ML20041E767
| ML20041E767 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/25/1982 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Specter A SENATE |
| References | |
| NUDOCS 8203110354 | |
| Download: ML20041E767 (1) | |
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The Honorable Arlen Specter MARL'Oi9826 10 United States Senate samm%
Washington D.C.
20510
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Dear Senator Specter:
p Because of the Cottnission's adjudicatory role in the Three HiN Island Unit i restart proceeding, it vrould be inappropriate for Chairman Palladino to coment directly on the ratters raised by your letter of February 8,1932.
Therefore, I am responding to your letter enclosing allegations of the Union of Concerned Scientists regarding the t;uclear Regulatory Commission (fiRC) correspondence v.ith Pennsylvania Governor Richard Thornburgh.
We received a similar request for cor. cents on the ;;RC staff's January 5, 2
19S2, letter to Governor Thornburgh frca Congressman l' orris Udall, Chairman of the House Comittee on Interior and Insular Affairs.
On February 10, Mr. William Dircks, itRC's Executive Director for Operations, responded to the issues raised by Congressman Udall.
I believe that lir. Dircks' response is also respcnsive to your request and an encicsing a copy for your information.
Sincerely, Carlton r.armerer, Director Office of Congressional Affairs
Enclosure:
As stated
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- .A FEB 1 O_ y SECRETARIATREC The Honorable fbrris K. Udall, Chairma Comittee on Interior and Insular Affairs United States House of Representatives Washington, D.C.
20515
Dear Mr.-Chairman:
I am providing an NRC staff response to the questions you posed in your January 20, 1982 letter to Chairman Palladino because it would.be inappropriate for the Comission to coment on mtters pending before it in the Three fille Island Unit One (TMI-1) restart proceeding.
I agree with you that the letter and mmrandum you referred to in your letter give a confusing picture of the staff review of the water leyc1 instru-mentation proposed by the licensee for TMI-1.
I regret this confusion.
It was inadvertent, and I have written to Governor Thornburgh to clarify the matter (copy enclosed).
The confusion resulted from the fact that the memorandum to the Comission, although signed on December 29, was actually prepared by the staff after the letter to Governor Thornburgh that was' signed on January 5.
The staff had atttepted to keep the two documents coordinated by noting in the letter to Governor Tnornburgh that " sore design codifications are expected.to be required before the system is installed." Our meaning apparently was not conveyed, and we regret the misunderstanding that resulted.
To be clear on where we stand today, the engineering details of the' design proposed by Metropolitan Edison for the level measurement syste:n at TMI-1 are unacceptable to the staff in that the proposed design r:eets some but not all of our requirements. We have enclosed a copy of our January 6,1982 letter to tM licensee transmitting this conclusion and its technical basis. That letter also identifies the design modifications that would satisfy the staff's requirements.
The second question you raised concerned the basis for the staff's conclusion that reasor,able progress is being made by !ktropolitan Edison towards meeting the requirerent to install a vessel level measurement system in TMI-1.
Your specific words concerned "the reasonableness of there being a lapse of tore than four years" between our establishing the requirement and the installation of such equipment.
The staff recently sent two papers to the Conmission concerning PWR vessel level measure eat systems. They are numbered SECY 81-582 and 582A and copies are enclosed.
(The second one is the December 29 memorandum to which you referred.) These papers point out the remining difficulties in designing, testing, and installing level measurement systcc.s.
In addition, ACRS members have voiced strong reservations about hasty implementation of these systems.
L They are concerned that ambiguous masurements could detract from overall safety.
A recent ACRS letter to the Comission reflecting this concern is
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v The Honorable Morris K. Udall.
On January 8, the Corar,ission met with the NRC staff, the suppliers of PWR vessel level measurement systems, and ACRS representatives. The meeting disclosed that there remain significant uncertainties about the systens that have been proposed. The Commission has asked for the staff's plan to resolve the uncertainties. A copy of our response is enclosed.
We believe that existing instrumentation and procedures in PWRs are adequate to guide operators in the detection of and recovery from possible situations of inadequate core cooling.
However, to guard against unanticipated events and to provide less amb.iguous information to reactor operators, additional information is desirable. As we have proceeded to explore new instrumentation, we have found that if it is not chosen and implemented carefully, it would be possible to create new safety problems.
Until last fall, Metropolitan Edison had not proposed a specific design for a level measuring system for TMI-1.
Their effort to do so in November was a good-faith effort to develop and refine a vessel level measurement system.
Our review and their design are not complete at this time. 'However, the company has committed to installation of a system at its next refueling outage.
Tnat schedular commitment is consistent with what we are requiring c f other operating PWRs.
It is also consistent with the cautious and delibeiate approach we feel is warranted for this particular instrument system. Expecting further progress in Metropolitan Edison's response to our letter of Janrary 6, we find their overall progress on this matter to continue to be acceptaLle.
Sincerely,
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.J Wi liam. Dircks -
v Executive Director for Operations
Enclosures:
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February 10, 1982 letter from Dircks to Thornburgh 2.
January 6 letter to licensee 3.
SECY 81-582 and 582A 4.
ACRS letter to Commission 5.
Staff response to Jan. 8 meeting cc:
Rep. Manuel Lujan
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d' FEB 101982 Docket f;o. 50-289 The Honorable Dick Thornburgh Governor of Pennsylvania Harrisburg, Pennsylvania 17120
Dear Governor Thornburgh:
I am providing you with an update on one of the items discussed in my letter of January 5,1982. That item was " Inadequate Core Cooling."
In the paragraph with this heading, we discussed the status of our review of Metropolitan Edison's proposed additional instrumentation to detect loss of water from the primary system of Three Mile Island Unit One. We noted that the instrumentaticn was under staff review and that some design modifications were expected to be required.
You will recall that the licensee's progress on the installation of a level measurement system was an item of concern that Congressman Udall had earlier identified to you.
On January 20, 1982, Congressman Udall called to our attention an administrative error involving our January 5,1982 letter to you and a December 29, 1981 memorandum from me to the Commission that caused scme confusion as to what the fiRC staff position on the level measurement system actually was.
I have enclosed his letter, my response, and my December 29 memorandum for your information.
I trust these will clear up any confusion that may have been created.
Sincerely,
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WilTthm J. Dircks Executive Director for Operations
Enclosures:
1.
1/20/82 letter, Udall to Palladino 2.
Dircks response to 1/20/82 Udall ltr 3.
12/29/81 memorandum, Dircks to Commission G} 7 2MJ iI
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1MIC February 8, 1952 Dr. Nunzio J. Palladino Chairman of the Nuclear Regulatory Co=ission 1717 H streer, N.W.
Washington, D.C.
20555
Dear Chairman Palladino:
Enclosed is a copy of a letter dated January 26, 1982, from the Union of Concerned Scientists to Governor Richard Thornburgh of Pennsylvania.
Perhaps you have responded to this letter via one of the other recipients of a copy of the letter.
In any event, I would welcome your coments.
Thank you for your assistance.
cincerely,
/1 Arlen :
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AS/ww Enclosure ec:
Mr. Henry W.
Kendall Mr. Rcherr D.
Pollard 2/12...To OCA for Direct Reply... Suspense: Mar..Cpys to: R.;, EDO, Docket 82-137 e,,.,..
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January 26, 1932 Honorable Richard Tncenburgh Governcr Cc=nonwealth of Pennsylvania Harrisburg, Pennsylvania 17120
Dear Governor Tncenburgh:
We are writing in response to the NRC staff's letter tc you af January' 5,1982, regarding the restart of Three Mile Isla.:d Unit 1.
The most charitable interpretation of that letter is that it is grossly misleading.
A more frank appraisal is that it is deliberately deceptive.
As you recall, your letter of November 2C, 1981 to the Cnairman cf the Nuclear Eegulatory Commission for warded for review letters you had received from U.S.
Eep. Morris K.
Udall, dsted July 23, 1981, and from UCS, dated October 19, 1981.
You urged Chairman Palladino "to conduct a careful and objective review" of the questicns surrounding the safety of restarting TMI-1 that were raised by Rep. Udall and UCS.
You suggested that if there were "any Unit i safety questions that have yet to be satisf actorily addressed.
now is the time for the NRC to address them."
Finally, you requested "a written respor.se from [ Chairman Palladinc) er [his) staff reflecting NRC's view of the various points raised by UCS and Rep. Udall."
The NRC staff characterized its reply to your expression of a "paramcunt concern for the health and safety of the people who live within the shadow of ihree Mile Island" as an " interim respense."
However, it is clear that the NEC staff did not address the questions you posed.
Inere is no evidence that the staff carefully and objectively reviewed the substantive issues raised by UCS and Rep. Udall.
Tne staff avoids saying whether any Unit 1 safety questions have yet to be satisfactorily addressed cr. if so, whether the NRC has any plans to address them now.
Instead, the staff's letter purports to
" summarize Staff positions en the several technical and prceedural issues raised."
If the NRC had simply failed to respond to your questions, we would not need to bring that self-evident fact to your attention.
Our reason for writing now is that the NRC staff has not only declined to accress the safety concerns that you crticulated, but in additicn has presented you with informaticn. that dses r.c t reflect. the whcle truth.
In our view, the staff has e ttempted tc create an impression more favorable to restart of TMI-1 than it knows is warranted.
l.!s :achusstic C///ce:
13S4 MEssa:huseus Avenue Camondge, M A 02238 a
(617) SG55
P,ep. Udall's Letter Consider, for example, the ~ staff's response to the issues raised by Rep. Udall.
Mr.
Udall pointed to the " continuing resistance by G?U. to requirements instituted for purposes of correcting deficiencies revealed by inquiries into the accident." He cited as an example GPU's resistance to the requirement to install water level instrumentation for the reactor vessel.
Rep. Udall concluded with the following observation:
The reluctance of GPU to meet the NRC requirement, to say nothing of its failure to go the extra mile, suggests that the current THI management, as did its predecessor, holds that the plant-systems as they exist are adequate to cope with anticipated events; they appear to believe that ananticipated events simply will not occur.
This is of course the rame line of thinking that led to GPU's present predicament.
Inus, Rep. Udall's letter ran fairly be characterized as expressing concern primarily about GPU's attitude and only secondarily about water level instrumentation.
The staff's response is to acknowledge only the example and not to acdress the fundamental issue of GPU's attitude.
In addition, even this limited response does not accurately represent the staff's views.
In its letter to you, the s.taff said:
GPU has revised its position on this matter and has now committed to installation of a system in the Reactor (Coolant] System (RCS) hot leg piping which will provide an indication of RCS inventory loss.
This system is currently being reviewed by the Staff and some design modifications are expected to be required before the system is installed at the naxt TMI-1 refueling outage.
This statement does not convey the same message as the report the staff gave the NRC Commissioner s - on the. TMI-1 water level instrumentation only a week be for e its letter to you.
In a memorandum for the Commissioners dated December 29, 1981, the staff said:
A single dp (differentia 1 ' pressure) measurement over the top 10 feet of the hot leg (as proposed for THI-1) would detect voiding at the top of the candy cane.
It will probably *. rack hot les level for a sufficient distance to disti'guish between over cooling transients and a loss of coolant inventory indicative of a n. approach to core uncocery.
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w:uld also provide valuable information to support reactor coolant system venting operations and to cont'irm that natural-circulation operation. is not interrupted by voiding in the candy cane.
However, it would not trend voiding with' the pumps running and would not indicate void formation in the reactor vessel head until vessel water level reaches the hot leg no::le.
It would also fail to provide a continuous
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'uncovery, and would not track the ' replenishing of coolant inventory.
- ' As presently proposed, the single dp measurement over the top 10 feet of the hot leg is unacceptable tc the staff. (emphasis added)
The inability of the proposed instrumentation to detect the formation i
a steam bubble. void in the reactor vessel and the inability to measure 3
extent of core uncovery are~ mapr deficiencies.
. In, view of th deficiencies and the staff's. conclusion that -the proposed TM instrumentation desigr. is unacceptable, we believe.that the staff's stat to you that "some design modifications are expected - to be required" 4
misleading.
The staff's phrasing.is akin to saying that a prop automobile design that does not include wheels and an engine is accepta although some design modifications may be required.
In sum, the NRC' staff's response to the matters raised by Rep. Ud consists of ignoring the principal issue of GPU's attitude and failing accurately inform you that the staff rot"id GPU's belatedly proposed des changes to be unacceptable.
UCS's Letter Regarding the staff's handling. of the safety issues raised by U@
it is clear that the staff did not address the substance of those issuess 1)
The NRC's focus on quick, cheap fixes that ignore the more serious problems revealed by the TMI-2 accident; 2)
The restrictions in the scope of the hearings which preventeq t
consideration of important questions about the c
THI-1; safety of restarting 3)
Reducing NRC's standard of safety to the lowest common denominator
, by ignoring safety problems that are'not unique to TMI-1;.
4)
NRC's repeated extension of deadlines.for implementing the.TMI-2
" lessons learned" requirements after pressure from the. nuclear industry; and 3
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5)
The retracti'on or substantial weakening of commitments made by the NRC staff and GPU Nuclear,to make improvements directly related to the causes of the TMI-2 accident.
Like the res;>onse to the matters raised by Rep. Udall, the staff answer to the safety questions raised by UCS consists of ignoring. ti j
' principal issues and providing misleading information on the examples.
L brief discussion of just one subject, environmental qualificat' ion of safe j
equipment, will illustrate the deceptive nature.of the staff's response you.
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Environmental qualification of safety equipment involves demonstr:
that the. equipment which is needed to safely shut down the plant 4 accident can survive the' environment that it will be exposed to durin accident.
In our earlier letter to you, we pointed out that the s;-
testimony had not addressed accidents such as steam line breaks and, eyes small break loss-of-coolant accidents, had been limited to an accides much smaller dimension than the IMI-2 accident.
We also' nt.ted limitations on the scope of the hearings had prsvented UCS from prese evidence that many safety-related components in TMI-1 have-not been qual to survive serio_us accidents.
Finally, we expressed our doubts that th
. staff and GPU Nuclear' would honor their promises -to coFrect the environa qualification deficiencies at TMI-1 by July 1982.
In its response the staff acknowledges the accuracy of one ' of statements, but misleads you on the remainder of the issues we raised, staff states that its testimony was " directed [rather than UCS's -
" limited") to the ability of equipment to function followin.g. a small loss of coolant accident (SBLOCA) not involving core damage.
" Sinc =
TMI-2 accident was a ~ small break loss-of-coolant accident ;that inv substantial core damage, this confirms that the staff analyzed onl) accident of the same type as, but less serious than, the TMI-2 accident.
Next the staff states its position favoring "interin operation" of '
until GPU can " complete the actions required for all operating plants the Commission's Memorandum and Order CLI-80-21 dated May -27, 198 demonstrate that all safety-related electrical equipment will be qualifit withstand accident environments."
CLI-80-21 specifies that s a f e t y-r.c la t ed electrical equipment in all operating plants ' muss environmentally qualified by June 30, 1982. (11 NBC 707, 714, 715)
Howe the staff neglected to ' tell you that since July 1981, it has support <
request to extend, that deadline.
In October and November 1981, the g prepared proposals for Commission consideration to accomplish. that object
.Just two days after the staff's lett'er to you, a majority. of Commissioners voted for a proposed' rule which, if adopted, will extend June 30, 1982 " deadline" to the end of the second refueling after March 1982. (See Inside N.R.C., January 11, 1982, p.
- 1) Thus, the situation is even worse than when we last wrote you.
GPU appa.rently will not be requ to correct the environmental qualification deficiencies at TMI,1 until at the earliest.
Furthermore, the proposed rule does not apply to all sa equipment.
" Additional electrical equipment important to safety wil]
covered in a later rule, NRC said." (Id.)
It would be pure speculatiol attempt to estimate when or even if all.the safety equipment in THI-1'wil required to be environmentally qualified.
The next point in the staff's response which we believe is misleadin, the statement that "[allthough qualification of all of the equipment has been fully demonstrated, many of the inabilities 'to fully demonst compliance involve a lack of documentation of confirmatory test result support a finding that the equipment' is qualified."
This statement cre the false impression that most of the remaining problems involve only a missing pieces of paper or the per formance of some perfunctory tests will not provide any new informaticn.
In reality, the situation is far w and the staff knows it.
In urginE the' Cc=missicners to extend the June.
1
. 1982 deadline, the staff informed the Ccamissioners that " licensee submitt to date do not satisfactorily identify all deficiencies or provide compll justification for interim operation (Staff Recc=mendations Concera Extension of June 30, 1982 Deadline for Environmental Qualification Safety-Related Electrical Equipment, July 31, 1981, p.
2)
Tne staff af informed the Commissioners that its " review to date has determined that ?
qualification has not yet been demonstrated for approximately 807,.o f equipment in a harsh environment" and that it estimated "that 15-40', of equipment in a harsh environment will need to be replaced." (Id.)
The staff's own " Safety Evaluation Report for the Environment Qualificatior, of Safety-Related Electrical Equipment at Tnree Mile Isl Unit 1,"
dated March 24, 1981, discloses that environmental qualificat deficiencies exist in the following safety systems: Emergency Core Cooli Core Flood; Containment Spray; Auxiliary Feedwater: Nuclear Service
'n'a t Containment Isolation; Decay Heat Removal; nnd Centainment Cooling.
equipment involved includes pump motors, valve' motor operators, press switches, electrical distribution centers, solenoid valves, limit switch instruments to measure various temperatures, pressures and levels, cables instrumentation, cont.rol and power circuits, electrical connectors, termi blocks, containment electrical penetrations, and heat shrink tubing used an insulator.
The deficiencies range from some equipment that may inadequate "only" because of aging effects to other equipment that.may inadequate due to the effects of temperature, pressure, humidity, chemi spray, radiation, and aging, Thus, relying sclely on the staff's i
documents, it is clear that the staff's 1ctter to you is decide incomplete.
Numerous important safety systems at TMI-1 have not been sh to be capable of functioning during an accident and, under the extens proposed by.NRC, the deadline for demonstrating adequat,e assurance of saf will be postponed for years.
The staff successfully prevented UCS from introducing this same saf evaluation repcrt into evidence during the restart hearings, a ruling - t the Licensing Board now regrets. (Partial Initial Decision, December 1981, paragraph 1162)
The staff's objection to the introduction i evidence of its own safety evaluation report on environmental qualificat of TMI-1 safety equipment should be contrasted with its statement to you t<
"[t]his issue was litigated in the TMI-1 restart proceeding." The fact that this issue was not fully litigated, Despite the barriers which the staff and GPU erected to preclude completereviewoftheenvironmentalqualificationissue,theLicensingBoj nonetheless concluded that UCS " prevailed to. the. extent that UCS
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a demonstrated that all of the safety' equipment at TMI-1 will not meet all the [ environmental qualification) criteria in Regulatory Guide 1.59 at time of restart." (Partial Initial Decision, paragraph 1181)
Un for tunate
~ the Board declined to face the issue of whether " interim operation" of TM should be denied, in 'part because it also' was misled into believing that issues would be addressed by June 30, 1982. (Id.)
In sum, the staff's response regarding the safety significance cf j cnvironmental qualification issue is grossl* misleading.
It creates a fa3 impression that the issues were fully litignted, that the remaini
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corrected by June 30, 1982.
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and concluded that on both the staff attempted to mislead you.
The bases for this conclusion are, we believe, 2: ply explained in the discussion above.
If yc.u would like copies cf any of the referenced documents, we would be pleased
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you, as a lay.an, to substitute your judg.ent for the !!EC's on whether there is adequate assurance that Unit 1 can be operated safely.
We do not agree-entirely with that view.
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