ML20039G749
| ML20039G749 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/13/1982 |
| From: | Bishop L, Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | |
| References | |
| NUDOCS 8201190087 | |
| Download: ML20039G749 (18) | |
Text
{{#Wiki_filter:. <W.. . lmi.; ...f m %4 J UNITED STATES OF AMERICA ,l 1 i NUCLEAR REGULATORY COMMISSION I BEFORE THE COMMISSION N ) l In the Matter of ) ) 8 l !%. s j METROPOLITAN EDISON COMPANY ) Docket No r50-289 - X './ - ) (R TART) ,/ (Three Mile Island Nuclear ) Station, Unit No. 1) ) '7 ~q~ ) --{ ,j f. 'i 1. C IN 2 - 1 v<** 1 \\.' w' UNION OF C0hCERNED SCIENTISTS' COMMENT ,e9 RELATIONSHIP BETWEEN REOPENED PROCEEDING gQ7 ON CHEATING AND IMMEDIATE EFFECTIVENESS Ai it9 i On December 14, 1981, the Atomic. Safety and Licensing Board designated by the Commission to preside over this proceeding issued its Partial Initial Decision (PID) on plant design, separation, and emergency planning issues. In a prior Order dated November 30, 1981, the Commission had established a schedule for the submission of comments on whether that decision should be made immediately effective. Subsequent to the issuance of the PID, the Commission issued further Orders (dated December 23, 1981, and January 11, 1982) modifying its earlier schedule and providing that comments on the advisability of deferring any decision on the immediate effectiveness of that decision pending the Board's decision on operator cheating issues were due in i the Comission's hands by January 13, 1982. Pursuant. to the schedule established by the Commission's Orders of December 23, 1981, and January 11, g 1982, the Union of Concerned Scientists submits the following comments for the t s Commission's consideration. SiI F. A l5E'iE88R'd88bf8, PDR
'e i I. The Commission Itself has Recognized in its Prior Orders that Operator Training is a Central Issue in this Proceeding, and that TMI-1 Should not be Restarted Prior to its Complete Review The Licensing Board, in the PID (Paragraph 2023), determined that the pendency of the reopenci proceeding on the operator cheating incidents should not be a bar to the operation of THI-1 at up to 5% of design power, provided that the license conditions recommended in PID Paragraph 583 are enforced. UCS believes, bot.h as a matter of law and as a matter of public policy, that operation of TMI-1 should not be permitted until all of the concerns set forth i in the suspension orders (i.e., the Commission's Orders of July 2, 1979, and i August 9, 1979) have been satisfactorily resolved. Further, as a matter of l practicality, TMI-1 will in all likelihood not be prepared for restart until some time after the projected issuance of the Board's decision on the reopened proceeding due to continued work by the Licensee on post-THI-2 modifications and due to repairs necessitated by the recently discovered steam generator j tube leaks at TMI-1. The Commission should be aware that numerous prior Licensee prognostications of its preparedness to restart have subsequently { proven incorrect, and UCS can discern no basis for placing any more reliance on the most recent projection. Moreover, the recent decision by the Court of Appeals for the D.C. Circuit in PANE v. NRC, No. 81-1131 (D.C. Cir., January 7, 1982), which requires that the Commission complete an environmental assessment on " psychological distress" issues prior to restart, makes a rush to a decision here on immediate effectiveness unnecessary. A brief review of the facts initially justifying the Commission's I immediately effective shutdown order illuminates the importance of not reconsidering that order until the cheating decision is rendered. In an Order dated July 2, 1979 (44 F.R. 40461), the Commission found that it lacked the requisite reasonable assurance that THI-1 could be operated without .m_.%.,. -%-,,w.. .,m,,--
- endangering the health and safety of the public.
Accordingly, the Commission directed in an immediately effective order that TMI-1 be maintained in a cold shutdown condition pending further order of the Commission itself. In its Order and Notice of Hearing, dated August 9, 1979, the Commission specified the bases for its concerns and reaffirmed its suspension of the TMI-1 operating license. Among the bases specified in the Order was the conclusion that the Babcock and Wilcox des gned NSSS's " appear to be unusually sensitive to certain off-normal transient conditions originating in the secondary system." The Commission specified five design features of the B&W NSSS that contribute to this sensitivity: (1) the design of the steam generators with a relatively small liquid volume in the secondary side; (2) the lack of direct initiation of a reactor trip upon loss of feedwater; (3) the reliance on the Integrated Control System to automatically regulate feedwater flow; (4) actuation before reactor trip of a PORV on the primary system pressurizer; and, (5) a low steam generator elevation relative to the reactor vessel which provides a smaller driving head for natural circulation. Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), 10 NR'C 141, 142-143 (1979). Further, the Commission found that because of these five design features, the B&W NSSS places more reliance on the. reliability and perfccmance characteristics of the auxiliary feedwater system (a.k.a., emergency feedwatet system), the Integrated Control System, and the Emergency Core Cooling System (ECCS) to recover from " frequent anticipated transients." The Commission concluded that this, in turn, " places a large burden on the plant operators in the event of off-normal system behavior during such anticipated transients." Id., at 143 Thus, the Commission decided at the outset that the nature of the design of the B&W NSSS made the issue of operator training central to the Commission's eventual decision on whether to permit restart of THI-1. e,wmme*- wm e owe m--- e .mmm...
4-Regarding the five design features that contribute to the unusu11 sensitivity of B&W NSSS's to off-normal transients originating in the secondary system, three of the five factors remain partially or wholly unresolved. Regarding factors 1 and 5, the design of the steam generators and the position of the steam generators relative tc-the reactor vessel have not been altered for TMI-1. Factor 3 remains unresolved with respect to reliance on the Integrated Control System (ICS) to automatically regulate emergency (as well as main) feedwater flow. The partial " resolution" is to rely on the operator to control emergency feedwater flow if the non-safety grade ICS fails and during a SBLOCA even without ICS failure. Reliance on correct operator action is therefore increased. As the Board itself noted, "what will not be completed by restart is safety-grade automatic control of the EFW flow to the steam generator and environmental qualification of some components for non-LOCA events", improvements the Board characterized as " highly desirable". PID, at Paragraph 1036. Thus, it is clear that some level of concern remains about the sensitivity of the B&W NSSS to such transients and, therefore, the consequent importance of operator training. In addition to the design features noted above (features which are c6mlon to all B&W NSSS's), the Commission noted that the NRC Staff had identified several hu: Pan errors committed during the TMI-2 accident that " contributed to its severity." 10 NRC 141, 143 (1979) Further, the Commission concluded that the " unique circumstances at TMI" required.that d additional safety concerns be resolved, including, inter alia, concerns about the " management capabilities and technical resources of Metropolitan Edison.," Id. As demonstrated above, the Commission itself has reccgnized repeatedly that the resolution of questions about the adequacy of station operating ~ procedures and the adequacy of operator training is fundamental to any
.w ~5-consideration of restarting TMI-1. The bases for these concerns were not identified for the first time by parties to the proceeding, but rather by the Commission itself. As such, operator training is a " mandatory" issue which must be satisfactorily resolved prior to restart. In the Order and Notice of Hearing, the Commission provided that the Licensee shall maintain TMI-1 in a cold shutdown "until further order of the Commission which will be issued following satisfactory completion of the required short-term actions" set forth in the order. 10 NRC 141, 146 (1979). The Commission, in its Order of December 23, 1981, reiterated its intention that any decision lifting the immediate effectiveness of the shutdown orders be focused on "the concerns which prompted the original immediate suspension order of August 1979." Id. l at 2. Thus, in order for the Commission to lift the suspension of the THI-1 r operating license, the Commission must find that all of the bases which prompted the Commission to make its suspension orders immediately effective have been resolved satisfactorily. The Commission could not have intended that the suspension could be lifted, and the public health and safety assured, if only a portion of these concerns have been resolved. II. Resolution of the Cheating Issues is Necessary to Satisfy the Conditions Set Out in Paragraph 583 of the August 27, 1981, PID That operator training is so fundamental to the TMI-2 accident, and therefore to any consideration of restarting TMI-1, is amply demonstrated by d the Licensing Board's December 14, 1981, Partial Initial Decision. For { example, at Paragraph 2017, the Board stated: e O r
~ i ) ] l "[W]e have made many determinations favoring restart j dependent upon improvements in the TMI-1 machinery, i However it can be readily observed that our determination:i j also depend very heavily upon correct operator procedures j essential to safety. Operators whose competence has been ensured by appropriate training which has been verified by NRC and company-administered examinations f are an indispensable element of nuclear safety despite the many improvements in plant design." (emphasis added) l i j. Both Dr. Little and Chairman Smith of the Licensing Board concluded that i i there were issues 1. n the reopened proceeding on the operator cheating h l incidents that went beyond the license conditions set forth in Paragraph 583 I of the Partial Initial Decision. Moreover, even Dr. Jordan, who believes that TMI-1 can be operated safety kefore the cheating decision is rendered, stated squarely that "the real issue (for restart] is whether those license 1 f. conditions (in Paragraph 583] can be met." Id. at Paragraph 2020. i j However, as we demonstrate below, the resolution of the cheating issues is critical to a finling of whether those Paragraph 583 conditions can be met. Several of the proposed license conditions presume valid operator training and j examination procedures. The training which TMI-1 operators have received has been brought into serious question by the operator cheating incidents and by the failure of over half of the operators to correctly answer a question on 1 their licensing examinations related to the proper conditions which must be i the very heart of j met in order. to terminate high-pressure injection 1 operator actions involved in the TMI-2 accident. Below, each of the conditions set forth in the PID at Paragraph 583 are restated and discussed in relation to the reopened proceeding and the issue of i immediate effectiveness: i I 3 .i. 4 -n ..-,,--n,- ..c..
. 1 l l l 1. CONDITION: Licensee must demonstrate prior to restart that j j all of the NRC examination carididates have passed with a 90% grade the company-administered " Category T" examination. DISCUSSION The appropriateress of the testir.g procedures used by the Licensee are at issue in the reopened proceed ing.~ Further, the very effectiveness of the Licensee's training program is also at issue; thus, even if the test were i properly constructed and administered, if the training program itself is found wanting, the passing of the Category T examinati.on with a 90% grade would mean very little. l 2. CONDITION: All licensed operators shall have received an additional three days of training covering the TMI-2 ] accident subject matter. DISCUSSION Given the broad language of this requirement and the lack o t' qualification given it in the Board's decision, it is very difficult to ascribe muen significance to it. Questions regarding this additional training abound: Who will administer the training? Are the instructors themselves thoroughly familiar wit.h the TMI-2 accident? How will the performance of the operators in this additional training be evaluated? What specifically is the content of the new program? It is indeed instructive to note that despite the extensive retraining 4 i already conducted by the Licensee and its consultants, more than half of the examinees in the recent NRC licensing examinations for TMI-1 failed a question dealing specifically with trie conditions which must be satisfied prior to i f terminating high-pressure injection (ECCS operation). This particular issue i I is so central to the TMI-2 accident that any high failure rate such. as i f experienced in the ;iRC licensing examinations, particularly on this very I question, must of necessity raise serious questions about the efficacy of Licensee's training program. 4 t .~- .----m---..._--e, -m
3 CONDITION: Operators not previously NRC-licensed shall have successfully completed the NRC-administered examination on the B&W simulator. DISCUSSION In UCS's view, there is no special merit in this provision, since according to NUREG-0737 requirements (Item I. A.3.1) simulator examinations are required beginning 10/1/81 for all facilities which are without their own simutators (TMI-1 is such a facility). The lack of significance of chis requirement is further evident from the lack of fidelity between the BG simulator and the TMI-1 control room in terms of human factors considerations. 4 CONDITION: Licensee shall demonstrate that it has available for use at TMI-1 a CRT "part-task simulator" which displays temperature and pressure. DISCUSSION While centendable, a part-task simulator hardly provides a training experience which is comparable to a full-plant simulator. Questions abound here as well: What degree of fidelity exists between the part-task simulator and the actual control room instruments, both in terms of human factors design and actual instrument response? How accurately does the part-task simulator reproduce temperature and pressure conditions that are experienced during transients and accidents? How much training time have the operators logged on the part-task simulator and how is this training evaluated? What have been the results of any such evaluations? Further, if the basic training program is found wanting as a result of the reopened proceeding, how useful is additional training on the part-task simulator? 5. CONDITION: Prior to 4/1/82, Licensee shall prepare for bids and distribete specifications for a TM1-1 exact replica simulator and shsll make " reasonable and diligent" efforts to have the simulator installed by 1985. DISCUSSION This is a worthwhile and laudable goal. However, inasmuch as the simulator is not yet installed and will most likely not be installed until
l 1985 at the earliest, it can have precious little bearing (if any) on the competence of TMI-1 operators at the time of restart. In essence, this condition is irrelevant to the Commission's consideration of immediate I l effectiveness. 1 6. CONDITION: Prior to restart, Licensee shall contract for a i basic principles simulator to be installed in 1982. I Following installation, annual requalification training l shall include at least one week of training on the basic j principles simulator. i DISCUSSION As in 5 above, this condition has little bearing on restart or immediate l l effectiveness unless the simulator is installed prior to restart and the i requisite training is conducted. Even then, until the efficacy of Licensee's j training program and the Licensee's and NRC's testing procedures is verified as a result of the decision on the reopened proceeding, this condition will have no practical value for assuring the competence of the TM1-1 operators. 1 ] 7. CONDITION: Prior to restart, Licensee shall demonstrate ] that members of its senior management who have joined the 3 Licensee's staff since 7/1/79 and who are designated as Emergency Directors or as Emergency S~upport Directors have i received a formal training course addressing' TMI-1 specific plant design features. I 1 DISCUSSION This should, if properly designed and administered, prove to be of j benefit for the Licensee staff members involved. It is clear, however, that f it will not affect the competence of the licensed operators. } 8. DISCUSSION: Licensee shall conduct training of all its i operators in ATOG (Anticipated Transient Operating Guidelines) prior to ATOG implementation. 1 l DISCUSSION 1 ATOG has not yet been implemented. Moreover, the program has encountered serious difficulties in meeting NUBEG-0737 criteria, as reflected in correspondence between the NRC -Staff, B&W, the B&W Owners Group, and the l Licensee on ATCG, the most recent of which (a letter dated December 3,1981, i -.-m._- y --w.yw--, ws g.9 p g v.
4 i } ' from Darrell G. Eisenhut to Warren Hall, B&W Owners' Group) is attached to this filing. In summary, the Staff concludes (as a result of reviewing the i ATOG filing from Arkansas Nuclear One, Unit 1, and observing operators utilize ATOG procedures on the B&W simulator to respond to transients and accidents) 1 that there are seven " serious concerns" with ATOG. One of the concerns is i that the procedures can mislead operators since the initial trends of ] " overcooling" and " overheating" events are similar. This could affect. the Commission's consideration of the pressurized thermal shock issue at TMI-1 (the Commission will recall that TMI-1 is one of eight plants in the U.S. that j has been cited by the Staff as posing a risk of reactor vessel cracking or j rupture as a result of a pressurized thermal shock event). UCS notes that the Commission has recently designated pressurized thermal shock as an Unresolved 4 Safety Issue, thus underlining the significance of this potential problem with ATOG. 9. CONDITION: This condition requires a variety of shift i staffing requirements depending upon plant operating conditions. DISCUSSION i Since the efficacy of the Licensee's training program for all licensed 3 I l personr.el is at issue in the reopened proceeding, the number of licensed personnel on shift at any one time is largely irrelevant if these persons have f not been adequately trained. 10. CONDITION: At restart and thereafter, Licensee will 1 maintain a " management system" to perform the following functions: (a) review operating experience; (b) promptly I supply information pertinent to plant safety including j proposed procedure changes and plant modifications to i operators and other plant personnel; and (c) assure that such information is incorporated into training and requalification programs. DISCUSSION i l While these functions are necessary, they do not compensate for training j which may in the first instance be inadequate. I
O . i Thus, it is clear that the conditions proposed in Paragraph 583 of the PID are inadequate to overcome the concerns about operator training at TMI-1, are irrelevant to the issue, or there is not adequate assurance of compliance i prior to the issuance of the Licensing Board's decision on matters in the reopened proceeding. Further, the Board explicitly relies on the ultimate acceptance of the Licensee's training program for its findings on plant design. However, the efficacy of this training program has been cast into serious doubt as a result of the operator cheating incidents and the test question failures on conditions for throttling or terminating high-pressure injection. The following examples typify this reliance: 1 1. Paragraph 625 of the PID states: "We do not disagree with the UCS claim (proposed finding Paragraph 25) that extensive training and well-conceived procedures are required when the feed-and-bleed cooling mode is relied upon to dissipate heat from the core, but the complete record as it stands today supports the conclusion that these procedures and training can be provided. However, we have reopened the record in this proceeding to inquire into the significance of the test cheating disclosures on the effectiveness of operator training." The Commission should note that the Board concluded only that the requisite procedures and training "can be provided", not that they have been provided. The Commission should also note that the Board phrased its language in terms of the record "as it stands today", meaning, of course, without the decision on tha reopened proceeding, which the Board noted might alter its original findings. 2. Paragraph 601, fn, 73, states: "The dependence upon correct operator responses in conjunction with the new instrumentation (to detect insdequate core cooling] underscores the importance of the reliability of NRC and Licensee-administered operator tests and the importance of the reopened proceeding on cheating on those tests." 3 Paragraph 746, in which the Board (although concluding that UCS' position on its Contention #10 "has merit") finds in favor of the Staff and Lfcensee and states: "Howeve.r we also note the extreme impor tance of adequate procedures and thorough training of the operators." In Paragraph 747, in
. which the Board finds that Sholly Contention #3 (related to the same issue as UCS' contention) has been reso'ved, also states: "However, this finding underscores the safety importance of the reopened proceeding on the issue of cheating on operators tests and the reliability of the operator training." 4 Paragraph 953, fn. 116, regarding the reliance by the NRC Staff and the Licensee on operator action in the small-break LOCA analyses, states: "This is yet another example demonstrating why the Board found it necessary to reopen the record on the implications of cheating on operator examinations." 5. Paragraph 991, in which the Board takes note of the Staff and Licensee positions that no upgrading of non-safety grade systems at TMI-1 is necessary, states: " Upgrading cannot take the place of operator training. Licensee's and Staff's dependence upon operator training, however, emphasizes the importance of the reopened hearing on the ramifications of cheating on operator examinations." 6. Paragraph 1051, in which the Board addresses the reliability of the ' feed-and-bleed cooling mode, states: "We here note again the importance of operator training and testing, and the significance of the reopened proceeding on matters related to cheating on operator examinations." In addition to these explicit references to the importance of the reopened proceeding, there are numerous examples of instances in which the Board implicitly relies upon the adequacy of operator training in reaching its findings on plant design issues. The following examples serve to illustrate: 1. In Paragraph 619, the Board relies upon " equipment, procedures and training" to assure that the core "will never be uncovered" as.it was during the TMI-2 accident. To the extent that the Board relies upon training of the TMI-1 operators to assure that the core does not become uncovered, the Board premises its conclusion on the adequacy of that training. 2. In Paragraph 638, the Board relies on modifications to the plant "in conjunction with improved operator training" to "substantially enhance the capability of the operator to l recognize and respond to conditions of inadequate core cooling." This is particularly significant for TMI-1 since l there is no direct indication'of reactor vessel water level provided to the operators. .~ _ _ _ _ _ _ _ __m
= = :: = ; 2 a ) i 3 In Paragraph 658, the Board points out that Emergency Procedure 1202-6B requires "the operator to distir.guish between the transients (overcooling versus a small-break LOCA] hased on indirect indicators from existing instrumentation." Clearly, such reliance upon operators to use indirect indicators to discern the existence of two quite different types of accidents is premised upon adequate 1 operator training. Furthermore, the importance of this reliance on operator training is heightened by the fact that i overcooling transients have been identified as a means by j which pressurized thermal shock events are initiated. 4 In Paragraph 1115, the Board relies upon " improved training of operators" to reach its conclusions on the adequacy of the Staff's method of classifying accidents as being within or outside the design basis. 1 In summary, given the Board's great reliance on the integrity of the Licensee's operator training program in its decision, the circumstances of this case require that the Commission defer any decision on immediate effectiveness of the Licensing Board's December 14, 1981, Partial Initial, j Decision until after the issuance of the Board's decision en the operator cheating issues. The issue of operator training is so fundamental to this I proceeding and the adequacy of operator training so permeates the Board's PID that the Comission must await the Board's determinatior.s on operator training resulting from the reopened proceeding. j u III. Public Policy Also Suggests Deferring Restart { Until the Issuance of the Board's Decision on the Issues in the Reopened Proceeding i I As a matter o t' public policy, the circumstances of this case dictate that the Commission defer its decision on immediate effectiveness. Operator training is absolutely central to the TMI-2 accident, and thus to " consideration of restarting THI-1. All of the post-TMI-2 accident investigations point to this conclusion. The Essex Corporation, which i - - ~,. _--.-.,e.-
- - =. - .=__.a .__:-_=.-..=- l ' l l conducted an in-depth review of the Ti1I-2 accident and its implications for human factors considerations (including operator training), concluded that the l TMI-2 accident " reflects a training disaster." NUREG/CR-1270, Volume I, page 99; also cited in NUREG/CR-1250, Volume II, Part 2, page 604 (Special Inquiry Group report). Even the Licensee's own internal review of the accident l concluded, " Inadequate operator training was clearly one of the most important factors which contributed to the accident." GPU Accident Review Task Force Final Summary Report, at 12; cited in PID at Paragraph 2015. l The Board concludes, based not on factual record material but rather on the technical judgment of two of its members, that operation at up to 5% power during the pendency of the reopened proceeding "would essentially eliminate the possibility of an accident having serious consequences for the public health and safety." PID, December 14, 1981, at Paragraph 2021. It should be further noted that this conclusion is premised on the basis that operation at 5% power would be "very short-term." Id. UCS agrees that the possibility of an accident at 5% power having serious consequences for the public health and safety is low, but this does not address the issue from a public policy standpoint (indeed, the probability of an accident such as the TMI-2 accident was also considered by the Commission, the Staff, and the NRC's Licensing Boards to be " low").
- Rather, the issue should be approached from the perspective of what action the Commission would take if operators at an operating facility had their training brought into such serious question; we believe that the Commission's proper course of action in such a case would be to suspend operations at that facility until the concerns were resolved.
Thus, TMI-1 should remain shut down until the operator training issue is fully resolved. To do otherwise would diminish the significance of correct operator training in the eyes of other NRC licensees and the public.
_.. _ _ _ ~ _.. _. - _.. _ . 4 The Staff, in its comments (dated September 11, 1981) to the Commission on immediate effectiveness of the Board's management PID, argues in a footnote l on page 9 of that document that the Commission may consider the economic costs of continued shutdown in determining whether to make the Board's PID immediately effective, citing Consumers Power Company (Midland Plant, Units 1 and 2), CLI-73-38, 6 AEC 1082 (1973). If the Commission wishes to consider the "more neutral considerations of impacts on electric power ratepayers anc energy supply", that concern also argues against a premature restart. If permission for restart at up to 5% power is granted, it is a likely result that the Pennsylvania Public Utility Commission and the New Jersey Board of Public Utilities would permit Met..opolitan Edison Compmy, PENELEC, and Jersey 4 Central Power and Light Company to place TMI-1 back into their rate base. Since operation of TMI-1 would be limited to 5% power, however, considerable replacement power would still have ' to be purchased. Thus, if the Commission follows the Licensing Board's recommendation and permits operation at 5% power, the ratepayers of the GPU subsidiaries will be saddled not only with the continued replacement power costs, but also with the rate base costs of TMI-1. This certainly would not benefit consumers. ~ In addition, the Board's conclusions regarding the risk to the public health and safety from accidents at 5% power ignore the other impacts that could result should such accidents nonetheless occur. The Commission must i consider the impact on in-plant safety from such accidents and the eccnomic costs (due to cleanup and costs of replacement power due to lost generating a capacity during the cleanup). Finally, the Commission should not make a decision which is essentially moot. As explainerd at the outset, the As espoused in a memorsndum from the Commission's General Counsel dated October 18, 1979,
SUBJECT:
" Adequate Protection of the Health and Safety of the Public".
i
- 2-.
, = :. e i preparation prior to restart of an environmental assessment (required by the J D.C. Circuit) will take significantly longer than will be required by the Licensing Board to issue its decision on the reopened proceeding, now { projected for February 1982. Conclusion the Commission's long-held concern with For all these reasons operator competence, the need for satisfy the Paragraph 583 conditions, and notions of public policy -- the Commission should defer its - decision on immediate effectiveness of the Board's Partial Initial Decision of December 14, 1981, until the Board's decision on the reopened proceeding is rendered and reviewed, i 4 DATED: January 13, 1982 RESPECTFULLY SUBMITTED, WR tesdzn Ell W R. Weiss $[ Lee L. Bishop [/ Harmon and Weiss 1725 I Street, N.W. Suite 506 Washington, D.C. 20006 Counsel for UCS G ,.e "* W - MN g*S9M vr fem SF Fuu9t FusM'WM F1&T T* F G M F MN T W M 98 8 rt P'*"V *T'F*
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,. - C WAS5tlNG TON, O C. 70555 o Q: f' ? (' C f f December 3, 1981 Mr. Warren Hall, Chai rman Opera tion Support Subcomnittee Babcock and Wilcox Owners' Group Consumers Power Company 1945 West Parnall Road Jackson, flichigan 49201
Dear Mr. Hall:
in response to concenis about the adequacy of Emergency Operating Procedures throughout the nuclear industry following the accident at Three tiile Island, Unit 2, Babcock and Wilcox (B&W) embarked on a program for upgrading the Emergency Operating Procedures for B&W-designed plants. The general concept of the program adopted by S0W 0.;ners' Group is for B&W to write procedure guidelines for each BEW- ?esigned facility, and for each licensee or applicant to write detailed procedures from the plant-speci fic guidelines. In meetings wi th the B&W C*,vners ' Group, the NRC s taff agreed to review the Arkansas Nuclear One Unit 1 (ANO-1) Anticipated Transient Operating Guidelines (ATOG) submittal as a generic program for upgrading emergency operating pro-cedures, but the plant-speci fic guidelines would not be reviewed. ATOG is intended to be syrptom-based, whem symptom sets are combined into event categorias and the operator mitigates an accident by cor-recting the synptoms of the particular category of events. We performed a preliminary review of the ANO-1 ATOG based on the criteria of Item I.C.1 of NUREC-0737, "Clari fication of TMI Action Plan Requiremants". He met with the BaW Owners' Group on Augus t 14, 1981, to discuss the res ults o f our review. Subsequent to the August 14 meeting three members of the NRC staff visited the'8&W simulator as agreed to in the meeting. On September 4,1981, they observed B&W personnel use the ATOG procedural guidelines to respond t'o several transients that included multiple failures and operator errors. Based on our preliminary review of the ATOG program, the discussion at the August 14 meeting, and September 4 visit to the ban facility, we have several serious concerns with the ATOG program: 1. The approach taken adaresses only the core hebt removal function through use of a secondary heat sink or direct cooling. Other sa fety functions, such as maintenance of containmen t integrity, are not addressed to the same depth. This makes the information presented to the operators incomplete and leaves the interconriections between functions undefined. 1 M> b i e
f 4 Mr. 'co i-n !.a i 1 2. A fuli range of multiple failures is not consideied, perticularly with c:6,wct to poaer supplies and s ur port sys tems. Therefore, igartant bad.up rU curces are not ida.ti fied for the opcrators. 3. Although the ATOG procedural guidelines are not pwely %'c.:1-oriented, they do c.ppear to be adequately oriented toward ritigation of syuptoms. hw-ever, ATOG Part II, Fundamer'.als, dues not adequately describe how the five mjor fv.ctions dcfined by BSW are maintained using the ti.ree event catr;0 ries of '.iOG Part I, Procidural Guidelines. 4 The initial trends of overcooling-and overheating-type acciJents can be i very similar, whicn could lead the operator into the frong section of a pro-cedure based on the procedural guidelines. 5. The M00 guidelines appear to be " display dep:. dent" Little info n a tion is preser.ted to facilitate use of the procedure it the prssturc-tenperature CFT Jisplay is not available. 6. Some parts of the AT0G program (e.g., ir. adequate core cooling) were not included in the ANO-1 submittal. All parts of the progran should be adc'ressed in the Oconee submittal, which was selected as the generic program for staff I review. Examples of items that should be addressed are natural events and raintenance of containment integrity. 7. The staff has several concerns that have been transmitted and discussed separately on the adequacy of some of the ban calculational codes being used to support the ATOG program. It is the staff's understanding that the following agreements were reached at the August 14, 1981 meeting to facilitate resolution of these concerns: The NRC staff will review the Oconee ATOG submittal (not ANO-1) as a generic i. program, for technical adequacy. 2. The Oconee ATOG documents will be submitted formally and docketed. 3. Transient Information Documents (TIDs) will be submitted that will provide compcr isons of the AT0G program for each plant to a reference plant. 4 The NRC staff will visit the B&W facility in Lynchburg two times. The pur-pose of the first visit in early September was to observe the ATOG pro, cedural guidelines being used on the B&W simulator and to determine whether or not they are symptom-oriented. The purpose of the second visit, to occur in November, is to discuss the calculational information, computer codes, and other technical information used in developing and validating AT0G. During the second visit, the staff will identi fy any additional information needed to ccmplete its. review of the ATOG program. 5. In the course of our review of the technical content of the AT0G program, the staff will provide 9&W with comments on the acceptability of the ATOG approach to accident mitigation.. This feedback is to assist S&W in develop-ment of the plant-specific guidelines which have not yet beer. completed. a ~ *** 4-- ee* --mge,g w m--,,,ei.%
Mr. War-en Hall The staff recognizes that significant effort has been expended by B&W and the B&W Owners ' Group in developing the ATOG program. The staf f feels that the approach taken in the ATOG program will prove to be an acceptable method for upgrading emergency operating procedures and that work should continue in refining the approach. However, we feel that a signi ficant ar aunt of work remains to be done to resolve the staf f con-cerns and prov:de the best possible inf ormation to the operators in the control room in a timely fashion. Related to this matter are the principal agreemer ts reached in a meeting with the NRC staff and the B&W Owners' Group at a meeting held on October 23, 1981 and subsequently acknowledged by B&W licensees. The B&W Owners prop 3 sed a program to resolve staff concerns by June 1,1982 regarding the need for validated calculational methods used to predict system be-havior during recovery from small break loss-of-coolant accidents. The program would consist of: (1) a review of the codes, models, assumptions and the available experimental data related to the dynamics of interest, ~ (2) defining needed additicnal experimental data which addresses specific technical gaps and (3) identifying where and how additional experimental data may be obtained. It is our desire to pursu-resolution of our ATOG concerns as rapidly as 'essible so the BTel C.-ci,ers can upgradt t!,eir emergency operating pro-c <2 d u res. To accciglish this ocal, we would like to schedule another meeting with you in carly Decer.6er to discuss the ATOG program modifications and a schedule for implementation of the program at B&W plants. By copy of this letter, we are providing the B&W plant licensees and appli-c ants the results of our preliminary evaluation of the ATOG program. S i n ce re ly, - s4 n d_a 19t1h, lA$1 M )p \\ 'Difrell G. ;Eiser$ hut, Director Division of Licensing Of"ce of Nuclear Reactor Regulation cc: DNapior (B&W) S&W Licensees & ccs-see next page ESW Applicants B&W Ovners ' Group, Operation Supnort Subcummi ttee Mer.ibers 4 - -=:= ~~~ ~ ~ ~
.= i. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of ) ) METROPOLITAN EDISON COMPANY ) Docket No. 50-289 ) (Eestart) (Three Mile Island Nuclear ) Station. Unit No. 1) ) CERTIFICATE OF SERVICE I hereby certify that copies of "UCS COMMENTS ON STAFF BRIEFING OF COMMISSION AND RENEWAL OF MOTION FOR AFFIDAVITS CONCERNING EX PARTE CONTACTS" and " UNION OF CONCERNED SCIENTISTS' COMMENTS ON RELATIONSHIP BETWEEN REOPENED PROCEEDING ON CHEATING AND IMMEDIATE EFFECTIVENESS" have been served on the following persont by deposit in the United States mail, first class postage prepaid this 13th day of January 1982.
- Nunzio Palladino, Chairman Dr. Walter H.
Jordan U. S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 881 West Outer Drive J 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 Br ad ford, Commissioner Raleigh, North Carolina 27612 U.
S. Nuclear Regulatory Commission Professor Gary L. Milhollin Washington D.C. 20535 1815 Jefferson Street Madison, Wisconsin 53711 ' John Ahearne, Commissioner
- Judge Gary J.
Edles, Chairman U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Washingtor), D.C. 20555 Appeal Board U. S. Nuclear Regulatory
- Thomas Roberts, Commissioner Commission U.
S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555
- Judge John H.
Buck Atomic Safety and Licensing
- Ivan W.
Smith, Chairman Appeal Board Panel Atomic Safety and Licensing U. S, Nuclear Regulatory Board Panel Commission U. S. Nuclear Regulatory Washington D.C. 20555 Commissisa Washington, D.C. 20555
- Judge Christine N.
Kohl Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory j Commission Washington, D.C. 20555
Judge Reginald L. Gotchy Mr. Marvin I. Lewis Atomic Safety and Licensing 6504 Bradford Terrace 1 Appeal Board Panel Philadelphia, PA 19149 U. S. Nuclear Regulatory Commission Ms. Gail B. P h e l'p s ] Washington D.C. 20555' 245 West Philadelphia Street York, Pennsylvania 17404. l Mrs. Marjorie Aamodt R.D.
- 5 Mr. Robert Q.
Pollard l Coatsville, Pennsylvania 19320 609 Montpelier Street Baltimore, Maryland 21218 l Robert Adler, Esq. j Assistant Attorney General Mr. Steven C. Sholly 505 Executive House Union of Concerned Scientists P.O. Box 2357 1725 Eye St., N.W., Suite 601 Harrisburg, Pennsylvania 17120 Washington, D.C. 20006 Louise Bradford
- Counsel for NRC Staff 325 Pe fer Sre D
ec o Harrisburg, Pennsylvania 17102 U. S. Nuclear Regulatory Commission Walter W. Cohen, Esq. Washington, D.C. 20555 Office of Consumer Advocate i 1425 Strawberry Square George F. Trowbridge, Esq. Harrisburg, Pennsylvania 17127 Shaw, Pittman, Potts & j Trowbridge Jordan D. Cunningham, Esq. 1800 M Street, N.W. ] Fox, Farr & Cunningham Washington, D.C. 20036 3 2320 North Second Street Harrisburg, Pennsylvania 17110 Docketing and Service Section Office of the Secretary Thomas J. Germaine, Esq. U. S. Nuclear Regulatory Deputy Attorney General Commission j Division of Law - Room 316 Washington, D.C. 20555 i 1100 Raymond Boulevard j Newark, New Jersey 07102 Dr. Judith H. Johnsrud l Dr. Chauncey Kepford / /. /,U/ j Environmental Coalition on Nuclear Power 433 Orlando Avenue- ' Hand delivered to 1717 H St., State College, PA 16801 N.W., Washington, D.C.
- William S.
Jordan, III, Esq.
- Hand delivered to indicated i
Harmon & Weiss address. i 1725 Eye St., N.W., Suite 506 Washington, D.C. 20006 i j John A. Levin. Esq. Assistant Counsel i l Pennsylvania Public Utility j Commission i P.O. Box 3265 Harrisbur6,. Pennsylvania 17120 f - -. =
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