ML20094A226
| ML20094A226 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 11/02/1984 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | |
| References | |
| CON-#484-895 2.206, SP, NUDOCS 8411060334 | |
| Download: ML20094A226 (14) | |
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- g4 0c5$1V2/84IN UNITED STATES OF M4 ERICA NUCLEAR REGUIAIORY COMISSION BEFORE THE COMISSION In the Matter of )
)
GPU NUCLEAR CORPORATION ) Docket No. 50-289
)
(Three Mile Island Nuclear ) (10 CFR 2.206)
Station, Unit No.1) )
UNION OF CONCERNED SCIENTISTS' PRELIMINARY RESPONSE 'IO DIRECTOR'S DECISION AND REQUEST FOR DEFERRAL OF NOVB4BER 6 MEETING, EUR OPPOR'11.JNITY 'IO ADDRESS COMISSION AND FOR PRODUCTION OF CERTAIN DOCLNElfrS
'Ihe Comission is tentatively scheduled to meet on November 6,1984, to have a oriefire and possible vote on Um's 2.206 petition concerning the 'IMI-l Emergency Feedwater System. UCS requests that the Comission defer this meetirv3 to allow UCS a reasonable time to subnit its review of and response to Mr. Denton's decision. We also request an opprtenity to address you orally if the Staff is to present a briefing.
As the Commission is aware, UCS is currently engaged in preparations for the remanded 'IMI-1 restart hearings, as well as in ongoing proceedings before the Commission to determine the necessity for and scop of those hearings.
The full-tine efforts of UCS counsel and cognizant technical staff has been required for the past two months to meet these obligations, which include review of thousands of pages of documents, the preparation for and conduct of 8411060334 841102 PDR ADOCK 05000289 g PDR .
..over 15 depositions in Washington, Harrisburg, and King of Prussia, numerous prehearirg conferences and teleconferences, the preparation of direct testi-mony 'and cross-examination and the filing of briefs before the Comission.
These obligations have prevented UCS from preparing a complete review of Mr.
Denton's decision and the bases therefor.1!
As a result of our preliminary review to date, we wish to call your attention to two very important areas where we believe that facts have not been presented to support Mr. Denton's decision. The first concerns the Sta ff's conclusion that, although 5 audits were required to address the question, the Staff can now be assurcd that the necessary equipnent in the emergency feedwater system is qualified to survive accident environments. In judging the weight that can be attached to this conclusion, you should be aware that the Staff stated with egaal assurance in its June 1980 Restart Safety Evaluation of 1MI-l that the Em system was fully qualified for a main steam line break. NUREG-0680, p. Cl-10. However, when the documentation allegedly supporting this claim was finally audited as a result of UCS's petition, this assurance was shown to be without merit. We Director's 1 Decision, dated September 25, 1984, and the supporting Safety Evaluation Report, dated September 13, 1984, make it clear that the EW system was not in
, fact so qualified, that much of the alleged doctmentation did not exist, and that replacement of certain components and other plant modifications were required.
1/ %e filing of this paper now was not intended to disrupt the Commission's decision making process. In addition to being fully occupied with the obligations discussed above, we were aware that the Commission previously postponed a similar meeting scheduled for October and, from several telephone calls to the Office the Secretary, that the November 6 meeting was only " tentative."
I p,
his is totally consistent with the pattern of the environmental qualifi-cation review 'for 1MI-1 -.during the last five years. %ere have been several j instances dere GPU and : the Staff were unable to support their claims that 2I-1 equipnent was qualified when called upon to do so.. For example, on July f 26, 1984,- the conunission ' gave the Staff 14 days "to . certify the status of t environmental qualification of equipnent [within the scope of the rertart
! proceeding) as discussed above for radiation -levels associated with large break IDCAs in accordance with the DOR guidelines." CLI-84-11, ' S1. op. at 9, i
July 26,1984. To date, the Staff has been unable to do so even though it has '
i f claimed for years that MI-1 was safe enough to restart. In fact, in its -
latest briefing of the Commission on the status of the environmental l
qualification progam, the Staff characterized 1MI-1 as uniquely bad compared i
to other plants that- have been audited. During the Comunission briefing on.
September 4, 1984, the following exchange took place:
MR. N0(BIAN: * *
- 1MI was,'it was unique because we went. to that
- I plant we found that the records were not there. Sey clearly wre .
4 not there, i COMISSIONER ASSEIETINE: Had they said they were there?
l
. MR. NOONAN: Soy said' they were there. . hey said to us that f everything was qualified. We said,,"We went to come look and see the supportirg documentation." We went up there and they did have records but they were no dere near complete. Some were handwritten ;
statement.s. After a couple of meetings . . . l CONISSIONER ASSELSTINE: Were the records sufficient to show that the equipnent was qualified?
MR. NOONAN: No sir . . .
Discussion and Vote on Environmental Qualification of Electrical Equipnent - Comission Meetity) Tranceript, September 4,1984, pp. l 64-65. '
It is true that later in the briefing, the Staff claimed that the records were now there and that they now support qualification. Id. , pp. 65-66. Yet, i
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while the Staff is now again concluding that the EEW components are environ-mentally qualified, the Staff has not provided for review the documentation
. which is claimed to support that conclusion. Furthermore, much of the documentation now relied on by GPU and the Staff to refute UCS was created after UCS filed its 2.206 petition. For example, in its June 1980 Restart Safety Evaluation Report, the Staff concluded that "the motor-driven EfW pumps will start and operate under the worst postulated environmental conditions."
NURH3-0680, p. Cl-10. Now, more than four years later, the Staff relies upon hCAP 10575, Rev. O, " Evaluation of the Operation of Emergency Feedwater Pump Motors in a High Energy Line Break Environment for GPU's WI Unit 1 Nuclear Power Plant," dated June 19, 1984. See " Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Director's Decision Under 10 CER 2.206 (Environmer.tal Qualification of Emergency Feedwater) ," September 13, 1964,
- p. 23. Furthermore, the electrical terminations for the EEW pump motors were replaced because their " qualification could not be docmented...." Id., p.16.
The documentation purported to establish the qualification of the replacement terminations (Kerite splices) is dated July 27, 1984, and August 3, 1984.
d Id., pp. 35-36.
Given the history of this issue, and this utility, we do rnt see how the Comission could possibly endorse the Staff's conclusion now without at least directing it to provide the underlying docmentation so that UCS and the Comiusion can review and evaluate it, he therefore request the Commission to order this material released and to provide for a reasonable period of tire to review it.
The second general area that clearly requires your attention concerns the basis for the Staff's overall judgement that mI-1 can be operated without
undue risk to public health and safety. %e - Staff concedes that the EEW system still does not meet NRC regulations applicable to a system important to safety in that it can be " rendered ineffective" by a single failure.
Director's Decision, pp. 24-25. Yet, without anything approaching a rigorous analysis, the Staff concludes that 'IMI-1 can be safely operated nonetheless.
The only basis for this assertion, and even this is implicit, is essentially a qualitative probabalistic analysis. That is, the Staff apparently believes that an accident is unlikely to happen. Id., pp. 25, 27-31. We can imagine no-clearer rejection of Governor Thornburgh's position that "[t?here should be no choice at all between resolvire safety questions before cranking up a nuclear reactor, or simply putting off those questions and crossing our fingers."
Statement of Dick nornburgh, Governor of Pennsylvania, Before the U.S.
Nuclear Regulatory Oomission, August 15,1984, p. 2.
In this connection, the Staff's understandirs of the status of the EEW hardware, as well as its view of what is necessary for safety and in what time fra.ne, has changed greatly in the past four years. In the original June, 1980 Staff Restart Safety Evaluation, the Staff found that the EEW system would be
" fully safety grade" by mid-1981. NUREG-0680, p. C8-37. Replacement of the flow control valves was stated to be the pacing item for this schedule. GPU proposed to delay completirg the upgrade until the first refuelirs outage af ter restart. The Staff refused to permit this delay; it stated that it would " require that the fully safety grade modification described above be installed within 60 days af ter receipt of the required equipnent." Id. Wis
" requirement" presumably reflected the staff's recognition of the safety importance of a fully safety-grade EEW system.
1 In the past, four years,1MI-1 has moved further away from achieving a !
l fully safety-grade Efh system than it was in 1980 in the sense that it is now l known a) that many nore changes are needed to the system (i.e., it is much further from safety grade than the Staff believed) and b) the Staff is no longer " requiring" completion of the safety-grade upgrade within 60 days of acquisition of the pacing equipnent.
In fact, as, of ' October 3, 1984, GPU had completed only 3 of 15 major changes to the EEW system required to make it fully safety grade, i.e., to meet the requirement that was orginally directed to be met by mid-1981. See H.D. Hukill, Director, TM I-1, to D.G. Eisenhut, Director, Division of Licensing, October 3, 1984, attachment, second and third unnunbered pages.
(this material was transmitted to the Conunission via a letter from GPU counsel Baxter to Mr. Oillk, 0:tober 9,1984.) GPU did not even release the basic engineerirg for the necessary electrical cable and conduit work until August, 1984. I_d.
d at fourth page. Upon reviewing the scope of the necessary work at this incredibly late date, GPU has discovered that it will need, inter alia, 60,000 feet of cable, 7,000 feet of new cable tray and conduit and 11 new control cabinets. The construction work cannot be completed until the third quarter of 1985, 'with three months required after that for startup and test activities requirity plant shutdown. Id.
Even nere astonishing, this end of 1985 schedule " assumes 7MI-1 shutdown during the entire construction phase." That is, if restart is permitted at any earlier date, the work will be put off. Hukill to Cinenhut, supra, p. 1, emphasis added. GPU has unequivocally stated: "We plan to construct modifications or portions thereof which would not prevent the plant being ready to restart when restart is authorized. At any point in time, we intend
I' to have 'IMI-1 in a configuration which would support restart within 4-6 weeks of ~ NRC permission to restart." Id_. Sus, so long as there is any chance of the Gomission authorizing restart, GPU will not even begin any portions of
'the EPW upgrade which would take longer than 4-6 weeks! Since the major piping changes ~ necessary would apparently take some four months from the time cutting into the existing pipes began (Id., attachment, unnumbered third page), this GPU policy would result in continually putting off beginnirg that crucial work so long as restart appears possible. It could not be more clear that there is no " schedule" for completing the EEW upgrade and there will never be unless the Comission directs that it be ,done. Wat this could be the case for a plant shut down for 51/2 years - almost enough time to build an entire new plant - .is almost beyond belief.
GPU is not required to build an entirely new plant; but as each year passes, GPU announces that the date for completion of the EfW upgrade has slipped another year into the future. During a meeting in Bethesda, Maryland on December 16, 1983, GPU told the Staff that, assuming that 'IMI-I was shut down for the entire period, the redundant EEK flow control valves and block valves would be installed by August 1984, and that all other modifications necessary to upgrade the EEW system to a safety grade system would be completed by December 1984. - During that same meeting, the Staff comented that GFU's comitment to complete the long term EEW modifications during the first refueling outage af ter restart had been made so long ago that if restart i
had occurred when anticipated, the modifications would have been completed before now. The only consisten:y one can perceive in the treatment of this l
2/ See Sumary of Afternoon Meeting with GPU Nuclear Corporation on December 16, 1983," dated December 22, 1983, Enclosure 2 (" handouts and other information received from the licensee"), three unnunbered psges entitled
! " Hearing Related Iong Term Action Items" and "Dnergency Feedwater -
Upgrade." Copies of these three pages are attached.
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E issue cince 1980 is that the flexibility of the Staff's " requirements" has kept pace with the flexibility of GPU's successive schedules. The Comission's 1979 order requirement that " reasonable progress" be shown toward completion of all long-term modifications as a condition for restart has been completely flouted. CLI-79-8,10 NBC 141,146 (1979) .
Against this background, the Staff's claim that the plant is nonetheless sufficiently safe to operate lacks support or credibility. %e fact is that the Staff has no technical analysis of the degree of reliability of the EFW system. We only attempt thus far was a quantitative reliability analysis of only one aspect of the system - its ability to operate to mitigate a snall l
break loss of coolant or loss of main feedwater accident. We ASLB found the EfW system insufficiently reliable largely on the basis of this analysis.
LBP-81-59, 14 NRC 1211, 1355-1370 (1981). The Comission overruled that l decision on t'he grounds that the analysis, which relied to some extent on generic information "may not" have been exactly applicable to 'IM I-1.
CLI-84-11, S1. op. at 13, July 26, 1984. Now the Staff has no technical analysis at all; it relies entirely on unsupported judgment. If the Comission was unwillirg to accept the former, it surely has no basis for accepting the latter.
UCS offers these two examples to illustrate to you that the issues I
treated by the Director's Decision are complex and require close scrutiny. It should be noted in this regard that the Staff took nine months to respond to l the UCS petition, although it was originally directed by the Comission to complete its response in two nanths. he believe that our request for time to i
respond to you in writirn and orally is more than reasonabic. I l
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We also wish to point out that, as far as UCS is aware, neither the OI investigation of whether GPU has made material false statements to NRC in connection with the environmental qualification program nor the OIA investigation of whether the NRC Staff provided false or misleading information to the Boards or the Commission on the environmental qualificacion issue have been completed. See Director's Decision, pp.19-20.
Although we have' not completed our review of the Staff's identification of each specific aspect of the MI-l EEW system with does not comply with the
' regulations applicable to systems important to safety, Mr. Denton's decision appears to be incomplete in this regard. For example, we recently learned that the MI-1 EEW system contains "four emergency feedwater enable / defeat selector switches." WI-l Operating Procedure 1102-11, " Plant Cooldown,"
Revision 47, 08/29/84, p. 9.0. Our recollection is that these switches were not discussed durirg the restart proceeding. Based on the limited information available at this time, these switches appear to violate the requirement of IEEE Std 279 (which is incorporated in 10 CPR 50.55a) which requires that bypasses of protective functions "be removed automatically whenever permissive conditions are not met." IEEE Std 279-1971, Section 4.12, " Operating Bypasses." These switches are not discussed in the Director's Decision or its supporting Safety Evaluation Report, leading UCS to question whether the Staff undertook a complete review of the WI-l EEW system to identify those features which do not meet the regulations applicable to safety grade systems or limited itself to responding to those identified in UCS's retition.
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In sum, UCS requests the following:
- 1. Deferral of the November 6 meeting until approximately December 15 to provide UCS time to review the decision and respond in writing;
- 2. An opportunity to address the Corrinission orally;
- 3. That the conmission direct the Staff to provide the documentation which purportedly supports the claim that all pertient EEW components are now environmentally qualified. Such documentation should include, if applicable, the justification for not requiring a component to be environmentally qualified and the qualification documentation for any backup or substitute equipnent.
Respectfully submitted, W
Ell . Weiss General Counsel JWk7m
- . a Union of Concerned Scientists
!!armon, Weiss & Jordan 2001 S Street, N.W., Suite 430 Washington, D.C. 20009 (202) 328-3500 Dated: November 2, 1984 W _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ . . _ _ _ _ _ _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
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EMERGENCY FEE 0 WATER UPGRADE SCOPE: HUREG-0737: ITEM II.E.1.1 l UPGRADE THE EFW SYSTEM TO A SAFETY GRADE SYSTEM A) MECHANICAL SYSTEM CONFIGURATION CHANGES B) SEISMIC UPGRADE OF PIPING SECTIONS IN THE 11AIN STEAM AND EFW SYSTEMS TO SEISMIC CATEGORY I (SUPPLEMENTS NRC GENERIC LETTER 81-14).
C) REDUNDANT CONTROL AND BLOCK VALVES i i
CURRENT STATUS: ALL tiODIFICATIONS ARE IN THE DESIGN AND ENGINEERING {
CYCLE.
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i SCHEDULE:. j IIECHANICALISTRUCTURAL ORDER LONG LEAD EQUIPMENT COMPLETE fl0DIFICATION (VALVES) ifEMS (A). (B).- RELEASE ENGNG. FOR CONST. DECEMBER 1983 :
G (C) RECEIVE LONG LEAD EQUIPMT. JUNE 1984 COMPLETE CONST. 6 IESTING AUGUST 1984 l
(Oui 4GE REQUIRED) r t
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EMERGENCY FEEDWATER UPGRADE
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' SLOPE: :NUREG-0737 ITEM II.E.1.1 '
A) ' MECHANICAL AND ELECTRICAL EOUIPMENT QUALIFICATION
- UPGRADE (SEISMIC AND ENVIRONMENTAL)
, ! 8) CHANGES TO THE CONTROL SYSTEM FOR EFW COMPONENTS-C)- OTSG LOW LEVEL AUTO-START D) llAIN STEAM RUPTURE DETECTION SYSTEM
- E) CONDENSATE STORAGE LOW L0w ALARM o
t CURRENT STATUS: ITEM (A) COMPLETE FOR RESTART ITEM (B - E) IN DESIGN.& ENGINEERING CYCLE SCHEDkLE:
ITEM (B - E) ORDER LONG LEAD EOUIPMT. JANUARY 1984 (ELECTRONIC CABINETS)
RELEASE ENGNG. FOR CONST. AUGUST 1984 RECEIVE LONG LEAD EQUIPMT. ***
COMPLETE CONSTRUCTION & TESTING DECEMBER 1984 (CUT *GE REOUIRED)
3UST RECEIVED GIDS, EEI' 2ELIVERv IS 40 WEEK SRC.
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UNITED STATES OF IMERICA NUCLEAR REGULA'IORY CONISSION In-the Matter of )
)
GPU NUCLEAR CORPORATION ) Docket No. 50-289
)
(Three Mile Island Nuclear ) (10 CFR 2.206)
Station,' Unit No.1) )
CERTIFICATE OF SERVICE
.I hereby certify that copies of "UNICN OF CONCERNED SCIENTISTS' PRELIMIN-ARY hESPONSE 'IO DIRECTOR'S DECISION AND REQUEST EOR DEFEPRAL OF NOVEMBER 6 MEETING, FOR OPPOR'IUNITY 'IO ADDRESS CONISSION AND FOR PRODUCTION OF CERTAIN DOCU4Erf1S" have been served on the following persons by hand delivery or, where indicated by an asterisk, by express mail this 2nd day of November 1984.
Nunzio Palladino, Chairman * 'Ihomas Y. Au, Esq.
U.S. Nuclear Regulatory Comission 505 Executive House Washington, D.C. 20555 P.O. Box 2357 Harrisburg, PA 17120 James Asselstine, Commissioner U.S. Nuclear Regulatory Commission Docketing and Service Section hashington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Comission Frederick Bernthal,Comissioner Washington, D.C. 20555 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Harold Denton, Director Office of Nuclear Reactor Regulation Thomas Roberts, Comissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 hashington, D.C. 20555 Thomas Baxter, Esq.
Lando Zech, Comissioner Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Comission 1800 M Street, N.W.
hashington, D.C. 20555 hashington, D.C. 20036
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