ML20062J337

PNO-TMI-80-045:on 800915,NRC Approved Major Changes in Organization Which Establishes General Public Utils Nuclear Group & Which Includes Revised Plant Staff Organizations

ML20062J337
Person / Time
Site:	Oyster Creek, Crane
Issue date:	09/16/1980
From:	Jay Collins, Fasano A, Haverkamp D Office of Nuclear Reactor Regulation
To:
References
PNO-TMI-80-045, PNO-TMI-80-45, NUDOCS 8010100374
Download: ML20062J337 (2)

Text

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PRELIMINARY NOTIFICATION

,1 September 16. IS80 PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PNO-TMI-80-45 This oreliminary notification constitutues EARLY notice of events of_ POSSIBLE dfety or public interest significance.

The information presented is as initially received without veritication or evaluation and is basically all that is known by NRC staff on this date.

Facility: Metropolitan Edison Company Jersey Central Power and Light Oyster Creek Nuclear Generating: Compa Three Mile Island, Units 182 /and/

Statior, Middletown, Pennsylvania Forkea River, New Jersey Docket Numbers 50-289 & 50-320 Docket Number 50-219 Sub.fect:

MAJOR ORGANIZATION CHANGE Effective September 15, 1980, NRR approved a major change to the organizations -

of Three Mile Island Units 1 and 2, and Oyster Creek.

The change establishes a General Public Utilities Nuclear Group (GPUNG) through which the operating and management responsibilities for TMI-1, TMI-2 and Oyster Creek will be implemented for Met-Ed and JCP&L.

The change also includes revised plant staff organizations.

The GPUNG is being formed by combining the nuclear experienced management and technical staffs from within the GPU Service Corporation, Met-Ed and JCP&L into a single organizational entity.

The new organization is headed by the Executive Office GPUNG which will be responsible for the operation of Oyster Creek, the operation of TMI-l and the recovery of TMI-2.

Reporting to that office will be onsite directors from each unit.

Media interest has been expected because of public sensitivity to TMI related events. The Comonwealth of Pennsylvania has been infortned.

The licensee is planning to issue a press releasa howcver, the NRC has no plans at this time.

This preliminary notification is issued for infonnation or.ly and no further action by the NRC is anticipated.

The NRC TMI Program Office received notification of this occurrence by telephone from NRR on September 15, 1980, and this information was current as of 10:00 a.m.,

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Contact:

D.

R." Haverkamp 590-3950 A. N. Fasano 590_-3950 J. T. Collins 590-3955 Distribution:

(Facsimile Transmission Times Noted)

H St Bldg Chainun Ahearne Coninissioner Bradford S. J. Chilk SECY Commissioner Gilinsky Consnissioner Hendrie C. C. Kanvnerer, CA ACRS.

(For Distribution) p~~

THIS DOCUMENT CONTAI 801010037M

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'q. Tex T TM J_L

M'ni Mrin n - f t er 'eciJ ent.

l Go / aff.Jnita this contentisn ': hen they scy the rurpose ia nat to etect on-lauionI, but to ;ravent then. Gee race 2 of t

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io1J affiJavit. Ho i oubt the Staff tha; a?; roved TIII docian f

i atten to" to 1 rovent y concentrationa thet acre high enough to en;1ro, but thcy feilcf. Staff can not win on thic iacue by

hr::ing that T.;I ~ca Tifferent. Ti.cy cust chon viith ccientific data that' even un: r the :orct caro acci"entu that th3c reconbiners cnd ainin; cystena are cufficient to accure that no concentration vrould reach ay :( 43.

1 The ;I, nonitorin; cyston chould turn on autonatically.

If one ccn forset to turn on large valves for several days t.;cn one nicht cet caroles: in the heat o f en accident.

2. I li:h to be chr.n that the locations are at Joint.. of n'udnun cancentrr.tiona.

3.

o no aC to bc sho'. n that the ni:d.n; lotential is sufficient to acc; li, fic. orec'i.

4. Jhc cc acity o C the canbincrc ir not cufficient to handic

bel 2cci.cnt chat 3

nor:tca nuch :g 3 c. Thi-13 ea.ecially true

inc; there la no revician to C;rce the y throu;h the reconbiners.

O. 2:.e cciccity Of the '.:y'ro;cn iurco ;y;tou ia not,;ecified.

6. "ho n;nitoring cycten la not decisned to lithstanc' the forcc = heat o f, hydrogen c:(-losi:n and still even nonitor the hyCro:;cn concentrations au they buil t u: ascin liho they did at

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Res ectfully cubmitte'?,

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usarlanJ, Tenac 77475 C *tif'.crte rf Service In Jctober 2, 1930 (late in the day)-I sent copicn ta tho

.artion by U.;. anil.

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1 cir all cn! the ryrcli can bo raniasted ac o en chcnnel flou 4

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.c the ;cnnin ; equatien. The clo e ic the slo e of the i

rater nurface from the to of the,001 to the second 0;enins of c

the vent, io tho cth that the rater =uct flori to set out of the i

cir call area into the cu wreccion ;ool. Staff also is wrong in icnoring the frictional lacces both in the vent 01:e and in the i

flori to the entrance of the vent si;e. The concrote UG will be rou;h cac have a lorco nannings n factor or friction factcc if the

co y Jincran ic used for more detailed caculationc koo Fi;ure 5.32 of ';trecter's 'ui' Mechcnicc.The friction effect of the concrete wall ic JoubleM beccuco there 10 two calls, 26 inches acart.

It _c connon to uco the avera;o 31oro, inctead of an exactly

~1ooth clo c, in flo;; ccculations. Fcr onan;10 the U.:'.

.irny Corps af 2.;in ers ucon the 3:;C-2 Coa uter ;rogran which uses the average clo;c bet";cen river crosc-coctions in the Mannings fornula when it caculatec flow ratec in rivera.

Tho,taff errorcU in not concidering the ex;cnsion cnd cort-raction caefficient: of head locs, r;hich are cinilicr to friction caafficientu in that they coth cause the Octor flon toco closer.

See aco 265 of Strcctar rhore it ic.ointed cut that thece losses nrc o f ter lar;er then the friction lo sses. In cCdition the staf f hac not accounted for the fact that the water nuct nahe a risht angle turn when it enter the vent opening.

Onc staff alco crrara in saying that the clearing of one vent is uufficient. In fcet two vente must be cleared of water completely.

Jec yace 6-12 o f.L'?.

In ::unnary it can cafely be said that neither Tex PIRG nor

t:f f hav. correctly conciJered the causlen flon ;roblem involved in ro -i g clea-in; the vent furing a IACA Con;uters and cath can cot o the job cccurately enou;h to juctify the cua11 narcin cllored by the a ylicent. The only ccfc ncy to tect ic by full ccale tecto, at lecct a fu'.1 ccalc occtor with three vents.See ;ase 6-12 of 027.

Tine hac run out co I will neto verr brief replys to the Material yacta cubmitted:

1 It should cay accond set of vents. Alco that accumoc a Eryroll cIl of uniform strensth when in fact it noul0 have weak c ots c

in the cornorc.

2. The Hov 1974 m dio not isnoro friction coefficients. Oee cat;e 6-13. It is wron; 5 ignore then e.vecially in the rouch concreto rall: of the reir.

3. The tacts were only concerned with vont locsco and the tects were not full ccale under actual operating ccncitiinc.

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4. Jnce aSain they only considerad the vent-a smooth pipe l

not a rough concretc *:all with right angle turns to reach the vent,

5. Iho staff is a ' arty to this heeMng. I would like to j

hear their bacia cnd aco their Cata. They also approved the clants that have haa all the other groblens including TMI.

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6. There is no requirement for constant clore, cince cn avern;e clo;c of the cano value can be uced with the came reFult.

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7. Zhc venta have a cl: w cithauch it ic clo Jo to csro.

Il la no rator ath that is in;ortent in :ctermininl; the slo;c.

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i ucin; thcn in o;cratin;.lant then thy Jo they continue to fail.

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t Ucro cnce a;nin th;y have.ro:c + 2 new cycten ucin; ;res;ure Jiff:rential that clictinatca the floatc. Go that! They nahe no exclaination nor offer no rroof that this sucten will rork. En are ev7n uore concerne about their uso of Soli! Jtato aystona 30 cloce i

to the rcnctor vetrol becauco of the hi;h radiatiun levela in that orca.

..c aantioned before in the A50 contention, colid stato elect-ronica ic tery cencitivo to cuch raJiation. At the very least the licent should Le forced to Jotail the o;eration of tho.rogosed aT nca cyaten to the 3carJ, Staff end other intervenora in the public hearin3 1

llc Co not icagree nith thic atatenant.

2. ~;c Co no t ica;rce crith this statencnt cucopt for the lact ;cntLnce. ~l e a not believe that e G.E. engloyee who has be;n

]n the job for only one nonth has the ri;ht to toll the ap?licant chat cycton they *:ill use. The acrlicant has not said what they will do.

3. This statencnt only adCrocsos the float, but does not encure that the can;loto cycten till work ;roperly. Concidering the fact that the in t ;,'aten tiu not work even though it was no doubt n 7 raved by TiRC cr.' the % en;ineers hari croniaed that it rould work thora ic no roacon to believe thcn this time e recially :ihcn they have au;;lic ; no data to bach u; theiritald accertion" that it nill.

~,ta f f t, iCJ rM., Tex PTi?G a-6 ryrell Crackin7 This is con :10cred by Tex PIRG to be their most important cafety dantention because of the huco consequencec to the public safety if the vont clearins tine; are alow by only a fraction of ano ceconJ. Jec 11;ure 6-2 of 371. In the LOCA the force and creed of the raccuro build-u; 13 co creat that if the applicants calculations of sremure vercus tinc are off by only 0.5 cecond, the f ry ell c6 centein ent will within seconds be cracked or

hattercE rith ::uch force that cost of the radioactivity would inueuiately be lost to the atmos;;here in a way even worse then that canaiJoroJ in the !!AO i-740 report by Brookhaven Labs.

First I must joint out that the staJf'r.as handled this ilotion in a :'1uch better way than the anlicont. They have at least cncloce 3 actual Jata ant. referenceG actual studies. Also they are correct in come of their correction: to Tex PIRG's work. For exan;1e I

they are correct in.cinting out that no did not account for the

reccure ?.ifferential 6ue to thu cas grecsures. They are also correct in cayin; that the uce of the Mmnings formula alone is incorrect a

for flon throuGh cloned conduit.

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ocever they ucho several errors also. First the Hannings i

forau2 a is a vorcion of the Chezy for:sula which is a version of 4

the Darcy-':ciabach formula which the staff cGmits 13 :.ro;er for the a o in.i. co. 2.1:a staf f assumos that the flow is in cloced ripes

'.; hen in fact enly ; art of the flor ;ath is in ;i;cc. The part of the flo. fr?n tho in af the cui;roccion.001 to the vento bet ccn the

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i 9 3r-inJucm vihrnti 'n 77x 'tra Un, 11 1

i ero the a;;11 cant acmit 'there is a Generic Cafety problem i

l that in Aill unrecolveo. The :;2C and and Acvicory Committee on j

deactor Carocuarda both ctill say that tha ;roblem is unresolved, i

cae B-73 and II-33 o f Table D-1 of 312. In addition there would be no nec6 for 1sneric 12 cue 2-6C on Loone arta IIonitoring Gyctems if there were not ;oing to be any looce ; arts affected by vibration.

If the cc licant: 1974 testa had solved the problem, the AC23 would not have ar; roved this iteu as a Category 3 Task which means that it is in ortent in protecting the public health 2nd safety.

In contract the a.cplicant would have us believe that since it cleina to have dane some tos's (no test results have been shown),

anJ it cay: that it will do come more tests later, if necessary, then there is no iccue left to discuss. If this was the standard for rulin; on IIotions for Summary Judgment, then there would never noeu to be any public hearings becauce all applicants will promise to

.o whatever they think is necessary to calve tho problem.

In rec;onse to their Interial Facts, 'Jle state ac follows:

1 e : o not Coubt that it hac atudied the problem, but we say, I

ac Joos the apclicant, that the ; roblem has not been completely 301-ve d. '.io te A'plicant only says "com;onents are less likely to be damaced".

(2) and (3) only ;romise to do further studiec, maybe. Cur contention a;ccifically ctates that the ctudies have not yet been Cono r that future. romised ctu;iles are not relevant. This is cc acia ly co hcre cuch atuJica are only ;a;er studies or based on

. c 10 ns elc.

(4) tnd (6) relate to the ;act. Tex FI23 ia concerned about the future. ::o bacic is cupplied for the claim that past vibration

roblenc wid not cauce any loca of safety 'rotection. Ueither had rac.t history led the 3R0 to expect that at TIII valves would be im, roperly clocef or that a sm111 leak would lead to a celtins of the fuel.

(3) ~,le do not contect the fact that ACMGO will have a 10000 arta monitor, but the ar;.licant Goes not claim not doec Ter FIEG believe that the system till detect all vibration that could affect the cafety of the reactor. Tex IIRG is also concerned l

by w.

imination of the one cycten that has successfully detected vibration in Lav Sact, ie the transversing in-core proboc (TIPS) and re;1acin; it with a untasted accuctic system.

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Ontr,1 hi ~ rive nten-Tor iTRG "o.

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cnce again a;;11 cant hac attem;ted to limit our contention by clainine that it is limited to float critchec. The switches were only uue) to

2. 7 a (not all) bacia for the claim of a defective centrol rod drivo yctom.its recently as June 23,1980, this syston

till failed to nrk rhen 72 of 185 control rodc failed to fully incert at the

rorna Ferry nucicar ;1 ant using thece GE control rod i

drivoc. If GE always icci;nc cystems ;ro;crly and tests them before 4.

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i IT. M jim % int:.r rrnular 7t-c, Carre rinn Crnekim-Thic very insortant issue hac recently received auch attention from the "RC. Criterion 31 requires that the nn licant vrure that l

cven under acci4nt condition: that involvo hich preccure, including i

j clasa ') acciicnta nor,that the r ublic health and safety will not be hcraci by lenha in the reactor coolant rrescure boundary. It nuat even incluJe encu;h safety margins to protect for effects of irradiat-ion cni trancient otrecaca during accidents and after 40 years of o;cration.

1c;ito a lcrso number of fcilurcs in operating

:lanto over the. act few years of the lar;c gipes that had not even lasted one farth of tho ;1:nts o erating life and despite the fact that the

RC has listed thic ;roblon recently ac one of its Category A issues, A-42, the arlicant non atates that there is no fact iccue left and that the :roblcn is so completely solved that it chould not even be conciue_; in a ;ublic hearinc. 2Ven worce it baces this on the fact that it claims to have made cene changea that will help the ;roblem.

It chould be cufficient cncrer to this clain that tho IIRC Tack Force han not finally cnnounced that the vroblen hac been calved. Alco a careful reaJin; of a;;licant's notion chors that it does not oven clain that the crablen ic solved, only reduced. Reducing a problem of cuch cafety significcnco Joec not colv e it.

In addition as to each of tho ::aterial Issues, Tex PIRG ctates:

1 ::o do not dca;rce d.th (1), but would only point out that tho,y o not clain that it has not occurrod in other stainless ctonis. :~either have thcy clained that as norc operating experience i: ; therel on other fi;os that a lcr;e1 3 of ;1;es will show the rro-bien alcc. Jo clain is nado cna no evidence Given to chor that as more time acccc cn the noro rociate.nt "lon carbon" cteels that they to rill not chon the canc ;roblen.

(C),(3), cnd (4) ccn be considered tocether and cnc cred by nt ting that n:hin; conc chances to hol; the problem does not eliminate the ;roblen nor accure the protection required by the regulations.

cbviously if the :iRC felt tho ;roblen was colved the Tack Force would have been Cisbanded.

(5) : ot even the a;;11 cent' c ont statements clain that (5) is correct. Shat cl in ic only nado for Tyre 316 !!ucicar Grade Otain-loca Jteel cnf even there no bacis is Given for the statenont. The clain ic naCo that G.J.

aterted a ctudy in 1975, but obvioucly tay coulu not have tried theco lou carboa stocls in oreratins ;1 ant for noro than 4 yecra rhich io not lon; enouCh to accure their safety.

l The clained docunentation of thoce studica ic only tuo ;accrs that have not yet cycn been ubliched. C.tch self servinc statoments are 4

not acientific bncic for cuch clainc, at least until the scientific connunity : ac had tino to rec;ond to the papers.

(6) It nahos no censo at all to clain that compliance with Gui,le 1.E4 accuroc acetinc the Regulations or colving the ; roblem.

Guiic 1.% ;s in :nistenco in aucuct 1975 (; age 5-6 of G. Tonas CER) anJ 2110 :c - - au;cc.tibio cuatenitic utcela rhich cause the ;roblem.

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3.

It la irrelevant what the ion conect.trations are in the air.

Iono aid their clectric fieldc arq cacily shielded by metal box covers around the electronic circuitc. But nuclear radiation can cac11y icnetrato tho body of airplanco and th'eir thin metal covers that curroard como of the electronic equip ment..

I - I e-"X describos the intencity of comma rays as they g

pass through materialn of thicknesc x and maco absorption coeffic-ient u. This shouc that only 5% loss takes place in the intensity of the camma ray as it coes through Ono contimeter of A1. Since that i

is more than the total thickness of the airplane skin and cover of '

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the electronic container, it shows how easy it is for gamma radiation to affect the censitive electronics in the plane. See page 2724 of J

Handbook of Chemictry and Physics, 43rd edition.

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4. The radioactive emmiscions from ACUG3 are not low. Even by URC calculations over 32,000 curies will be emitted per year into the air. This is almost 5 timoc as much as the Black Fox Huclear plant will esit. Each curie is 3700CC00000, disintegrations per second and 60x60x24x365 timec that por year. There is no way that such numbers of cciccions are low. A penny for each eticcion would make the whole world rich, yet each caission can cauce a cenetic defect, cancer, or damoge a colid stato electronic device. According to UACH-740 the i

radioactive plume can bo hundreds of miles long. See Appendix S-Figure 6.

Although there would be come dispercion as the radiation ricos the dic_:crcion factore used in Reg Guide 1.111 show that when combined j

uith the rise ascociated with the heat releaced from the reactor the radiation can rice to creat distances. The recent St. Helens eruption and Ruusian bomb tests chow that radioactivo particlos can so around the earth soveral times.

5.

All of the information shown above go to show that it is possible i

for colid ctate electronico in airplanes flying near ACNG3 to be affected in cuch a way as to increase the probability to crash. Chen the few planes that fly near to nuclear plaats is considered with the few o;erating nuclear plants, and the fact that at least two haue fallen near to nuclear. plants it at least raices the possibility that the wall knocn sencitivity of colid state electronics is the cauce.

I The burden by law is properly on the applicant to show by independ-ent ccientific evidence that Tex PIRG is uranc. A careful reading of l

the Aeplicant's motion chors that it has tried to ;ut that burdon on f

Tcx PI2G. Zot only does applicant not understand the phycies of the t

contention, but it does not even supply scientific facts to back up its own theory based on ions. It nuct clearly show by calculation.

l the intencity of ra6iation at a few hundred feet above the air ejector t

if a cicnificant rortion of the 20,000 curies are emited at once' l

under the worct cace weather conditions which limit dispersion. It l

must then show the impacts on colid state electronics at that concentration. Thic will take laboratory experimental data on acutal l'

cyctonc used in modern aircraft. The affidavit of one of ap;11 cant's

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own employees who by his own recume hac had no experienco with i

clectronice will not fulfill that burtcn ec;.ecially when it 13 i

critten in cuch ;;ncral terms as "cui cions will decreace with time' but still fail to GVen Cefine the half life of tho' rolevant natorial.

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