Text

Ucs Brief on Commission 840127 Review of Issues Decided in ALAB-729 & ALAB-744.History of Proceeding Shows Successive Narrowing of Issues Until All Unresolvable Issues Excluded. W/Certificate of Svc
	ML20087H413
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Site:	Crane
Issue date:	03/19/1984
From:	Weiss E; UNION OF CONCERNED SCIENTISTS
To:	;
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	ALAB-729, ALAB-744, NUDOCS 8403210014
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-UNITED STATES'OF AMERICA

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NUCLEAR REGJLATORY CCMMISSION BEEORE THE COttiISSION In the Matter of

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METROPOLITAN EDISON COiPANY

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Mcket No. 50-289

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(Ibstar t)

(Wree Mile Island Nuclear -

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Station, Unit No.1)

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UNION OF CONCERNED SCIENTISTS' BRIEF ON THE COMMISSION'S REVIEW OF ALAB-729 INTRODUCTIOt1 By order dated January 27, 1984, the Cannission took review of certain issues decided in ALM 1-729 and AI18-744.

Rose -issues are briefed below.

It

'is disheartening to note that the formulation of most of the issues foreshadows the possibility that the Commission may avoid grappling with the substance of the serious safety and policy questions presented by manipulating the scope -of the hearing to excitrie then.

Indeed, the history of this proceeding shows a successive narrowing of the scope until it excitdes all

' issues that cannot be " favorably" resolved.

We ' btrk, 'of course, stops with the Cannission.

Putting aside the question of whether the rules of this proceeding have been a matter of dis-ccetion or are dictated by law, the limits of discretion are not so broad as to ' allow the agency to turn a blind eye to serious safety deficiencies in DSO3 a

,, TMI-1.

We particularly urge the Chunission to give the fullest consideration to the fundamental question of-whether there is assurance of a highly reliable means _of. decay. heat;renoval at MI-1.

ARGUMENT 1.

Envirorrnental Qualification of Safety Equipnent The' operative facts relevant to this issue are straightforward:

1.

UCS had a contention adnitted in this proceedirg, which was later adopted and amplified by the Liceasing Baard, claiming that the pre-accident means of detenninirn the qualification of safety equipnent to survive severe accident environnents were inadequate to meet WC 4 and that MI-l should not be' penuitted to operate until GDC 4 was met.

B)ard Question /UCS Cbntention 12 quoted. at AIAB-729, 17 NRC 814, 891-2 (1983).

' 2. - -- UCS prevailed on this Contention; indeed, the facts were virtually uncontested.

No party even attenpted to show -that MI-l meets GDC 4 or that

all _ safety equipnent 'is environnentally qualified.

IBP-81-59, 14 NRC 1211,

_1981).

Nor was factual evidence subnitted by any party to 1409, para.1181,

(

justify a conclusion that 21-1 is sufficiently safe to operate despite nonccxnpliance with QC 4.

Indeed,. the Staff " defaulted" on the issue.

Id. at 1402, para. 1155.

FTnile the licensee's witness offered the sanguine view that 95% of the mI-l equipnent was docunented to be qualified to the standards adopted in CLI-80-21 i

and

t. hat the tenainder would be resolved by February 1, 1981 ( Id,., a t 1400,

. pira. 1149), his testimony was so vagua that the Baard concededly could not I

L

, rely upon it even to reach "a qualitative judgenent of the risk of allowing interim operation prior -to June 1,1982."

Id., at 1403, para.1157.1f Faced with the undeniable reality that the factual record of this

. proceeding contains - no basis for a fiMing on this issue that '1MI-l can be operated without posirs undue risk - indeed, the " facts" are to the contracy

-- both' the Licensing and Appeal Ibards have soujht refuge in the Comission's generic pronouncements on environnental qualification.

In so doing, they have alternatively misunderstood and misapplied those pronouncenents.

In CLI-80-21, 11 NRC 707 (1980), the Cbmmission, in response to a TS petition, adopted strict new industry-wide standards for establishing envirorrnental qualification and set a compliance deadline of June 30, 1982.

'Ihe Cornnission also. specifically directed the staff to continue a detailed review of the status of plant equipment and directed further: "These deadlines, however, do not excuse z. licensee from the obligation to modify or replace inadequate equignent promptly." I 11 NRC 707, 715, enphasis added.

The Commission. found that. the actions taken in CLI 21 " provide reasonable assurance that the public health and safety is being adequately lf Mareover, the licensee's testimony was false. As of Novenber 5, 1982, almost two years after Braulke's testimony, the Franklin R3 search Institute concitded that of 120 '"equipuent itens" (i.e., types of equipnent) in 'IMI-1, only 2 "equipnent itens" were fully qulified,1 was "qudlified pdndiDg modificatiion," 40 had not established qualification, 19 were deficient for qualified life, 25 were "exenpt," 22 were "not in the scope of the review" (i.e., not reuired for cold shutdown and/or exposed only to mild environnent) ard -for 11, insufficient docunentation was supplied to categorize then.. 'Ibehnical Evaluation Repart, Raview of Licensees' R2 solution of..Outstandity Issues frcm NRC RIuipnent Envicorrnental Qualification Safety Evalu:ition ik2 ports, 'IMI-1, Vol.1, p.

4-3, Nov. 5, 1982. A copy of the pertinent page is attached.

'Ihis material was provided to the Commission via Ibard Notification 82-133.

2f UCS is baffle 3 by the Appeal B)ard's statenent that TS " argues that" CLI-80-21 did not excuse licensees fran the obligation to prunptly replace inadequate equipnent.

' Ibis is not an "argunent.*

It is a direct quotation from CLI-80-21 and thus is a fact.

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. protected 'during : the' time necessary for corrective action."

"Ihe Licensir'3 Board ? cited - this lan~guage -(14 NHC at 1399, para, 1145) and later coanhrled that "the. question of interim operation has. already beeen addressed and decided by Cbmnission Order CLI-80-21."

Id_. at 1409, para.1181.

LBut. this is manifestly an erroneous arri legally impermissible interpreta-tion of CLI-80-21.

'Ibe Comnission had not a shred of evidence before,it on the status of safety equignent in 'IM I-1.

At most CLI-80-21 represents a statement of policy that M all equignent is fully qualified by June 30, 1982, and if,. tne staff in the meantime ensures pronpt replacanent of equ13nent discovered during. the review process to'be unqualified (as opposed to

- temporarily missing some docunentation), those actions make a generic shutdown of L plants unnecessary.

'Ibe Comnission did not and could not have used

~CLI-80-21 to ' resolve factual issues properly raised in a plant-specific proceeding.

Surely, the Cannission could not by simple edict overcone the

- facts in this record. ~ Cf. ' Minnesota v. NRC, 602 F.2d 412 (D.C. Cir.,1979).

' Subsequent. to the Licensing Ibard's decision, the Comnission suspended the June. 30,- 1982, deadline for compliance with the new environmental

- qualification-standards.

It based that industry-wide suspension, inter alia, upon the following determination:

- Ihe Cbmmission has receival, and the staff has evaluated, each 4

operating plant licensee's jugification for continued operation.

On the basis of the analyses,- the Comnission has determined that continued operation of these plants parding coupletion of the equipnent qualification' progran, will rnt present undue risk 4 co the public health and safety.

47 Fed. MJ. 28363 (June 30,1982).

- 3/ g It tus recently been conceded by the staff that these " analyses" cons 1%ted of detennining whether licensees had asserted that the plant could be safely operated. No." analysis" of the basis for these claims was made by the staff.

Discussion /Possible -Vote on Equipnent Qualification Policy Statement and Propased Rule, NRC Responsa to Court of App 3als Decision,

. Transcript of Connission !iaeting, January 6,1984, pp. 63-64.

__-____-____-___________-__-_x__

~

_ I'1he : Appeal Board cited this language and concided that the issue had -

thus been renoved L framr this case.

.17 NRC ' at 893-4.

'Ihe only possible

_ relevant distinc lon between the above-quoted pronouncenent of June 30, 1982, and ' the earlier-quoted pronouncanent of CLI-80-21 is that the former at least asserts 'that plant-specific data had been reviewed.

Howaver, in (CS v. NRC,

D.C.

Cir. No. 82-2000, June 30, 1983, tha Qurt held that this determination of _ plant-specific safety was both necessary as justification for the Coarnission's deadline suspension and was unlawf ully made without any opportunity for public participation, in violation of the Atomic Ehergy Act, the Adninistrative Procedure Act and the NBC's own rules.

Id., St. op, at 19.

2 It therefore obviously cannot serve as the basis for a conclusion that 'IMI-1 is currently in a cordition to operate wittout urdue risk to the public.

In LAEAB-744, the Appeal Board. rejected LCS' request that it reconsider

- its _ treatment of - this ' issm,

'Iha Appeal Baard's reasoning appaars to center on its belief that "[t]he C%mnission originally decided to address the issue of emironnental qualification generically," aM therefore the Licensing Ebard had no obligation to look at the current safety of' 'IMI-1.

ALAB-744, Cctober 6, 1983,, S1.op at 3..

A3ain, this represents both a misconstruction of both'

. CLI-80-21 and the Qmmission's " determination" of June 30, 1982, and an

. evasion of the crucial legal issm.

'Ibe fact is that the Cbmmission has always perceived and based its actions upon a clear understardirg that emironnental qualification is both a generic ard a plant-specific issue.

In CLI-80-21, it took the generic action of - adopting an lodustry-wide standard and deadline.

But it also understood that ' the agency has an overriding duty at all times to ensure the safety of each individual plant ard therefore it directed that the generic deadline not

' function as an excuse to operate when equignent in individual plants is

1

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discovered to actually be unqualified or when docunentation is po'or.

In the fonner case ~, prompt replacunent -or modification was required by the Cbanission

~-

Jand in the latter, a " technical judgment" justifying operation.

11 NRC 707, 715.

On June 30, 1982,_ the Qmmission again dealt with both the plant-specific

- and generic ~ dimensions of the issue.

G2nerically, it suspended (and later extended to.1985 or beyond) the industry-wide compliance dea 31ine.

Howe:ver,

it also made the detennination quoted above, purportedly based on plant-

specific ~ staff evaluations, that each plant tud individually justified interim

~ operation.,

'Itose plant-specific detenninations were a necessary precondition to generic deadline extension and were struc?. down by the court.

Ptreover, a furrianental truth seans to have becane lost in the muddle of buck-passing that has characterir.ad the NRC's tortuous evasion of the question

' posed by UCS.. Ibe evidence in this case shows that GDC - 4 is not met at 'IMI-l L

and. no-one, not the staf f, the licensee or the Boards have pointed to any

_ facts which. show that ' the-plant is. safe _ enotgh to operate nonetheless. 'Ihe Connission edicts male without providing parties the right of participation are not a lawful way to resolve issues fairly raised in a hearing.

Minnesota

v. NRC, 602 F. 2d - 412 (D.C. Cir. 1979).-

Perhaps the most bizarre episode in this entire. shell gane is the fact

'that even.the Mf has refused' to present technical justification for

- operation of 'IMI-1.

When the Staff was given the opportunity by the Appaal Board to explain how ad(xIuate protection of the public health and safety is

~

provided pending resolution of one aspect of this issue - the lack of an p

environnentally qualified pathway to cold shutdown --- the Staff, going full P

circle, stated that the Qmmission had "itself determined" that plants could operate safely despite lack of erwironnental qualification.

NRC Staf f's i

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- s. :nw ;m, ys e

7 ResponseL - to Appea1 Boards - Order of July 14, 1982, Affidavit of Zoltan R.

L

. Ibsctoczy, p. 3, Au3ust 9,1982.

.1. mis.. issue was, fairly raised in the restart hearing.

It clearly has.a

~" nexus" to the MI-2 accident and, just as clearly, UCS has prevailed.

'Ibe

~

licensee has not renotely appro'acheid meeting its burden of proving that safety

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canponents in 2I-1 are capable of surviving a 2I-2 type accident or that the plant -is nonetheless sufficiently safe to operate.

It cannot be seriously disputed that any intervenor in any licensing case is free to raise and litigate a plant-specific safety issue concerning environnental qualification, just as any ip%rv'enor is free to denonstrate that. failure to meet any safety requirement -is a basis for denying or modifying a license.

tereover, in the

'IMI-l restart case, intervenors were also free to ;hallenge the sufficiency of the NRC requirenents. to protect safety, in light ' of the 'IMI-2 accident.

CLI-79-8, 10 NBC '141, 148 (1979).

' Ibis important safety issue was raised by USC, has not been met, and cannot be lawfully "ranoved".

'Ibe Cornnission has' asked what the " proper scope" of the contention is.

' Ibe - scope of the contention, as affirmed by the Licensing Board, is the capability.. of safety couponents in tne containnent and auxiliary buildings to survive an accident at least as severe as mI-2 with 30- 50% fuel failure ( l 4 NRC at 1397, para.1140) and hence, coupliance of such equipnent with GDC 4.

The Commission has also asked whether the qualification status of equipnent can be "ccrtified" by the Staff or is an issue to be litigated in a hearing.

The' certi fication. procedure is offensive to the most basic principles of adninistrative due process.

A decision must be made the

" basis of the record af ter fair opportunity for exploration of the facts by

_ < the ; parties."

Seacoast Anti-Pollution League v. Costle, 572 F.2d 872 (1st

. Ci r. 197 8 ) '. -

anployees of the agency " engaged in the performance of

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k. _ p.

-investigative orL prosecuting functions for an agency in L ~ case may not F

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participate.- or.. advise in the decision."- 5 U.S.C.

554- (d).

See Transworld

. Airlines v. _ Civil Aeronautics Board,_25.4 F.2d 90 (D.C..Cir. 1958); FIC _ v., _.

1 Atlantj : Richfield Co.,

576 F.2d 96, 102.(D.C.

Cir. 1977);. Kirg v.

Caesar

Rodney School Distric,t, 380 F.

Supp. 1112, 1118 (D.C. Cir. 1974). 'Ibe Staff and: licensee had an opportunity.to present facts on the record.

Having failed toLdo so, the Staff, which was an adversary party opposed to UCS, cannot be permf tted to " certify" a new record to tha. Comission -- a record which will not' be subject to. UCS ' probing, will be made only by the-Staff - and licensee,.

and which would take the place of the hearirn record.

'Ibe Appeal Ibard. - recognized also that matters which go beyond the implanentation of a decision and involve the resolution of disputed questions 888.4/

must be determined by an adjudicatory body-not the Staff.

17 NRC at

Both.the - questions of 1); whether specific equipnent is qualified and 2) if

- not, whether operation can nonetheless safely be parmitted are the fundanental matters'in dispute raised by the contention.

'Iheir resolution perforce cannot be delegated to the. Staff and the mechanism for their resolution, assuning it

~

is other than a firrlirg that the record does not support restart, must provide LCS a. fair opportunity to present evidence and_ question witnesses presented by the other s'ide.

Mareover, if the Oxtrnission is interested, as it must be, in assuring

. itself of the safety of 'IMI-1 rather than in fittiing sane way to avoid the-issue, it should. welcone an open airing of the facts.

Right now, GPU is 4_/ '1his is a lorg-established precedent in AEC ard NRC case law. See Consolidated Edison Co. (Irdian Point Station, Unit 2) CLI-74-23, 7 AEC 947, 951-2 (1974);

Public Service Co.- of Indiana (Marble Hill tuclear Generatiry Station, Units 1 and 2), ALAB-461, 7 NRC 313, 318 (1978);

iCleveland Electric Illuminating Co. (Perry tuclear Power Plant, Units 1 and 2), ALAB-293, 2 NBC 730, 736-7 (1975).

E

...t

r.

in L

~_ attempting to-justify-operation of. the plant with unqualified equipnent in the EEW systen on-the' renatkable basis that the feed and bleed cooling mode can be d u. sed,_if.

EFW fa il_s._

H.D.

Hukill to J.F.

Stolz, Febr uary 22,. 198'4, e

Justification for' Cbotinued Operation, first unnumbered page.

7his is despite the _. fact 1 that ' the Appeal Ibard ruled that feed and bleed has not been denonstrated ' to be a' viable method of cooling the core. 17 NRC at 852.

Another rationale offered by GPU is _the undefined " low probability" of a high energy line. break.

GPU Nuclear Technical Ibsronse to Union of (bncerned Scientists' Petition for Show Cause Concerning TMI-l Energency Feedwater Systen, February 24, 1984, p.4.

This purported justification is perhaps even more revealing than the former, since the staff has made it clear for several years that' whenl a piece of safety equipnent is foud to be qualified,

. justification for contintmed oparation can not be basal on asserting that the

accident; is of low 1 probability,,/

Environnental qualification requirenents 5

t are -in place precisely to protect 'against u

relatively low probability but high consequence ' accidents.

ThatE GPU would nonetheless put this forward as justification - reveals a coupany that is either intransigent or still ignorant of its responsibilities in this area.

We. have 'as _ yet seen no : response by the Staff to these particular assertions; but we present than as _ illustrative of the need for close scrutiny

~

~of these issues.. UCS has no confidence aM cannot be legally required to rely upon the Staff to effectively' provioe this scrutiny.

. 5f 4he criteria for determining whether a plant may safely operate with nonqualified equipnent specifically do not include that the accident in question is of -low probability. SECY 82-51, "Staf f Pequirunent -- SECY 181-603B -- Proposed Rulunaking, Erriironnental Qualification of Electrical

.- Equipnent in Nuclear Powr Plants," App. A, Feb. 4, 1982.

See also 41 Fed. Reg. 2876, 2879, Gols. 1 and 2, Jan. 20, 1982.

b

. 2.

Dnergency Feedwater (EFW) heliability r

^

'lhe Omnission has asked Wiether the Appeal Board erred in its treat 2nent "

of the. Licensirg Board' quantitative analysis of the - EEW -systen -and, if-so, whether there is sufficient evidence in the record to support a finding that tha EEW systen is adequately reliable urder a quantitative or other rationale.

h need for a highly reliable EEW systen was one of tha primary lessons learned fran the 'IMI-2 accident.

NUREG 0578, July, 1979, p.10.

'lhe Staff has since determined that tho safety functions performu3 by this system are so vital that even - meetirg the sirgle-failure criterion is not sufficient to ensure system a3equacy. Cognizant AEOD staff wrote the following:

N AEW systen, in my opinion, is probably the most versatile and vital of the plant safety systems.

It is typically used during normal plant operation, i.e., startup ard shutdown, as well as in the mitigation of Instulated events such as main steamline break, anall break loss of coolant accident, loss of fesi generator tube rupture, and loss of offsite powr.gter, stean So crucial is the availability of this systen during a loss of offsite power that it is required by the staff to have at least two full-capacity irdepardent systens powered by diverse sources ard is the only safety systen designed to function during a total loss of AC, loss of offsite power ard failure of the redurdant onsite energency AC powr. - Further, it is the only safety system for which a reliability analysis mustabe perfogmed denonstrating an unrel2 ability in the range of 10 and 10 per demand.

C. Michelson, Director, AEOD, to H. Denton, Director, NRR, Technical Paview Paport, " Postulated toss of Auxiliary Feedmter Systen Ibsultirg fran Turbine Driven Auxiliary Feedwater Pung Steam Supply L.i Rupture," Feb. 16, 1983, Attachnent at 3, enphasis added.

In design review since the issuance of the Standard Ibview Plan, the auxiliary feedwater systen is treated as a safety systen in a pressurized water reactor plant.

It is required to satisfy toe decay heat runoval

~6/ Wa are amre that the 'IMI-l EEW system is not used for normal startup ard shutdown. Ibwever, that does not detract fran the force of this statenent.

7/ UCS offered this docunent into evidence in the Appeal Board's reopened hearirus on decay heat runoval.

'Ihe objections of the staff ard GPU wre susta ined, ' howaver.

i

s

, requirenents set Ibrth in General Design Criterion 34 of Appendix A to 10 CFR

Part 50.

It also plays a 'significant role in ~the mitigation of feedster transients, which are anticipated operational occurrences. NUREG-0578 at A-30.

General Design ~ Criterion 20 of Appendix A to 10 CFR Part 50 requires, in part,ithat the; protection system shall be designed to initiate automatically

'the operation of appropriate systens to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences.

Appendix A to 10 CFR Part 50 defines and explains anticipated operational occurrences as - "those ' coMitions of normal operation which are expected to

occur one or more times during the life of the nuclear powar unit and include but. are not limited to loss of. power to all recirculation puups, tripping of the turbine generator set, isolation of the main condenser, and loss of all offsite power..

In ' the' event of an anticipated oparational occurrence such as a main lfeedwater ' transient or a loss of all offsite power, the 'IMI-l systens

+

-initially available -for decay heat renoval. are the energency feedeter systen and the high pressure. injection 'systen. reaten, et al., ff. Tr.16,552 at 6-8.

GPU arg'wd that the EORV or pressurizer safety valves operating with HPl in the. so-called " bleed aM feed" cooling mode, could be relied upon in the event

~

ofl EW ' failure.

'Ihe. Appeal Board, bamver, agreed with LCS that bleed and feed has not been danonstrated to be a viable mode of core cooling.

17 NRC 814, 848-852.

After the ' reactor coolant systen has been cooled and depressurized to about '250 F and 320 psig, the - low pressure injection systen (also called the

. decay heat renoval 'systan) can be used to continua the cooling process until the con 3itions of c >1d shutdown (reactor coolant systen average tanparature

. less than 200 F) are reached.

Id. at 5, 9.

f ~

o

'Ibe : Licensee hasL perfonned no evaluation to' determine the probability of

loss of' main feedwater at MI-l.

However, " the generic data for BEW plants

.g. g.a,, over: a - two year period for;'five - plants (i.e., - 10 unit-years) show that the e

.fregmocy of ' loss 'of main feedwater was 0.3 per plant-year.

'Ibe Licensee.

estimated ; thatithe ' uncertainty attached to this ' frequency ' is less than a factor. of 19.. Tr. 16,618-20,. Keaten.

'Ihis represents a high probability of

. loss 'of main feedwater and a consequently high rate of denard for energency ifeedwater.

'Ibe = Licensee also does not know either the probability of failure. of the enecgency f feedwater systen or ' the probability of failure of all decay heat iranoval system at 'IMI-1.

Tr. _16,629, Keaten.

It offered no failure analysis.

~

'Ibe : Licensee, 'under cross-exanination, agreed that use of tha EEW systen for decay heat renoval relies upon the ' operation of other non-safety grade

~

equipnent sich.as the ' atmospheric dung valves,. the turbine bypass valves,

' and/or the main corxlenser.

Tr. 16,557-59, Keaten.

'Ibere is no way to renove Tdecay ~ heat fran.. the stean. generators wittout the use of non-safety grade equipment., Id. E'Ihis introdtces an inherent unreliability into the systan.

I

'Iha reactor operator is ~ relied - upon to' manually control steau generator

~ level.

Automatic control-of stean -generator level is provided by the

- non-safetiy' grade integrated control systen, but not at a sufficiently high level -_for adequate' heat renoval 'in the two-phase made of ' natural circulation.

Tr. '16,561-62, Ibss.

'In su:nmary, the ' Licensee presented no convincing quantitative or qualitative ezidence ugen -which one could conclule that the reliability of the

- methods - for decay heat renoval is suf ficiently high to justify restart in light of the lessons learnu3 fran the 'IMI-2 accident.

m

'O

~

- 'Ibe Staff testified that -it-had performed a reliability assessment of the

~~

'IMI-l EEW systan and concitzied that the EEW systen with the modifications to

, [be;implenented by the_ time of fres_ tart. 'would be sufficiently_ reliable to allow m.

restart of

'IMI-l'.

W nniel ard Curry, ff. Tr. 16,718, - at 1.

'Ihere es substantial questioning about the basis for this conclusion.

Tne. Staf f presented reliability estimates of the TMI-l emergency

' feedwater systen design as.it existed in mid-1979 and as it will exist after planned charges are canpleted.

Id. at 31.

In the latter case, the reliability ' estimate assuned that all of the lorg-term modifications had been coupleted.

Tr.

16,733, Curry.

'Ibe - Staf f's analysis usul failure rate estimates from WASH-1400.

Wermiel ard Curry, ff. Tr. 16,718, at 33-34, Tr.

'16,962,' Curry.

The Staff analyzed three specific plant " transients" that result in the danard for-EEW -- loss of main feedwater, loss of offsite power concident with

loss of main feedster, and loss of all AC power coincidenti with loss of main feedwater.

Wanniel ard Curry, ff. Tr. 16,718, at 32.

'Ib estimate the probability of EEW failure, the Staff defined failure as failure to provide 460 gpn flow to at least one steira generator within five minutes.

Id. at 31.

Given a loss' of ' main feedmter, the Staff estimated the probability of EEW failure to be 8X10~

for the mid-1979 design and 4.5X104 fx the design after all long-term modifications are completed.

Id. at 35, 37, and Attachanent 3.

'Given a~ loss of offsite power coincident with loss of main

- feedwa t ar, the Staff estimated the probability of EFW failure to be approximately the sane: as that for-loss of main feodwater.

Id. at 35, 37.

For a loss of all AC pomr, the Staff estimated the probability of EEW failure to be ) about-6X10~

for the mid-1979 design ard about the same for the design dfter all-long-teun modifications are CoupletrX3.,Id.

, The Staff'also estimated that, for the loss of main feedster transient,

-3 the probability of 'EEW failure is about 3X10 for the design as it wil1 exist-Lat tre proposed Testarti date.

Tr. l6,738, Wrry.

Se Staff did not present

~

an estimate of probability of EEW failure for the restart design for the loss of 'offsite power and -loss of all AC " transients."

me Staff witness believed that his estimates ware accurate 'within an uncertainty range of a factor of 10.

Tr. 16,965, Qr ry.

These are, of. course,.relatively high failure rate estimates,

particularly considerinj that the danan3 rate for the anergency feedwater systen is also high. mis is because EEW is required to remove decay heat for anticipated operational occurrences such as loss of main feedwater and loss of offsite po wr.. Ioss of main feedwater has historically occurred at B&W plants at the rate of 0.3 per plant year.

Tr. 16,618-20, Kea ten.

Thus, while it could conceivably be acceptable to tolerate lower reliability levels for safety equipnent which is called upon to function only very rarely, the evidence. shom '.that energency feedwater is needed perhaps once a year - or within that range.. Given this dunan3 rate, an EEW failure rate in.the range'which the ' staff presented is intolerable.

tbreover, the, failure cate is in fact higher than in3icated by the staff.

The staff witness biased the.results cif his fault tree analysis by simply assuning that at.least one of the diesel generators would function when called upon.

Wat is, he assunal that one diesel generator was available arri the

-2 probability of' failure of the other was 10 Tr. 16,971, Curry.

(CK requested the Baard to take official notice of the diesel generator failure cate estimates usa 3 in WASH-140C for. failure of a diesal generator to m

start of 3X10~

WASH-1400, App. III, Section 2, Table III 2-1.

Tne request was ' denied on the ~ ground ' that the - figures presented in WASH-1400 are not universally accepted. ~ Wis ruling ms incorrect.

L

We noted above that the failure rates 'used by the staff in the 1MI-l EEW -

analysis were generally deriv'ed fran WASH-1400.

A review of the record also

' sh6ws ; that, ths_,; Licensee.hss _ relied. heavily _on_ WASH-1400_ couponent__ failure._.-_

a

_:.2-rates in calculating accident probabilities.

(Eg, Tr. 11,107, 11,130, 11,140,

' Levy;. Lavy, ff. Tr. 11,049, at 14, 15.

In addition,. the Appeal Board decision in Florida Power and Light Co_.

(St.. Lucie Nuclear Ibwer Plant, Unit No. 2), ALAB-603, 12 NEC 30 (1980) is instrtx:tive., The issue in that proceeding centered around the likelihood of total loss.of AC power.

In that connection, -one staff witness on diesel generator ' reliability 'used the WASH-1400 dunand failure rate of 3X10~

Id.

r

- at 47. ' 'Ihg Appeal Baard noted that' this was an appropriate use of WASH-1400.

Id. at n.

60, p.

47..

Based upon this figure, they determined that the probability of failure of both diesel generators is in the range of 10~

to

.10 Id. at 48.

. Considering that the Licensee's objections to the Ibard's taking official p

notice of tha failure rate of diesels was general in nature and presented no -

facts suggesting that these-figures are inaccurate, and considering that. the Estaff has itself' used these figures in testimony very recently, we see no

reason why they cannot be officially noticed.

If the diesel generator failure rate were factored into the staff's

-analysis, the effect would be to make the probability of failure of energency feu3 water wen greater, alttnagh the exact magnittx3e of the change cannot be determina3.

Judging fran the Staft's failure probability estimates for the loss of main feedwater " transient," it can be concitded that relatively little of the improvenent in EEW, reliability attributable to hardware changes will be incorporated prior to restart.

Tr. 16,742-43, 16,74 6, Curry.

.n-

- 'Ihe Staff l attenpted to domplay the significance of the relatively high

~

probability 6f EEW failure in two mys. - First, the Staff claimed that' if more

_ _ time' forl operator - action were - considered,, i.e.,

if the definition of EW failure was ' changed to f ' allow more than five minutes to deliver flow to at least -one steam. generator, the estimated reliability of EW would improve.

' Ibis was one of the prime grouds cited by the Appeal Ibard for rejecting the

-quantitative analysis.

17 NRC 814,832-3..Second, the Staff claimed tnt the availability of the bled aM feed cooling mode could be recognized as a backup to EW - for decay heat renoval.

We now address these t.wo factors to explain why such testimony cannot be given any weight.

(

The ' Staff acknowledged ~ that it Nd done no analysis of 'IMI-l EEW failure probability for a time interval longer than five minutes.

Tr. 16,74 4, 16,746, Cur ry.

The Staff opined nonetheless tnt if a longer period of time were analyzed (i.e.,_ if the definition of _ EEW failure allowed more time to deliver E W _to the steam generators), operator action could introdtre additional failure ' modes, but that it was more likely that operator action would correct failures. Tr.'749,-Curry.

Ibwaver, that " opinion" was not based on review of

- the' iMI-l energency procedures or operator qualification training, or on any expertise of the witness and is little more than sheer speculation. -

Tr.

16,758-9, Wermiel.

There is, in fact no basis for conclding that accounting

~

for operator action would significantly improve the chances of success on a-

quantitative basis, particularly considering the potential for operator misaction.

When the - Board (Dr. Jordan) asked the Sta f f to explain why Wastingrouse plants have an order of magnitude higher EW systen reliability than 'IMI-1 (Wermiel aM Curry, ff. Tr. 16,618, at 35, 37), the Staff attributed this to the difference in the success criterion.

That is, since W2stinghause steam v

e

~ : generators dry out in' the absence of EEW more slowly than MI-1, mmh more credit can be given for operator recovery action.

Tr.17,075-76, Curry.

Ibever,. B&W did analyze EEW reliability for 5,

15, and 30-minute intervals, and ini no case were the reliability estimates as high as the~ best Westingluuse reliabilities.

Tr.

17,076, Curry.

Werefo re, - this -record irdicates that, even if the success criteria had been loosened, no great improvement in EEW reliability would M danonstrated.

We Staff made no attanpt whatever to analyze the effect of assuning lonjer time periods.

Tr.

17,076-77, Curry.

We Appeal Board erred in accepting unsupported speculation as a basis for decidinj that lenjthening the time for success would.significantly alter the results of the quantitative analysts, particularly when B&W analyses irdicate otherwise.

We Appeal Baard's only other Msis for rejecting the quantitative

. failure analysis was its observation that, since EEW systems in B&W plants can vary widely in design, they could not be "sure" tMt the EEW challenge rate is applicable to. 'IMI-1.

17 NIC 814, 832.

mis objection seens fundanentally hypocritical to UCS.

2.

best available data is tnat frcx.i B&W plants; one can never be "sure" that it will precisely match 2I-1 perfonnance.

Irdeed, since all ~such historical. data. represent averages, it would be miraculous if the 2I-1 EEW : challenje rate were precisely the average.

But there was no evidence introdmed at all to indicate that 2I-1 would be significantly different within the uncertainty inherent in a quantitative analysis.

If one wre to accept the Appeal Board's reasoning here, na quantitative analysis muld ever be accepted.

In addition, licensee's objection, cdoptW by tne Appeal Board, focusM on wnether or not the EEW systen would be challerr3ed at the sane rate that it had been challenged in some partinent B&W plants.

How3ver, the reliability l

F

+

- criterion. concerns availability on denand.

te assanption is properly made that the EEW systen will be dananded because loss 5f main feedwater (a non-safety. grade, system) is an anticipated operational -occurrence.

Wat is,

it:islexpecta3 to occur durirg plant lifetime.

Moreos'ar,.-as IES has shown above, there is good reason to believe that tha failure rate presented by the staff is generous to 'IMI-1.

Ebr one thing, the analyses simply assumed that 'at least one diesel generatot would always be available and that the other would fail at a rate of 10'.

Tr. 16,971, Curry.

In addition, the quantitative analysis assumed, with a few non-germane exceptions, that the EEW systen was seisnically qualified.

W now know that

. th'is is very far : from the truth.

App. Tr. 345 f f., Wermiel.W See also UCS Cmments on te Camission's Ex Parte !beting of Decenber 17, 1982....",

January -7, 1983, pp. l 21-23.

i' We ' Appeal' Board's rejection of the quantitative EFd failure rates accepted by the Licensirg Board was unjustified.

However, even if the quantitative analysis is disregarded, that does not

' help GPU or. provide any rational basis _ for concluding that the EEW systen is sufficiently reliable. One must ask,_ if quantitative analysis cannot be used, where can the Counission look for a stan3ard by which to jtdge reliability and a measure by which to determine that the standard is met?

We only other staa3ard, indeed the - standard nonnally applied, lies in the Cant.ission's

. deterministic design criteria for systens important to safety; that is, the 4

General Design Criteria of ~ 10 CFR Part 50, App.

A, represent tha agency's lorgstanding jtdgment that the design of systans important to safety must confoun to specified criteria ensuring redurdancy, d iversity, testability, 8//." App. Tr."_ denotes 'the transcript of the Appeal Board reotuned hearirys on decay heat:runoval, held Mrch 7 and 8, and March 16 and 17,1983.

I

..g w < ac -

..w P

w h

- -l seismic and envirorsnentall qualification, etc., in order to ensure sufficient

/

rel'iability. Judged by this standard, the MI-l EEW systan Estently fails.

UCS has detailed the nunerous. Ways _ in Milch the TiI-l EEW systan fails to meet che ' equirenents -for a safety systen in many filings.

Union of G ncerned r

Scientists' Petition for Show Cause O ncerning WI-l Energency Feedwater Systun, January.20, 1984; Union of. Cbncerned Scientists' Cannents on the Commission's Ex. Parte Neting of DecenMr 17, 1982...",

January 7, 1983, pp.

7-28; Union of, Concerned Scientists' Findirgs of Fact arri Cbnclusions of Iaw on... Board Question 6, June 12, 1981, pp. 166-194; UCS' Brief on Exceptions to tM ~ Partial Initial' Decision of Decenber 14, 1981-Part 2, April 14, 1982, pp.

103-110.

h system is not renotely safety grade.

'Ihe deficiencies cut a

broad swath acrc,ss the spectrun of safety requirenents.

It does not meet the 1.

' single failure criterion..

It is neither seismically nor environnentally d

qualified,- the main steam line rupture' detection systen is grossly inadequate.

' See Union -of Cbncernd Scientists' Petition for Show Cause (bncerning MI-l Energency Fetdwater. Systen, January 20, 1984.

Irxleed, GPU itself has filed a 13-page description.of the - EEW systen modifications necessary to provide -

increased reliability in its capability to mitigate the effects of design

' basis accidents when. the main feedwater systan is not available."

H.

D.

Hukill, Director, 21I-1,'to J.

F.

Stolz, Atgust 23, 1983.

tbne of these modifications will' be done prior to restart, if' GPU's position is accepted.

.In the face _of the plain fact that the mi-1 EEW systen meets neither any quantitative 'or qualitative reliability criterion, the Oxanission is not free to if all = back on ~ wann feelirgs or tM hopeful speculation of witnesses who offered ro solid basis for their self-serving assurances.

h re is, it should be urderstood, another dimension to the question of

- energency feedwater reliability.

It is not only important that the systan

_y.,.y,t

,, y e a y

=cP.

4 deliver sufficient : mter to the steam generators, but at least equally important that the delivery of water results in establishing a mechanian for

_ ! adequate core cooling..

It is known that for anall breaks within a certain spectrun,' liquid natural circulation will be stopped by the formation of stean volds at the high points' of the primary systen.

17 NRC 814, 837.

'Ibe high point vents, even if tiny were operable, are too snall to assist in restoring natural circulation. (Id. at 837-8.

"Thcrefore, other means must be available to provide adequate core cooling durire a snall break LOCA." _Id,. at 838.

As noted above, bleed and ' feed, the primary alternative espoused by GPU, was not denonstrated to be viable aM was not accepted by tha Appeal Iba rd.

Id. at.852.

'Ibe only other alternative ms the so-called " boiler-coMenser" mode of natural circulation, discussed at Id., pp. 840-848.

The testimony on the subje::t of the boiler-condenser mode can best be described as unsettling.

!7he Staff hired EG&G to do a' canputer analysis of a.01 ft break.

Sheron and

-Jensen, f f. App. Tr. 83, at 9.

Each of the two staff witne.sses offered a different explanation of the phenanena described by the analysis which featured a bizarre " chugging" behavior that is physically impossible.

See 17 NRC 814,.n.

118, at 845; App. Tr. 597-611, Jensen; App. Tr. 707-723, Sheron.

The Staff believes that > this denonstrates that the codes are incapable of calculatire the phenonena that occur in transition to boiler-cordenser or even

= whether boiler-cordenser is achieved.

App. Tr. 622, 705-6, Sheron. We agree.

In this connection, - we strongly urge the Cxmnission to read (CS' detailed analysis of the record on tnis issue.

Union of Cbncerned Scientists' Proposed FiMinjs of Fact and Cbnclusions of taw on Ibopened Ibaring, April 12, 1983.

Staf f. members in the NRC's Office of Analysis and Evaluation of Oparational Data ~(AEOD) who have indep3Mently reviewed the question of boiler-coMenser viability concitded and still believe that the proposition

, that natural circulation would be established in the boiler-condenser mode is not, a certainty, particularly in the absence of: experimental data for B&W plants. App. 'It. 746-750, Ornstein; UCS Ex. 53... mis _ represents the official ABOD viewpoint. App. Tr. 752, Ornstein.

AEOD's concerns regarding reliance on boiler-coMenser arise from the fact that - there are many couputer analyses which have a high degree of sensitivity to' input parameters (Id. at 747), but ABOD is uncomfortable since there has been no denonstration that what is postulated in theory would actually happen.

d. at 748.

Ebrthermore, even if there ms a danonstration

~ of one particular break ' size, with a given set of paraneters, that doesn' t tell us Wat will happen with different break sizes.

Id.

'Iberefore, the Staff should not give the impression that w can almys establish this mode of cooling.

Id.

'Ihe witness agreed that one cannot predict fran the collection of canputer analyses available, with different paraneters and different results, F-how the plant will behave over a spectrun of SBIDCA's.

Id. at 750.

'Ibe EG&G REIAPS. analysis predicting " chugging" was characterized by the AEOD witness as an "outller."

App. Tr. 788, Ornstein.

Such an outlier cannot be used to confinn the result of other codes which predicted very different plant behavior, precisely the case hare.

AEOD " wanted to understand more about the stoppage of natural circulation; wa wanted to know more about the re-establishnent of circulation; we w nted to know more about how the operators would be able to determine 758.9/

'Ihese are very where they were aM what they had to do. "

Id. at

- 9,/ ' In this connection,- (CS asked Mr. Ornstein whether AEOD has reacNd any

.judgnent about whether, for 'IMI-1, we can have confidence that the

. oparators muld understand sat was going on aM wuld take the correct action. GPU objectM ad the objection was sustained.

App. Tr. 78 9.

, timportant que'stions sich have -not been answered.

Basically, a far better understandirg of the physical phenonena.in question is required. See App.. Tr.

~

759,'ornstein.

In general, AEOD's testimony confirmed the need for experimental testing before the Camission could conclude that boiler-coMenser is a sufficiently reliable means of decay heat renoval.

The EG&G analysis did not confirm the accuracy of the B&W codes.

The fact that both RELAPS aM B&W predict that the core renains coveral is far fran.conclmive, given the vast difference in the codes, the assunptions used, the plant behavior pred icted, arx! the great sensitivity of the analyses to the input assunptions.

The fact that two different, highly uncertain and doubtful analyses both predict X does not provide proof of X.

.One or both of the analyses must be convincing on its

. merits.

In this case, as Mr. Ornstein statal, "seein) is believin3."

App.

Tr. 749.

There is no experimental testing confirming that boiler-condenser circulation flow 'will adequately renove decay heat.

The couputer analyses done to date are - not sufficient without experimental - testing to provide assurance of the viability of boiler-condenser.

In the face. of this fundanental lack of understanding of how the plant would physically respond to a SBLOCA after interruption of natural circulation, the Appeal Board fell back on abstract heat transfer equations, purportedly denonstratirg the viability of boiler-condenser.

Ibe Appaal Ibard refused to allow LCS to pusue lines of inquiry wtuch would luve shown that' it

'is necessary for the operators to know what is actually happening inside tha plant in order for than to take the action necessary to maintain adequate core coolin3 See App. Tr.

566-584, 585-588.

Ironically, the TMI-2 lessons concerning-the need to pay heed to the danands on oparators (i.e. to minimize

, sources of confusion) and to provide them with the necessary instrunentation

~

' and.trainirg to ensure proper action have been lost 'on this issue. -

In. conclusion,, this record.does _ not support a conclusion that the 'IMI-l emergency feedwater systen is sufficiently' teliable on either a quantitative or qualitative basis, considering the vital safety functions which it performs.

s

+

- ' 'f3.'PORV' The' Commission 1has' asked w'hether the Appeal Board erred'in,

~

' holding thati5he ' arguments concerning 'use of the PORV during :.

L

- 1ow temperature-operation and-inadequate core cooling 1

. conditions were'outside the scope of the proceeding, and,-if

'so, whether these " alleged uses" 'of the PORV ~ require that it be safety grade.-'The short answer to both questions is "yes".

~

~ UCS explicitly cited both of these vital PORV safety functions as.: grounds for-requiring the'PORV to be safety grade.

See

~

Pollard,3ff.Tr.-9027 at 5-4 to 5-5,: items 3 and.6.

SUBJECT:

BOARD !20TIFICATION 82-133 - TMI-1

' ENVIRONMENTAL-QUALIFICATION OF SAFETY-RELATED.

. ELECTRICAL EQUIPMENT

-In accordance with the procedures for Board Notification, the attached

..-letter. (Sto1r to Hukill dtd Decenber 10, 1982), is provided directly to the Commission. The letter forwards the staff's Safety Evaluation Report and Technical. Evaluation Report.(TER) for envirormental qualification of safety-related electricakequipnent at THI-1. This

,.} ^., '

issue. relates to Board Question /UCS Contentfon 12. The information 4'

in the letter and enclosures does not change previous staff positions primarily.because it is based on a worst-case LOCA while the staff's m

hearing testimony pertained to a s:nall break LOCAs. The TER. because of its size, is being distributed only to those parties interested

~

fn the enviromental qualification issue. The TER will be provided to other.narties upon request.

or sinaisisneady terrell G. F,isenbh, Darrell G. Eisenhut, Director Division of Licensing.

Enclosures:

,SER

TER cc:

Atcate Safety Licensing Appeal Board g

g,hg. h gf for THI-1

_ OPE P

gy-tng futas JQ][NCj,030;[8 TO$0ll.".EUI8, EQllES"BEHDIEBl.EMA

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Eta-Service List.

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.. _i 2m82 a2m

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i TECHNICAL EVALUATION REPORT l5 REVIEW OF LICENSEES' RESOLUTION OF OUTSTANDING ISSUES U...

FROM NRC EQUIPMENT ENVIRONMENTAL QUALIFICATION

{-

SAFETY EVALUATION REPORTS (F-11 and B-60) 7

[

+

l METROPOLITAtl EDISON COMPANY d..e THREE MILE Isl.AND NUCLEAR STATION UNIT 1 VOL. 1 0F 2

' w '*'*

[..

NRC DOCKET NO.

50-289 FRC PROJECT C5257 J:1

J1 NRCTACNO. 42513 FRC ASSIGNMENT 13 L'Il I

(${

l NRC CONTRACT NO. NRC-03-79-118 FRC TASK 492 E:

X.

Ni l

Preparedby j

Franklin Research Cer, tor 20th and Race Streets Philadelphia, PA 19103 FRC Group Leader:

S. Pandey J;

I Preparedfor s

f Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer:

P. She::tanski November 5, 1982 O

)i This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or 1, ;..

responsibility for any third party's use, or the results of st,ch use, of any information, appa-

' ' ~,

ratus, product or process disclosed in this report, or represents that its use by such third

. lj party would not infringe privately owned rights.

a Yi Reviewe by:

Approved by:

}

nMk W

1 -

Seni[r/StaffEngineer Project Manater /

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[# e'partment[irec D

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. Franklin Research Center j

d A Division of The Franklin insatute The Nn,arma Frarakn Park.ey. Phda. Pa 191C3 (213144e uxc

,l i

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TER-C525 7-492 lt t

+

<9 a

I TABLE 4-1 NUMBER OF' EQUIPMENT ITEMS IN EACH QUALIFICATION CATEGORY t

-NUMBER OF NRC CATECORY EQUIPMENT CATEGORY DESCRIPTION ITEMS cusszzasssamassassummassassuuss===mussssssssazz===sss=sasas==sassazzz=sasazzz==z p

I.A EQUIPMENT 00ALITIED----~~~----- ---------------------------

2

)..

( EQUIPMENT ITEM N0(3).

110,112 )

L,..

4 (G

.I.B EQUIPMENT QUALIFICATION PENDING MODITICATION---------------

1

, [

t EQUIPMENT ITEH NOCS).:

116 )

f d

h_

II.A EQUIPMENT QUALIFICATION NOT ESTABLISHED--------------------

40

[ EQUIPMENT ITEM'N0(3).t 1,

2, 3,

6, 7,

10,

,.i))

a 11, 14, 15, 26, 27, 28, 29, 32, 45, 46, 49, 50, 51,'53, 57, 60, 66, 67, 71, 78,'79, 81, 93, 98, y

106,107,108,109,111,114,115,118,119,120 3-m k

.II 8-EQUIPMENT NOT QUALIFIED---------------------~~~------------

0 x

a

II.C EQUIPMENT SATISTIES'ALL REQUIREMENTS EXCEPT QUALITIED LIFE OR. REPLACEMENT. SCHEDULE JUSTITIED-----------

19 4.,

Q A(){.

C EQUIPMENT ITEH N0(S).:

5, -17, 10, 19, 20, 21, 22,'24, 33, 36, 39, 40, 56, 50, 59, 63, 64, 69, 7 2,) '

f*

y W.

y

- III. A EQUIPMENT EXEMPT FROM OUALIFICATION-----------a------------

25 hp C EQUIPMENT ITEM NO(S).:

4, 31, 52, 54, 55, 74, g ',

75, 80, 02, 83, 84, 86, 69, 97, 94, 95, 96, 97, r.)

99,100,101,102,103,104,105 1 a

.III.S EQUIPMENT NOT IN THE SCOPE OF THE REVIEk-~~----------------

22

[ EQUIPMENT ITEM N0(S).

9, 9,

12, 13, 16, 23, 25, 30, 34, 35, 37, 38, 41, 43, 49, 61, 62, 65, q'~-

6P, 70, 73,117 1 tv DOCUMENTATION MOT HADE AVAILABLE-----------------

11

[ EQUIPMENT ITEM NOCS).:

42, 44, 47, 76, 77, 85,

~

87, 68,.90, 91,113 1 T O T : f, 170

.==============================================t===========================:

r r 6

.A 4-3

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Nb ~~._ arch Center nMn Rese

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0 o

~

DOCPETrp l'3NP C (NITED STATES OF A'4 ERICA NUCLEAR REGULATORY CONISSION N WR 20 A10:50 tFFnL Of y p, 00C4f.ilNG & stii,4 SRANCH In the tiitter of

)

MIJfROIOLITAN EDISCN COiPANY

)

Docket th. 50 289

)

(R+ star t)

(Three Mile Islan3 tbclear'

)

Station, Unit No.1)

)

CERTIFICATE OF SERVICE I hareby certify that copies of " UNION OF COtCERNED SCIENTISTS ' BRIEF ON THE COMMISSION'S REVIDJ OF AIAB-729" tuve been served on the following parsons by deposit in the United States mail, first class postage prepaid, this 19th day of March 1984, except as indicated by an asterisk.

Nunzio Palladino, Chainnan Gary J. Edles, Chairman U.S. tbclear Pagulatory Ctmnission Atanic Safety ard Licensity Appeal Ibard Wshirg ton, D.C. 20555 U.S. tbclear Regulatory Ccmnission mshirgton, D.C. 20555 Victor Gilinsky, Ctmnissioner U.S. Nuclear Regulatory Ccmnission Dr. John H. Buck Washing ton, D.C. 20555 Atomic Safety atd Licensincj Appeal Board U.S. Nuclear Pagulatory Cannission Jmies Asselstine, Ccmnissioner Washing ton D.C. 20555 U.S. tbclear Regulatory Ctanission Washirgton, D.C. 20555 Dr. Reginald L. Gatchy Atonic Safety and Licensing Appeal Board Frederick Ibrnthal,Ccmnissioner U.S. Nuclear P,egulatory Ccmnission U.S. Nuclear ' Regulatory Ccmaission Washing ton D.C. 20555 Washing ton, D.C. 20555 Judge Christine N.

Kohl

'nionas Roberts, Ccmnissioner Atomic Safety and Licensing Appaal Board U.S. thclear Pcquiatory Ctmnission U.S. Nuclear Regulatory Ccmnission mshin3 ton, D.C. 20555 Washing ton, D.C. 20555 Docketing and Service Section Ivan W.

Snith, Chairman Office of tlu Secretary Aconic Safety and Licensing reard U.S. tbclear R.gulatory Ctmnission U. S. Nuclear Regulatory Ccmnission Washin3 ton, D.C. 20555 Wasniry ton, D.C.

20555

p

' Sheldon J. Wbife, Alternate Qiairman

Willian S. Jordan, III

i Atanic-Safety and' Licensing Board.

Harmon & Weiss:

U.S.' leclear Ilegulatory Comnission 1725 I' Street, N.W.~

Washirg ton,._ D.C. ' 29555 Suite 506 r_'

s

- Mrs.~ Nrjorie Aamodt Jashing ton, : D.C. 20006

~R.D.1 65

~ Coatsville, PA ~19319.

John A. Is in, Assistant O)unsel Pennsylvania Public Utility Ctnaission P.O. Box 3265 fi1xine Ebelflirg,, Esquire

!!arrisburg, Pennsylvania 17129 Office of 01ief (bunsel Department of Ernironnental Ibs:)urces ANGRY /7MI PIRC 505 Executive Ibuse -

1037 Maclay Street P.O. Box 2357 Harrisburg, PA 17103 Harrieburg, ~ PA 17120

Steven C. Sholly 0

m. Inuise ' Brad ford Union of (bncerned Scientists

Ihree Mile Island Alert '

1346 Connecticut - Ave., N.W., Suite 1101 1011 Green Street Washirgten, D.C. 20036 Harrisburg, PA '17102 Richard J. Ibwson Dr.. Judith H. Johnsrud Office of Executive Iagal Director

.Dr. Chuncey Kepford.

U.S. Nuclear it:gulatory Ccmnission

' Dwirormental Cbalition on Wasning ton, D.C. 20555

' Nuclear Power

'433 Orlarrio Avenue Thanas A. Baxter, Esq.

' State (bliege,' PA 16801 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 j

_, b --

A CJ

Hand delivered.

kI

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ML20087H413

Text

SUBJECT:

Enclosures:

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