ML20039D722

Response to Licensee & NRC Comments on HPI Questions & Answers.Aslb Should Grant Ucs 811224 Request to Reopen Record to Receive HPI Documents Into Evidence.Certificate of Svc Encl

ML20039D722
Person / Time
Site:	Three Mile Island
Issue date:	01/04/1982
From:	Bishop L, Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:
References
NUDOCS 8201060056
Download: ML20039D722 (9)

Text

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00LKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING AR OFFICE Cr 3Emi In the Matter of ) skh "'

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart) N (Three Mile Island Nuclear ) [ D Station, Unit No. 1) ) p N WCip; UCS RESPONSE TO LICENSEE AND STAFF COMMENTS ON HPI QUESTIONS AND ANSWERS D

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On December 24, 1981, UCS received copies of the L i c QLQ' e n s ;ei'~., e a nck Staff comments on the HPI questions and answers. The Commonwealth's comments, dated Decenber 24, 1981, were not received by UCS until December 31, 1981. We have not received comments from any other party. Therefore, this filing responds only to the Licensee and Staff Comments.

We are filing this response to those comments today, January 4 1982, pursuant to permission granted by the Chairman by telephone on Wednesday, December 30, 1981. On that day, Counsel for UCS contacted Counsel for the Staff and the Licensee, both of whom indicated that they would oppose a request for extension to January 4, 1982. As a result, Counsel for UCS telephoned the Chairman, indicated that UCS needed such an extension and that the Staff and Licensee were opposed, and requested a conference call if necessary. The Chairman stated that UCS could file this response on Monday, January 4, 1982, and 1/

asked that his ruling be memorialized in this filing.- m\Jso3 J

1/ - We note that while we received the response filings from the Staff and the Licensee on Wednesday, December 30, 1981, neither Counsel nor any employee of UCS has read that filing prior to serving this filing, i

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Response to-Staff Comments The Staff.did not. comment with any-degree of specificity.on the relevance of the . HPI documents to the "non-cheating" proceeding.

Staff only states that it "does not challenge the relevancy of_the HPI documents to the 'non-cheating' - p r o c e e'd i n g . " (Staff Co n.ut e n t s , 'a t S.)

-The only positive statement the Staff makes is.that "the HPI documents in question are relevant to matters such as the adequacy of operator training and operator actions to cope with accidents." (Id., emphasis added.) We are left to ponder whether the Staff believes that the' natters. discussed during litigation of UCS Contention No.-10 are among the matters to which the HPI documents are relevant.

The Staff is similarly vague concerning its assessment of the significance of the HPI documents. The Staff simply asserts that the HPI documents do not raise.a significant safety issue which would have led to a different result. No bases for its conclusion are-given and-

-perhaps none could. be given in ' view of the Staff's professed bewilderment concerning the purpose for which the HPI documents are being considered- by the Board. The Staff, while choosing "not [to]

. speculate further on the significance of the HPI documents in the non-cheating aspect of this proceeding," nevertheless takes the position "that the HPI documents do not warrant reopening the record."

(Id., at 5, 6.) In its filing on -December 30, 1981, the Staff may have provided specific comments that could and should have- been provided in its December 24, 1981, filing. This tactic, if used, would deprive UCS of its right to respond to the Staff's arguments. Therefore, after reading the Starf's December 30, 1981, filing, UCS=may find it necessary to seek appropriate ~ relief from the Board.

Response to Licensee Comments The Licensee offers several arguments for the conclusion that the examination results do not, in Licens'ee's view, " reflect adversely on Licensee's training program or indicate that the operator candidates

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would f ail- correctly to observe Licensee's emergency procedures."

(Licensee's Comments, at 8.)' UCS disagrees. . We address below each of the Licensee's comments on the HPI answers provided by the examinees-who took the NRC written examination in October 1981.

2/

1. Licensee first notes that Section 6.B.'3.11.a of EP-1202-6B-appears in the " Follow-Up Action" section of the procedure-rather than the "Immediate Action"'section. (We note that there isfalso a: third "Long Term".section in the procedure.) The Licensee then attempts to argue that the examinees' failure to specify completely and accurately the conditions .that must be achieved ' prior to throttling or terminating HPI can be excused because the distinction between immediate and follow-up actions dictates the level of detail .which operators are required to commit to memory. This argument fails for at least three reasons.

First, the conditions under which it is permissible to throttle or terminate HPI appear 'in the "Immediate Action" section of some emergency procedures.; For-example, Section 6.B.2.B.7 of EP-1202-6B is in the " Immediate Action" section and,- thus, the conditions' for terminating. HPI in Attachment 2 to EP-1202-6B should -have been 2/ - In this. filing, all references to emergency procedures. refer to the version of the emergency procedures provided by the Licensee -in its. filings on December 17 and December 24, 1981: EP-1202-2, Revision

.7, 06/29/81; EP-1202-4, Revision 20, 03/13/81; EP-1202-5, Revision 13, 08/11/81; EP-1202-6B, Revision 7. 03/19/81; and EP-1202-6C, Revision 7, 03/31/81.

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committed to memory,'according to the Licensee. In addition,Section II.2.C.5 of EP-1202-5, although labelled as a " Follow-Up- Action", is included -in the "Immediate Actions" section of EP-1202-5. Thus, according to the Licensee's argument, the' examinees should have committed to memory the HPI throttling criteria _ in the "Immediate Actions" section of EP-1202-5, which, the Licensee observes, "are similar to one .o f the criteria listed in [the " Follow-Up Action"]

Section 6.B.3 11.a of EP-1202-6B." (Id., at 4, 5.)

Second, the Licensee's distinction between immediate_ and follow-up actions is not valid because of the arbitrary and inconsistent placement of similar statements in either the immediate or follow-up sections of the emergency procedures. For example, both EP-1202-6B (Section 6.B.2.B.2.a) and EP-1202-5 (Section II.2.C.5) specify that if HPI is initiated automatically, the operator should verify HPI injection. However, the step.is an "Immediate Action" in EP-1202-6B, but, inexplicably, the same step is a " Follow-Up Action" in EP-1202-5. Furthermore, this "Immediate Action" step in EP-1202-6B

.is very detailed, whereas no details are in given_in the equivalent

" Follow-Up Action" step in EP-1202-5. In any event, UCS believes that' the criteria for throttling or terminating HPI should be placed in the "Immediate Action" section of the emergency procedures because it has not been shown (and, in UCS' view, cannot be shown) that for all accidents (LOCAs,. non-LOCA overcooling accidents, station blackout, reactor trips, etc.) the conditions under which it is. permissible (or required) to throttle or terminate HPI will not occur shortly (e.g.,

sooner than 10 minutes) after the accident begins. During the THI-2 accident, the operators first throttled HPI at 3 minutes, 13 seconds

and tripped one of the HPI pumps at 4 minutes, 38 seconds.

(NUREG-0600,.at pages IA-14 IA-15.) Thus, it is appropriate to have the criteria in the "Immediate Action" section of the en.e r ge n c y procedures and-require the operators to commit ~the details to memory to avoid premature termination or throttling of HPI.

Third, even if the preceding comments are ignored, arguendo, the criteria for throttling or terminating HPI are a special case.

Premature termination of HPI was a major factor in the TMI-2 accident.

The accident has been the subject of intensive investigation by the Licensee and others for the last three years. Operator training conducted since the accident has emphasized the criteria for throttling or terminating HPI. Those criteria were the subject of a question on the April 1981 examination and again on the October 1981 oxamination, presumably with additional operator training on the subject between April and October. At this point, the criteria for-throttling or terminating HPI should be as rote as a nursery rhyme or the Pledge of Allegiance. Licensee's argument that the examinees can be excused for still not knowing the criteria-because they_are in the follow-up section of.one emergency procedure must be rejected.

2. Licensee argues that the examinees' inability to recall correctly all of the elements of the 50 F subcooling and LPI. flow criteria does not necessarily indicate inadequate training or that incorrect actions will be taken during an accident. (Id., at 5, 6.)

UCS disagrees. The saturation meter was added to TMI-1 and the-readout of the incore thermocouples was modified precisely for the purpose of avoiding incorrect operator action. If the operators do not ' know how to determine whether the 50 F subcooling criterion is met, their training has been inadequate. Similarly, there is a

significant difference between specifying >1000 gpm LPI flow and

.specifying >1000 gpm LPI flow in each of the four LPI lines and-that the flow has been stable for at least 20 minutes. UCS believes ~that

.the Licensee's attempt to portray the difference between-the-level of detail in -the ' examinees' answers and in the actual provisions-of the emergency procedures as insignificant is without merit.

3. Licensee argues that the examinees should not have been

. penalized for f ailing to indicate that it is only necessary to meet feither the 50 F subcooling o r_ LPI flow criteria. (Id., at 6.)

Licensee points the finger at the inclusion of the word "all" in-the question as the culprit for the examinees' failure to list conditions in the disjunctive. Licensee's argument fails on its-face in the case of all examinees who took the "B" version of the examination because the word "all" was not included in question E6, which read as follows:

" List the conditions to be satisfied prior to terminating or throttling HPI." (Emphasis in original.) In any event, UCS takes the position that it is significant whether the operators believe that both or either criterion must be satisfied before throttling or terminating HPI. The fact that only one of the 32 examinees gave the correct answer is, in UCS' view, more indicative of inadequate operator training than of a misleading wording of the question.

4. Finally, Licensee argues that the examinees should not have been penalized for equating "to keep from going solid" or "to prevent filling- the pressurizer" with the actual wording of the emergency procedure "to prevent pressurizer level from going off scale high."

(Id., at 6,7.) UCS disagrees because following procedure given in the examinees' answer could lead to different operator action than following the emergency procedure itself. For example, if pressurizer

level is rising following HPI initiation during a LOCA, an operstor might decide to throttle HPI "to prevent filling the pressurizer,"

even though such action-would not be necessary "to prevent pressurizer level going off scale high." In contrast, an operator following the-emergency-procedure would simply observe the rising pressurizer level.

As RCS pressure increases, the flow out of the break will-increase-and the HPI injection flow will decrease. Thus, for some break sizes, the flow into and out of the RCS will balance, the pressurizer level will stop- rising, and the operator will not need to throttle 'HPI "to prevent pressurizer level from going off scale high."

Conclusion For all the above-mentioned reasons, tne Board should grant-UCS' December 24, 1981 request to reopen the record to receive the HPI documents, as described in that December 24, 1981 pleading, into evidence.

Dated: January 4, 1982 Respectfully Submitted,

[

lA Ellyn V. Weiss i.ee L. Bishop

[

Harmon and Weiss 1725 I Street, N.W.

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

UNITED-STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0 In the Matter of )

.)

METROPOLITAN' EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit-No. 1) )

CERTIFICATE OF SERVICE

~

I- hereby certify that--copies of "UCS RESPONSE TO LICENSEELAND

' STAFF ON HPI QUESTIONS _ AND; ANSWERS" have been served on the following persons ' _by deposit in the ' United States mail,- first class postage prep lid this 4th. day of' January -1982.

• Nunzio Palladino, Chairman ##.Dr. Walter H.LJordan U. S. Nuclear Regulatory Atomic Safety and Licensing Connission' Board Panel

. Washington, D.C. 20555 881 West Outer Drive Oak Ridge,. Tennessee 37830-

• Victor;Gilinsky, Commissioner U. S. Nuclear Regulatory ** Dr. Linda W. Little-Commission Atomic Safety.and Licensing Washington, D.C. 20555 Board Panel 5000 Hermitage Drive

' ' Peter Bradford, Commissioner Raleigh, North' Carolina 27612 {

U. S._ Nuclear Regulatory Commission ** Professor Gary L. Milhollin Washington D.C. 20555 1815 Jefferson Street Madison, Wisconsin 53711-

• John Ahearne, Commissioner U. S. Nuclear Regulatory

• Judge Gary J. Edles, Chairman Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U. S.- ~ Nuclear Regulatory

• Thomas Roberts, Commissioner Commission U. S.. Nuclear Regulatory. Washington, D.C. 20555

' Commission

• Judge John H. Buck Washington, D.C. 20555 Atomic Safety and Licensing 8' Ivan W. Smith, Chairman Appeal Board Panel Atomic Safety and Licensing U. S. Nuclear Regulatory

. Board P,a n e l Commission U. S. Nuclear Regulatory Washington D.C. 20555 Commission Washington, D.C. 20555

• Judge Christine N. Kohl Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission-Washington, D.C. 20555

1 < . _ . _ _ . _

• Judge'.Reginald L. Gotchy Mr. Marvin I.-Lewis EAtomic Safety.and Licensing 6504 Bradford Terrace >

. Appeal Board Panel -Philadelphia PA 19149

. U. S.fNuclear-Regulatory-Commission Ms. Gail B. Phelps i Washington D.C. 20555 245 West Philadelphia Street-York, Pennsylvania 17404

~

Mrs. Marjorie Aamodt ~

R.D. #5 Mr. Robert Q.-Pollaro-Coatsville, Pennsylvania 19320 609 Montpelier Street _ . _

4 Baltimore, Maryland 21218

Robert Adler, Esq.

Assistant Attorney General

• Hr. Steven C. Sholly-505 Executive House Union of Concerned' Scientists' P.O. Box 2357 1725 Eye St., N.W., _ Suite 601; r Harrisburg, Pennsylvania 17120' Washington, D . C '. 20006-Louise-Bradford Counsel for_NRC Staff i Three' Mile ~ Island Alert Of fice of Executive : Legal 1 325 Perfer Street LDirector Harrisburg, Pennsylvania 17102 U. S. Nuclear Regulatory Commission WalteroW. Cohen, Esq. Washington,- D.C. 20555 Office'of Consumer' Advocate-1425 Strawberry-Square

• George F. Trowbridge,;Esq.

Harrisburg, Pennsylvania-17127 .Shaw, Pittman, Potts &

Trowbridge Jordan D. Cunningham, Esq.. 1800.M Street, N.W.

Fox, Farr &.Cunningham Washington, D.C. 20036-2320 North Second Street Harrisburg, Pennsylvania 17110 ~' Docketing and Service'Section Office =of the Secretary Thomas J. Germaine, Esq. [F. S.-Nuclear-Regulatory Deputy Attorney General Commission ,

Division of Law - Room 316 Washington, D.C. 20555

, 1100-Raymond Boulevard Newark, New Jersey 07102 Dr. Judith H. Johnsrud Dr. Chauncey Kepford  % f _,

j/(--

l-Environmental Coalition on Nuclear Power ,

433 Orlando Avenue

• Hand' delivered.

State College, PA 16801

t. ** Hand delivered to East-West

• William S. Jordan, III, Esq. Towers, Bethesda, MD. Extra-Harmon &-Weiss copy for Dr. Jordan sent ,

1725 Eye St., N.W., Suite 506 express to Pompano Beach, Washington,-D.C. 20006 Florida.

John A. Levin, Esq.

Assistant Counsel

.- Pennsylvania;Public Utility 1 Commission

P.O. Box 3265-

! Harrisburg,. Pennsylvania'17120

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