ~ Safety and Licensing Board, important questions about i

the safety of restarting THI-1 were not considered in the NRC hearings.

3)

GPU's position - that THI-1,should be allowed to i

restart unless it poses unique safety problems -

reduces't!RC's standard of safety to the lowest common denominator.

24 ) HRC has repeatedly extended its own deadlines for implementin6 the TMI-2 " lessons learned" requirements at TMI-1 and other nuclear powerplants after continued pressure fro:n the nuclear industry.

1 5)

Commitments made by the NRC Staff and GPU Nuclear during the hearing process have since been retracted or 1384 Massachusetts Avenue

• Carnbodge, Massachusetts 02238

• Tetecnune g617) 547 5552 1725 i Street. N.W.

• Swte 631 Washer.gton. D.C. 20006

• Teleohone (2021296.E0.)

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' tubstantially inodifisd.~

Some of these commitm'ents involva hardware improvements or plant staffing level upgradings which are directly related to the causes of the THI-2 accident.

1) NRC's Emphasis on Quick Fixes UCS has drawn from its participatibn in the THI-T restart hearings a

' firm conviction that " adequate safety assurances" have not been provided by oither the NRC Staff or GPU Nuclear.

If.TMI-1 is restarted as presently proposed, it will be without adequate assurance that another accident more cGvere than the TMI-2 accident cannot occur at TMI-1.

Many factors

' contribute to this conclusion, but they can perhaps be summarized by the gsneral 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."

While " business-as usual" might arguably be an appropriate posture'if j

the NRC and the nuclear industry had learned and applied the lessons from the THI-2 accident, the unfortunate fact is that in many important respects th y have not.

Nuclear industry spokespersons frequently claim that all of the significant safety problems associated with the TMI-2 accident have bsen solved.

This is patently untrue.

Although the HRC's so-called l

DAction Plan" does a relatively good job of identifying these safety problems NRC's progress toward resolving them has been gla, al at best.

In determining the priority' assigned'to implementing Action Plan iterr.s the NRC'used a 210-point rating system. Only 100 points were based-en safety significance.

The majority of the points were ass.igned for such factors as cost (both to NRC and the industry), the time required to solve l

the problem, and whether the item involved hardware modifications or improvements in the man-machine interface.

This approach has directed the

,,NRC's attention to quick cheap fixes, rather than problems with high safety significance which involve more complex technical questions and require r

more time and expense to resolve. (A copy of the NRC's priority ranking system is enclosed for your reference.)

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i, Today, two and one-half years after the THI-2 accident, some of the most serious safety issues (identified by all independent investigations of

.the accident) have not even begun to be addressed in a meaningful way.

In

• March 1981 NRC listed three new generic safety issues that stem directly i

from the TMI-2 accident.

NRC does not plan to resolve these issues until April, 1984.

Based on NRC's past record, we have good reason to expect t,

that schedule to be extended by many years.

HRC in continuing its practice t

of classifying safety prob 1 cms as generic as a way to effectively pastpone dreisions on difficult technical questions.

The hydrogen control and l

dagraded core issues are twc prime examples.

While the NRC has spent literally thousands of man-hours finding ways to speed up the approval of new operating licenses, it is unwilling to adopt the same standards of

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expedition in setting deadlines to resolve these and many other important cafety problems that plague currently operating reactors.

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2) Th3 Issuos Ignored g tha I?nstart 'Haarings i

A decision authorizing rest' art of TMI-1 by the Atomic Safety and l

- Licensing Board' and the Commission itself would not constitute a full I

cndorsement of the safety of that unit. We say this because the scope of the restart hearings was legally restricted in a way that allowed the Board

-to consider only the precise sequence of events that occurred at THI-2 or j

very close analogs.

In essence, the Commission quite. deliberately refused j

to look at other safety issues n't dire ^ctly involved in the THI-2 accident.

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i 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 demonstrate publicly that each of the alled " generic unresolved safety problems" has been resolved on a l

,...st-specific basis or that compensatory safety measures have been cdopted.

This review has never been done for TMI-1, because it was.

criginally licensed before the generic unresolved safety problems,were publicly disclosed.

In the TMI-1 restiart hearings, the Commission's refusal to look at-cafety issues beyond.those directly involved in the TMI-2 accident amounts, in UCS'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'be directly involved in the TMI-2 cecident was effectively barred from the hearing.

This is the issue of hydrogen gas control.

During the TMI-2 accident

'arge amounts of cxplosive hydrogen gas were generated when th'e r.etor core became heavily damaged and partially celted.

The amount of hydrogen generated during the accident was 6 to 10 times larger than the maximum credible amount specified in NRC regulations.

As a result, a hydrogen explosion occurred during the accident, l

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While that explosion did noti breach the containm' nt, no one yet knows e

whether the explosion damaged other equipment important to safety.

Neither the NRC nor GPU Nuclear has even cxamined the safety equipment inside 3

,THI-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 THI-1 that is incapable of coping with the amount of hydrogen actually generated during the THI-2 accident.

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UCS had sought a fuller inquiry into the hydrogen issue.

HoweTrer,

before the restart hearing, 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 a'ssumption that the maximum tmount of hydrogen generated will be only 1/6 to 1/10th the amount that was cetually generated during the accident.

In a later decision, two NRC Commissioners bluntly explained the effect of the Commission's ruling:

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Tha Bocrd [in this casal found (relying on ths THI l ruling] that, in view of new instructions to reactor operators and other improvements, an event which actually occurred two years ago was no longer ' credible', and.that.

.- therefore', there was no need to pursue possible remedial

' steps.

It is a finding that could_only have been made by

.a group schooled in the arcane-subtleties.cf nuclear-i

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regulation.

No ordinary person is capable of such foolish-ness.

After the TMI experience., this review of the

'eredibility' of an accident involving hydrogen has been a waste of the parties', the Board's, and the Commission's time.

It can only contribute to public cynicism about I

, huelear regulation and the role of public ' hearings, in the,

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decisionmaking process. Duke Power Co.

(William B.

'- AcGuire Nuclear Station, Units 1 and 2), Order (June 29.

1981), Separate Views of Commissioners Gilinsky and i

-Bradford, slip opinion at 10.

We believe it is especially ironic to apply such tortured reasoning.to TMI i

itself.

j Another' issue that was severely restricted in.the restart proceedings l

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is the question of whether the equipment needed to safely shut down the j

plant in an accident has been qualified to survive the accident environment.

The NRC Staff's testimony was limited to the ability of the equipment to survive a small break loss-of-coolant accident of much smaller l

1 dimension than the TMI-2 accident on the remarkable grounds that an

' accident as severe as THI-2 cannot happen again!

Nor did the NRC ever review for the restart proceedings the ability of safety-related equipment 2

• to survive other types of serious accidents, such as main steam line and high-energy line breaks.

i This is far from'a theoretical problem.

Because of these limitations j

on'the scope of the hearings, UCS was prevented from presenting evidence to the Licensing Board that many safety-related components in THI-1. have not been qualified to survive serious accidents.

The NRC Staff and GPU Nuclear promised to address these questions by July 1982, but not in a way that allows open hearings or public participation.

Nor is'there any reason to expect the July 1982 date to be a firm one. ' A large number of utilities j

have already applied for. a 13-month blanket extension, which the NRC Staff l

seems perfectly willing to grant. We have little doubt but that, after the

, public attention that acccmpanied the restart hearings is over, GPU will line up with the other utilities if it finds it inconvenient to adhere to

. -.the July 1982 " deadline."

3)

The Lowest Common Denominator is not the Approcriate Standard of Safety There are a. large number of other -issues,that were covered during the restart hearidgs in which UCS believes that the company and the NRC have proposed to'ecmpromise safety in order to get THI-1 back on line and to keep other reacters-in operation.

Because the Licensing Board has not yet issued a decision on design issues, we cannot say whether-it will accept the ccmpany's and the NRC Staff's positions.

It is therefo e premature to e

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,. ' discuss thesn'issuis in datail; howsysr, _if you or' your staff would lika to l

be briefed on them, we would be pleased to do so.

.A few examples of these issues ar.e: whether the relief valve (PORV).

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which caused'the TMI-2 accident should be classified as a component irportant to safety and required to meet strict standards of design and l

construction; whether the method of supplying electric power to the pressurizer heaters" jeopardizes the power source for all in-plant safety systems, thereby making THI-1,more dangerous than it was before the TMI-2 cccident; and whether the reactor ~operat' ors 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

' cf stricter reqP ements.

(UCS recently moved to. reopen the hearing,on i

come. of these design issues because the NRC Staff failed to disclose tihat i

some Staff members' recommended that certain stricter safety measures j

cdvocated by UCS be adopted, contrary to the Staff's testimony during the

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hearing.-)

UCS has. been astonished at the attitude consistently exhibited by GPU Nuclear throughout the restart hearings ~.

GPU has time and again responded to safety issue's by taking the position that if any other plants are operating with similar problems, TMI-1 should likewise be permitted to

. operate.

This' reduces the standard of public protection to the lowest

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common denominator--a " standard" dictated by considerations of expedienc'y l

and accidents of history.

It substitutes for -reasoned judgment the i

proposition 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 it THI-2.

4) NRC's " Deadlines" are Infinitely Flexible Another consistent, very troubling pattern emerged during the TMI-1 restart hearings:

NRC's so-called " deadlines" for achieving compliance with THI-2-related requirements are not true deadlines, but instead are infinitely flexible.

Virtually all of the osadlines have already been extended.

Many requirements origi,nally had implementation deadlines of January 1980 or January 1981. In successive issuances, the NRC has postponed these deadlines to July 1981, and beyo'nd in some cases.

For exemple, the deadline to upgrade the emergency feedwater system to meet NRC's requirements for systems important to safety was originally January

• 1981, 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, cccurring after June 30, 1981 are subject to reconsideration.

These -

deadlines cannot in any sense be called firm.

Thus-we have no basis for believing that any promises of future action by specific dates will be ks'pt.

NRC's history clearly demonstrates that the convenience of the licensees will take precedence over strict enforcement of safety requirements, including those requirements that stem directly from the THI-2 accident.

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5) GPU's Commitments Have Been With' drawn Nor,.can GPU Nuclear's commitments be relied upon.

For example, during

.the TMI-2 accident noncondensible gas.and steam accumulated.in the reactor coolant system, blocking 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 NRC's requirements to ensure the reliability of safety systems.

In order to provide a reliable method of removing noncondensible cas and steam, GPU originally " committed" to installing new vents for this

= at TMI-1 before it restarts. However, GPU has since abandoned this.

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When THI-1 restarts (assuming the Licensing Board so rules) it

, will be in essentially the same condition as TMI-2'was during the accident.

The vents will not be installed until many months in the future.

T In cone,1uding,we must emphssize that.the specific issues mentioned here are only a very few examples of the safety problems' that remain unresolved at TMI-1.

As you recognized when you asked UCS to provide an independent technical evaluation' of the krypton venting, these questions are complex and become entangled with economic and political

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considerations. We advised you then that the venting would not pose a significant radiological health hazard to the public.

This time our conclusion is the opposite:

restart of THI-1 in the condition proposed by GPU Nuclear and the NRC Staff would not provide adequate assurance of safety,to the people who live around it.

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NRC's decisions are strongly influenced by its regulatory history and its extreme reluctance to take any action that might suggest to the public that currently operating reactors are less than safe.

Th.us, each time NRC examines the safety of a particular plant, its response is colored by considerations of how its action might highlight past mistakes or require I

cdanges in other plants.

Your jurisdiction is much clearer:

you must consider only the interests of your constituents.

UCS firmly believes that j

restart of THI-1 as currently proposed is not in their interest.

One more point deserves your attention.

Your cos.t-sharing proposal for th.e cleanup of Unit 2 appeared to rely on the restart of Unit 1 as the basis for raising almost one-third of the remaining cleanup costs.

We agree with you that the cleanup of Unit 2 is necessary and should not be delayed.

We also believe that your cost-sharing proposal represents the

, most promising approach developed thus far toward breaking the cleanup m

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a While, as you have pointed out, the two issues -cleanup ^

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Tunding logjam.

of Unit 2 and restart of Un'it 1-are interrelated, we hope you will not link them so tightly that the result is two, rather than.one; unsafe t

nuclear plants at Three Mile Island, 1

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Sincerely, I

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I Henry W. Kendall Chairman Board of Directors h

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t Robert D. Pollard i

Nuclear Safety Engineer Mf

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Ellyn R. Weiss General Counsel t

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