ML20065T381
| ML20065T381 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/29/1982 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | |
| References | |
| NUDOCS 8211020383 | |
| Download: ML20065T381 (16) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'C2 P2! -1 M1 *05
,BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
UNION OF CONCERNED SCIENTISTS' REPLY TO APPEAL BOARD ORDER OF OCTOBER 15, 1982 Introduction On October 7,1982, UCS filed " Union of Concerned Scientista' Response to Board Notification BN-82-93 Concerning Semiscale Tests of Feed and Bleed and Mo ion that Appeal Board Direct NRC Staff to Provide All Pertinent Documentation and Analyses" (hereinafter "UCS Response to BN-82-93").
By Order dated October 15, 1982, the Appeal Board directed the Staff to respond to the UCS notion, granted leave for the other parties to respond, and l
directed that all responses be in the hands of the Appeal Board and UCS no later than the close of business, Monday, October 25, 1982.
The Appeal Board granted UCS leave to reply to any responses received.
~
UCS received copies of responses to the Appeal Board's Orde,r only from the Staff and the Licensee.
We consider the Staff to have violated the Appeal l
Board's Order because we did not receive Board Notification 'BN-82-107, which is relied on and cited repeatedly in the "NRC Staff Response to Appeal Board l
Order of October 15, 1982," until Wednesday, October 27,i1982.
We turn now to our reply to the Licensee and Staff responses.
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PDR ADOCK 05000289 0
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4 Reply to Licensee Response 1/
The Licensee makes.two major arguments in support of its position.
First, GPU claims that the Semiscale tests are not relevant to the TMI-1 design. Licensee Response at 1-2, 3-5 Second, it claims that its analyses prove the efficacy of feed and bleed.
Id,. at 5-6.
We will address these points seriatum.
According to GPU, the important factor which demonstrates the inapplicability of the Semiscale r'esults is that the Semiscale test simulated i
a plant with low-head HPI pumps and that TMI-1 has high-head pumps.
- First, this misses the fundamental issue raised by the Semiscale tests:
The tests G
.chow'ed the extreme sensitivity of feed and bleed viability to a number of different, plant-specific variables including the mass flow rate, the energy removal rate, pressurizer and surge line geometries, and surge line orientation.
Both UCS and EGaG concluded that the tests demonstrate that plant-specific analyses of feed and bl&ed supported by adequate experimental data are needed to conclude that this cooling method will work.
Letter from P. North to R.E. Tiller, August 6,1982 (hereinafter EG&G, August 6 letter) at l
7; UCS Response to BN-82-93 at 8-10.
The significance of the Semiscale test I
(S-SR-2) was not that'it used low-head HPI pumps and the PORV to attempt feed l
and bleed, but that it " suggested that a reasonable uncertainty may exist in the ability to effect stable [primory coolant system] feed and bleed." EGaG, August 6 letter, at 1.
In any event, the Licensee was apparently as unaware as UCS that another Semiscale test (S-SR_1) was performed using a high-head HPI pump, and "the 1/
" Licensee's Reply to Union of Concerrned Scientists' Response to Board Notification BN-32 93 Concerning Semiscale Tests of Feed and Bleed and Notion that Appeal Board Direct NRC Staff to Provide All Pertinent Documentation and Analyses," dated October 25, 1982 (hereinafter l
" Licensee Response").
l l
_3_
I system was allowed to establish conditions at the safety relief pressur in j
response to a loss of feedwater and loss of offsite power." Analysis of Primary Feed and Bleed Cooling in PWR Systems, EGG-SEMI-6022, September 1982, (hereinafter EGG-SEMI-6022) at 22, emphasis and footnote added.
During the initial part of the test, primary coolant system inventory remained relatively constant.
However, the bleeding mass flow rate increased due to changing fluid conditions in the pressurizer.
When the liquid level lowered to a point just above the core, an attempt was made to halt the net loss of coolant by adjusting the PORV set point downward, thereby reducing system pressure, in an attempt to increase HPI flow.
The mass balance was still unfavorable (i.e.
more water being lost than added), so pressure was again reduced in another attempt to recover p-imary system mass inventory by increasing HPI flow.
At l
this point, although HPI flow "was large enough to begin to recover mass i
l inventory, core unrecovery was too extensive to prevent excessive rod temperatures." Therefore, the test was* terminated. Id. at 31, emphasis added; c
See also pp. 20_31 generally.
Thus, Licensee's sole basis for claiming that the Semiscale tests are not relevant to TMI-1 is patently wrong.
The high-head pump test did no better i
than the low-head test.
In addition, Semiscale test S-SR-1 demonstrated that the TMI-1 PORY may be essential for feed and bleed cooling.
We remind the Board again that we do not assert that either the pump characteristics or the l
PORV are precisely the same as the TMI-1.
We reiterate: the point is that substantial uncertainties exist with respect to the viability of feed and 2]
Although the PORV was used as the bleeding path, its setpoint was adjusted so that it opened at the safety valve setpoint. Thus, there is no significance to the fact that the PORV rather than the safety valve was used. This test simulated the plant conditions which would exist at TMI-1 using the safety valves and high-head HPI pumps for feed and bleed.
- + - +
,r, bleed and that plant-specific analyses, backed up by testing, mus2 be done to resolve those uncertainties.
As EGaC noted: "Further analysis appears Babcock and Wilcox plant warranted to predict the probable response in.
designs."
_Id. at vii.
A related point is the Staff's claim that the Semiscale test "was only representative of a typical Westinghouse 4-loop plant."
NRC Staff Response to Appeal Board Order of October 15, 1982 (hereinafter " Staff Response"), at 7.
The implication, that the tests do not yield meaningful information for PWR's i
generally, is nonsense.
The subject tests were no more or less representative of a Westinghouse plant than a Babcock & Wilcox (or for that matter a s
Combustion Engineering) plant.
EG&G conducted the tests using the pressure vs. flow characteristics of pumps and valves that are used in Westinghouse plants because of "the availability of information and existing computer decks at [ Idaho Nuclear Engineering Laboratory]." Id.
As the Board has undoubtedly observed, EGaG reports its results generally in terms of their relevance to "large PWR's."
The Staff's circumlocutions should not be permitted to confuse issue.
EGaG itself states the relevance of the semiscale test results to Babcock & Wilcox plants like TMI-1:
While analysis of other plant designs (i.e., Combustion Engineering and Babcock and Wilcox) was outside the scope of the present analysis, it is clear that such analysis should be undertaken.
A simplified approach, consisting of constructing the "operarting as illustrated in this report, for each design would be a map" significant step in this direction.
Finally, it should be pointed out that no attempt was made in the present study to examine implications of the results presented herein relative to existing emergency operator guidelines.
This is an area that needs to be explored to determine if these guidelines appear adequate and are reflective of an understanding of the limits and dynamics of primary feed and bleed.
Id. at 111-112.
Licensee asserts further that, because of differences between the TMI-1 l
l design and the test conditions (of Semiscale test S-SR-2), "[u]ncertainties in l
i
. t obtaining a feasible., operating hand for feed-and_ bleed cooling, the subject of discussion in BN-82-93, are therefore eliininated with the use of high-head HPI pumps."
Licensee Response at 5 The first fallacy in this argument is that Licensee would ignore its own training and emergency procedures for TMI-1, cooling.1!
which direct the operators to use the PORV for feed and bleed Pollard, ff. Tr. 9027, at 5-16, 5-17; See also Licensee's Proposed Findings, paragraph 174, June 1,
1981.
Instead, it would have the Board look to a theoretical analysis of plant behavior which, while it purports to show tha+
the " bleeding" function could be accomplished through the safety valves, is totally inconsistent with the actual plant procedures, which direct use of
?
the PORV.
Moreover, the Licensee fails to demonstrate that the theoretically feasible pressure band for steady state feed and bleed, if it exists at all, encompasses 2500 psig. See UCS Response to BN-82-93 at 8.
In fact, in Semiscale test S-SR-1, discussed above, the upper bound of the theoretically feasible pressure band (assuming 100% quality bleed flow) was 15 4 MPa (2234 psig). EGG-SEMI-6022 at 22.
Thus, until a plant-specific evaluation is done for TMI_1, with suitable test verification, it is not known whether 2500 psig is within the theoretically possible pressure band for all bleed flow qualities from 0-100% at TMI-1.
The Licensee claims that its computer analyses are a " confirmation" of feed and bleed.
In the face of both of the new semiscale tests and all of the recent disclosures undermining the predictive capabililty of the B&W model (See 1/
At note 2 on page 4 of its Response, Licensee implies that use of the PORV could only improve the situation by increasing HPI flow and decreasing bleed flow.
However, this ignores the fact that early opening of the PORV could result in more inventory loss than cycling of the safety valve at 2500 psig.
Union of Concerned Scientists' Reply to Staff and Licensee Responses to Appeal l;
Board Order of July 14, 1982, August 25, 1982 at 26-29), it is difficult to understand how this assertion can be put fo rward.
It can certainly not be credited.
In addition, the B&W nodel used in the analyses cited by Licensees and Staff is generic; it is not even plant-specific to TMI-1.
Tr. 5127, Jones.
There has been no experimental verification of whether the model accurately reflects TMI-1.
It is ironic if not surprising that, while claiming th'at the results of S-SR-2 are totally inapplicable to TMI-1 because i
of different es in pump configuration, Licensee relies on non-plant-specific computer analyses for its claim that feed and bleed is viable for TMI-1.
This i
E say be an appropriate place to recall that the Licensee has the burden of proof on all issues, and appropriately so.
The reed to which it clings on this issue is far too slim to support that burden.
~4 Finally, the Licensee has an understandable interest considering recent developments in downplaying at this stag 5 the importance of feed and bleed to this proceeding and to the safety of TMI-1.
It was the Licensee that put forward feed and bleed many times as a reliable cooling mode which compensated for other potential equipment failures.
For example, the fact that was dismissed on grounds that feed pressurizer heaters are not safety grade l
cnd bleed cooling could be used if natural circulation were not possible.
Licensee Proposed Findings, June 1, 1982, paragraph 135 With respect to the l
need for feed and bleed, Licensee claims that " seemingly contrary" testimony of its witness cited by UCS was later corrected.
Licensee Response, n. ' 1 at l
- p. 2.
This correction assumed that a safety grade EFW system exists at TMI-1 and that it is sufficiently reliable.
Tr. 5646-7, Lanese.
As to the former, UCS disputes the characterization of the EFW system as safety grade because, at restart, EFW flow is still controlled by the non-safety grade ICS.
UCS l
l
"'
- f a
q -
I Brief on Exceptions, p.
104-105 Second, there -is no dispute that the TMI-1 EW system at restart is not safety grade for design basis accidents such as steam line break and high energy line break.
Staff Response, n.
11 at p. 7 As to the latter, the ASLB found that the TMI-1 EW system is not sufficiently reliable either before or after it is upgraded to safety grade and UCS agrees.
In sum, the Licensee's argument, which is echoed by the Staff (Staff Response at 7 and n.11), amounts to urging the Appeal Board to close its eyes to the clear fact that feed and bleed cooling is essential to protect public health and safety at restart for some design basis accidents.
9 Reply to Staff Response We now proceed to consider the Staff's arguments.
The Staff " construes
UCS's response as a motion to reopen the record and then urges the Board to reject it because it does not meet the legal standards for such a motion.
The fly in this argument is that UCS has n'ot made a motion to reopen the record.
We have drawn the Board's attention to the meaning and relevance of the technicial information presented in a Botrd Notification which was, in our view, grossly mischaracterized by the Staff.
The Staff (and Licensee for that catter) are obliged by Commission precedent to bring to the attention of Boards all new developments which bear on the issues in individual licensing proceedings.
This obligation is not simply an exercise in paper shuffling; it as delegees of the is required because both the Licensing and Appeal Boards, Commission's responsibility to assure the safety of the plants it licenses, must refuse to allow a plant to operate if there are significant questions I
about its safety.
Therefore, the facts surrounding the Semiscale results are now before the Appeal Board; UCS does not have to make a motion to reopen the record to accomplaish that.
Our response was made to alert the Board to
--s
-W-important aspects of the tests direct 3y relevant to TMI-1 which the Staff s
either failed to mention or mischaracterized.
Our request for production of the rest of the relevant documents was made at least partially so that we can determine whether to make a motion to reopen the record.
The Staff has now produced the specific documents requested on page 3 of the UCS Response to BN-82-93 As to our general request for other relevant documents, the Staff simple claims that it has provided everything that "the Staff considers arguably relevant and material..."
Staff Response at 4 The i
Appeal Board will understand that UCS does not find comfort in that assertion.
The Staff is a party to this case with an interest in minimizing the import of these findings.
It cannot be entrusted with what is the Board's job:
determining the relevance and materiality of these documents.
At the very least, the Staff should be required to present all documents not on the record relating to the viability of feed and bleed. This would include:
- 1. Documents dealinE with the a5equacy of the B&W codes for predicting plant behavior.during feed and bleed;
- 2. All documents dealing with the Semiscale tests or other experiments of feed and bleed viability, 6J
- 3. Any memoranda from the Office of Analysis and Evaluation of Operational Data ( AEOD) relating to feed and bleed viability or transients at operating plants involving feed and bleed;
- 4. Any documents indicating Staff requirements to modify the TMI-1 j
plant design or operating procedures related to feed and bleed;
- 5. Documents related to the capability of TMI-1 HPI pumps and safety valves (or relief valves) to operate under feed and bleed conditions;
- 6. Any material presented to the ACRS on a) the pertinent Semiscale tests and b) feed and bleed generally.
I As to the latter, we are aware that the Staff brie, fed the ACRS on these f
Semiscale tests during the-week ending October 1, 1982; this is reported in the Weekly Information Report to the Commissioners.
Surely, the material presented to the ACRS is " arguably relevant and material."
It is also
- orth noting that while the Staff was prepared to brief the ACRS on this subject on or before October 1,
1982, the Staff did not send out Board Notification BN-82-107 (transmitting the EGaG report dated September 14, 1982) until October 22, 1982.
UCS also finds it exceedingly difficult to believe that the request from NRR to EG&G to perform these tests was made orally and was related to " System 2
l Depressurization with Auxiliary Pressurizer Spray" as asserted in Affadavit of Brian'W. Sheron and Walton L. Jensen, Jr., Concerning Semiscale Test (S-SR-2)
Results, at 2.
Semiscale is operated by EG&G, a private contractor, under contract to DOE.
It strains credulity to believe that tests and reports of this magnitude would be undertaken by a contractor without written D
cuthorization.
In addition, the Depressurization with Auxiliary Pressurizer l
Spray relates to recent Combustion Engineering plants, which have n_o, PORV's.
o Furthermore, depressurization with pressurizer spray does not relate to feed and bleed since the former involves no inventory loss from the primary system.
In sum, there are many reasons to doubt the statements made in the Sheron and Jensen Affidavit in this regard.
The Staff states that it did not inform the Appeal Board of the Semiscale results in response to the Board's questions of July 14, 1982, because the Board asked only whether LOFT tests had been done.
Staff Response at note 5 I
on page 2.
Of course, this response evades the point made by UCS.
The Board and the parties have a right to expect the Staff to exhibit a more forthcoming attitude than is indicated by this exchange.
The Appeal Board should not be required to frame its questions as if it were cross-examining an accused felon.
-m-The Staff's only. response to the substance of UCS's interpretation of the 7
Semiscale tests is to ' asser't that the tests are just used to verify computer codes and that subsequent calculations using a code called RELAP-5 show that the TMI-1 core would remain covered.
The Staff offers not one iota of the underlying data or calculations necessary so that this Board could determine whether:
- 1. RELAP-5 is an acceptable code for TMI-1 (note that the Licensee's analysis was done by the B&W code);
T
- 2. The RELAP-5 code properly models the specifics of the TMI-1 1
design (the Staff does not mention whether this code is generic 3
or plant-specific);
- 3. There are experimental data to back up the RELAP-5 results.
The Board is simply asked to accept on faith that actual tests done at are to be Semiscale for both high-head and low-head HPI pump configurations disregarded in favor of calculations using
~
a computer cod 6, the accuracy of which is also to be taken on faith.
This is like being told to keep your umbrella down on a rainy day because the weatherman predicted sun.
l Nothing the Staff presents overcomes the basic conclusion to be drawn from the Semiscale tests: that plant-specific computer code analyses with are required suitable verification and adequate supporting experimental data to verify the viability of feed and bleed.
EGG-SEMI-6022, at 15 l
Furthermore, the Staff has said nothing a'cout the TMI-1 training and emergency provedures which relay on use of the PORV for feed and bleed cooling and the Staff never addresses in any manner those EG&G recommendations concerning the adequacy of operator training and emergency operating guidelines.
See, for example, p. at 112.
See also UCS Response to BN-82-93, at to, 12.
i t
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Finally, UCS had originally noted the Staff'.s statement that " feed and bleed, if performed, should be at a, relatively low (P<<
relief valve setpoints) pressure." UCS Response to BN-82-93, at 4-5 This provide strong support for our argument.that the PORY should be safety grade, since use of safety valves as the bleeding path threatens overpressuring the reactor vessel.
The Staff does not deny this fact.
Sheron and Jensen Affadavit at 2.
They could hardly do so, since the documents now released are full of references to the obvious risk of using the safety valves in this manner. See i
Memorandum from Sheron to Kniel, Enclosure, " Status Summary of Feed and Bleed Capability in PWRs," at 5, 7, and Enclosure, "Present Staff Position Regarding
' Feed and Bleed' for Decay Heat Removal," at unnumbered third page (both are attached to the Staff Response).
The statement on page 7 of the " Status Summary.." is unequivocal:
1 l
[hligh pressure feed and bleed is not recommended due to vessel
, structural considerations. Feed _and bleed should be performed at 17er pressures. Lemphasis addedJ
- ti i
j If, as the Staff claims, none of this is inconsistent wi+.h its position at the hearings (Staff Response at 2), that is presumably because the Staff a
n'ever mentioned that feed and bleed at high pressure (which is, of course, the
(
l condition when the safety valves are used rather than the PORV) may threaten the integrity of the pressure vessel.
Its failure to mention this hardly insignificant consideration, while it may be consistent, is no reason for ignoring the fact.
Furthermore, while the Staff claims that RELAP-5 calculations show that pressure vessel integrity would not be threatened for TMI-1 (Sheron and Jensen Affidavit at 4), those calculations were terminated at 5000 seconds.
In comparison, the Semiscale tests ran for over 17,000 seconds.
Even putting aside the question of the accuracy of the RELAP-5 code and of the assumptons L
~_
e f.
made with regard to. plant conditions, there is certainly no reason So believe that feed and bleed cooling will be needed no longer than 83 minutes at TMI-1, particularly for those design basis accidents for which it is undisputed that EFW is not safety grade.
UCS has had relatively little time compared to the Staff to review BN-82-107, which is a lengthy and complex document.
We are simply unable at this time to analyze it in the necessary depth.
However, we have found i
serious cetse to question the Staff's claims that the RELAP-5 calculations T
provide assurance of the viability of feed and bleed for TMI-1.
For one thing, the RELAP-5 calculations done by EG&G assumed operation of both HPI pumps, both charging pumps and both PORVs. EGG-SEMI-6022, at 91.
Thus, there was no attempt to comply with the single failure criterion for accident analysis.
Such analysis would not be acceptable under the NRC rules.
Since no details are provided concerning the parameters used by the Staff for its TMI-1 RELAP-5 calculations, it is not/ possible to judge the value of the results.
l In addition, we have noted and wish to bring to the Appeal Board's attention one of EGaG's conclusions that relates to another issue in this whether water level instrumentation should be provided for the l
proceeding TMI-1 reactor pressure vessel.
One of the " conclusions that can be directly drawn from these [Semiscale] experiments [is] is as follows: * *
- 3 Temperature response [s] in the hot leg, upper plenum, and upper head do not appear to be good indicators for determining liquid level in the vessel.
- As evidenced by the test data, the hot leg, upper plenum, and upper head temperatures did not respond to local liquid levels."
Id_.
at 56, emphasis added.
{
l e
e
l Summary Rather than dispell the question raisied by BN-82-93, BN-82-107 confirms that the viability of feed and bleed for TMI-1 is in great doubt and can only be evaulated by a plant-specific analysis and experimental testing of the critical plant-specific variables.
Furthermore, the adequacy of the operator training and emergency procedures at TMI-1 related to feed and bleed cooling need to be evaluated.
On the basis of the facts known today, it cannot be concluded with reasonable assurance that feed and bleed cooling will cool the core. Therefore, TMI-1 should not be permitted to restart.
b Respectfully submitted, A
- Y Ellyn R. Weiss Counsel for UCS b
Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C. 20006 (202) 833-9070 Dated: October 29, 1982
O 00tKETED UNITED STATES OF AMERICA
.' y m t NUCLEAR REGULATORY COMMISSION
'82 NBV -1 N1:06 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD S E vRt. la 4
r/., Tr g & $EiNICL
""" i'9 R t.K 0H In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 (Restart)
)
(Three Mile Island Nuclear Station,/ Unit No. 1)
)
T AFFIDAVIT OF ROBERT D. POLLARD Having been sworn, I hereby depose that the facts contained in the foregoing " Union of Concerned Scientists' Reply to Appeal Board Oreder of October *, 1982, are true and accurate to the best of my knowledge and belief.
Robert D. Pollard Sworn and subscribed before me this 29th day of October 1982:
l i
l y.y Commis::icn exP res l
October 31.1986 l
l 1
o I
ect m E:
UNITED-STATES OF AMERICA
';c' NUCLEAR REGULATORY COMMISSION 82 E'! -1 N1 :06 In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket Nofl,50r2B9
)
'( R'e a t 6*r't -)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
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Nunzio Palladino, Chairman Dr. Walter H.
Jordan U.
S.
Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
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S.
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Thomas Roberts, Commissioner U.
S.
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. o
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