ML20097C047
| ML20097C047 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/11/1984 |
| From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| Shared Package | |
| ML20097C040 | List: |
| References | |
| SP, NUDOCS 8409140245 | |
| Download: ML20097C047 (17) | |
Text
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RE1.ATED CORgESPONDENy$
o-00CKETED USNRC September 11, 1984
'84 SEP 13 P1 :43 UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In.the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S SUPPLEMENTAL RESPONSE TO THREE MILE ISLAND ALERT'S FIRST SET OF INTERROGATORIES AND'FIRST REQUEST FOR PRODUCTION On July 31, 1984, Intervenor Three Mile Island Alert (TMIA) filed its First Set of. Interrogatories. to GPU Nuclear Corporation and its First Request for Production.
On August 15, 1984, Licensee moved for a protective order limiting the scope of TMIA's discovery requests.
On August 30, 1984, the Licensing Board held a conference call during which it dis-cussed its tentative rulings on Licensee's motion.
The Board ruled on Licensee's motion by Memorandum and Order, dated August 31, 1984,'and. served on September 4, 1984.
On September 4,
1984, Licensee submitted its responses to TMIA's discovery reglests, without benefit of the Licensing Board's Memorandum F
and Order.
Licensee now provides the following supplemental responses in accordance with the Licensing Board's rulings.
8409140245 840911 POR ADOCK 05000289 e
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[;b or Supp.' Response to Document Request No. 5 All~ interviews of Mr. Dieckamp concerning accident condi-
-.tions and prodedures from March 28 through March 30, 1979, are available for inspection and copying in the Discovery' Room.
Supp.' Response to Interrogatory No. 3 Responses received-from members of the command team are available in the Discovery Room.
Supp'. Response to Interrogatory No. 16 Mr. Dieckamp has provided the following supplemental statement.
The notes and documents referred to in Mr.
Dieckamp's supplemental statement.are being collected to be made available in the Discovery Room.
"It is not possible for me to recall and recount every communication in which I was involved during the period between March 28, 1979.and May 30, 1979,' concerning TMI-2 reactor con-ditions and accident events.
The problem is compounded by the number of people with whom I communicated during this period.
To aid in' responding, however, I have reviewed my files for written commun1 cations and notes of oral communications during the period., Based on that review and my best recollection of that-period over five years ago, I offer the following account c
of my communications and resultant appreciation for TMI-2 plant conditions..
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"The first three days or so are more readily recalled.
My initial contacts concerning TMI-2 were limited both in numbers of people and gubjects discussed.
Additionally, my notes aid
'in recalling those days.
The contacts and the subject matter of those contacts were principally:
~
" March 28, 1979 "1)
At about 9:00 a.m. on March 28, 1979, W. Creitz gave me the first notification of problems at TMI-2.
My notes indicate a feed pump trip at 4:00 a m.; reactor trip; primary (pressure) relief; (drain. tank) disk r'apture; 30,000 gallons (of water relieved to the containment building basement); and 1# pressure (in the containment building).
Creitz also. mentioned failed fuel.
I indicated that that would not seem possible if the emergency systems had worked as intended.
I gained the impression that the emergency systems had functioned as intended.
"2)
Shortly after talking with Creitz, I talked with R. C. Arnold who was in Parsippany.
I remember asking him about the emergency systems and failed fuel;but I did not get the sense that Arnold pos-sensed added knowledge about the situation.
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"3)
At about 9:15 a.m.,
I made a brief statement concern-ing the situation at TMI-2 to the Pennsylvania Public Utilities Commission (PaPUC).,
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I attended'a press briefing by Lt. Gov. Scranton and staff at-about 11:00 a.m.
I left this briefing.with
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a se se of reassurance that=the plant's emergency Isyshems had functioned properly.
L
'I made further comment on'TMI-2 to the PaPUC at about 5)'
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-noon.
6)
I-spoke with some members of the Lt. Governor's staff
-at about 2:00 p.m.-
I learned nothing about the sta-tus of the. plant but heard some comments about radia-
' tion measurements.
I am unable to reconstruct the specifics of the comments but I was puzzled that the comments did not make a lot of sense to me.
I had hoped to sit in on the briefing of the Lt. Governor by TMI' personnel but I was asked to leave.
" 7)
At about 2:30 p.m.,
I encountered Herbein, Miller and Kunder on the steps of the Pennsylvania State Cap'i-toi.
They were on their way to brief the Lt. Gover-nor.
Our conversation was extremely brief.
I ex-pressed concern about the absence of senior people from the p'. ant.
I recall no detailed discussion of plant parameters or conditions but gained-the impres-
.s.
sion"that the plant was stable.
8)'
Sometime in-the-early evening, after returning to my-home in New.ersey, I spoke with R.
C. Arnold.
He told me about the plant having been taken solid and the' starting of a reactor coolant pump.
I recall no.
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if detailed discussion of plant parameters or a sequence
'of events throughout the day.
" March 29 /19[h.
"1)
On Thursday morning, March 29, 1979, I met briefly with R. C. Arnold in order to review and sign out a
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memorandum establishing a' task force to investigate and analyze what was then thought to have been a se-vere plant' transient.
"2)
During the afternoon I attended a briefing for a group of congressmen at the TMI visitor's center.
J.
Herbein's comments (which were transcribed) served as
.my first overall briefing as well.
I do not. recall having synthesized the various portions of that
~ briefing into a real understanding or insight into the extent of core damage.
I was satisfied that the plant was shut down, being cooled, and stable.
"3)
At the visitor's center, I spoke briefly with R.
Vollmer of the NRC.
He informed me about core thermocouples that were still reading higher than the coolant temperature.
We postulated fuel damage and localbflow blockage, but were unable to arrive at any conclusion.- I did not get a sense of anything omi-nous.
"4)
While at the visitor's center, I also spoke with some members of the task force that I had authorized '-
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earlier in the morning.
I have no recollection of any specific detail.from those conversations.
"5). Afteg returning to New Jersey in the early evening of March'29, 1979, I spoke with R. C. Arnold.
I think it was then that he gave me an increased awareness of the open PORV and interruption of high pressure in-jection.
We agreed that Arnold should go to the site to work with Herbein.
I still did not sense the full extent of the situation.
" March 30, 1979 "On Friday morning, March 30, 1979, I went into my
'Parsippany, New Jersey office.
I was discussing the status of g
TMI-2'with W. G. Kuhns'When we learned of the radiation release that focused new attention on the site.
My notes indicate that I spoke with R. C. Arnold at about 12:30 p.m.
and he relayed general information about the radioactive releases and radia-tion levels.
As a result of the ominous nature of the Friday morning information I began to seek assistance from numerous organizations around'the country.
My notes contain the first mention of hydrogen in a phone conversation with R. C. Arnold at 2:05 p.m. o,nsFriday March 30.
Notes of subsequent phone conversations'with Keaten at 2:30 p.m.
and 8:20 p.m. and with M._Levinson at 6:20.contain hydrogen related references.
"My' notes from the afternoon and evening of Friday, March YN
30 indicate that much of the telephone discussion related to '
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'O the presenc of, the removal of, and the operational problems
. ; y,r of non-condensible hydrog;en.
My notes provide no explicit ref-(3 erence but I tbink I first learned of the pressure spike some-u time on Fr5da'y, March 30, 1979.
During that Friday / Saturday night I stayed in the office and was in contact with the site anb remember speaking on several occasions with Wm. Lowe con-3e cerning hydrogen with pa,rticular reference to the radiolytic ji decomposition of water.
"I moved to the TMI site on the afternoon of Saturday March 31.
There followed a period of intense and virtually total immers1Ln in TMI-2 activities.
In April I spent most every day at the TMI site or concerned with TMI matters else-where.
Dur.ing the first few weeks of April I remained at the site.
I availed myself of the early GPU operators' interviews, sat in on preliminary revi'ews of the sequence of events, par-
' ticipated in status reviews with the onsite NRC staff, coordi-nated the activities of the Industry Advisory Group and gener-n ally participated in the management of the accident.
During
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.f the third week in April I drew upon this awareness and the developing learr.'ings, including an investigation of the closed emergency feed valves and the G. Miller report based on a taped conversation ahd reconstruction of the day of the accident, to assemble testimony for presentation to the Nuclear Regulation Subcommittee of the Senate Committee On Environment and Public Works (Hart Subcommittee).
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"By early_May when the congressional tour took place on May 7, I had gained a considerable insight into not only the
.present plant g..onditions and plans for plant stabilization and cleanup bu5'a' iso the plant conditions on March 28th, including lthe action of individuals-on that day.
"My understanding by early May of the accident is re-flected generally in my testimony to the Hart Subcommittee on April 23, 1979.
A similar but expanded testimony was given be-fore the Subcommittee on Energy and Environment of the House Committee on. Interior and Insular Affairs (Udall Subcommittee) on May 24, 1979.
"I do not recall specifically.but do not expect that my understanding of-the specific plant conditions on March 28th
-changed very much during May or indeed thereafter until the re-lease of the various investigation reports and their associated-materials.beginning with NUREG-0600 in mid 1979, and including the President's Commission, Rogovin Special Inquiry Group, and the Senate (Hart Subcommittee) Reports through 1979, 1980 and.
1981.
"As.for the specific plant' parameters which are identi-fied, my recollections of the first knowledge or appreciation of those params ers is:
"(a) Q The pressure spike which occurred at approximately
- g 1:50.p.m.
A See September 4, 1984 Licensee response...
"(b) Q The PORV had been open from approximately 4:00 a.m.
to.approximately 6:00 a.m.
A My earliest hearing of the failed PORV came from the J. Herbein briefing on Thursday afternoon, March 29, 1979.
The information at that time was not defini-tive about the duration of the PORV opening or when the block valve was closed.
My awareness of the duration of PORV opening and block valve closing had to come from early reviews of the accident sequence of events during the second or third week after the accident.
I cannot recall the specific occasion of my first awareness of the full duration of the PORV opening.
"c) ~ Q
.The HPI (high pressure injection) had been throttled during the time the PORV had been leaking during the early morning of March 28, 1979.
A My earliest hearing of the intermittent HPI operation or throttling came from the J. Herbein briefing on Thursday afternoon, March 29, 1979.
My subsequent awareness of the extent and impact of the PORV open-ing gnd the HPI throttling had to come from early re-views of the accident sequence of events and from the more analytical efforts of the Industry Advisory G-Group which was working to estimate the amount of primary. system inventory loss, the resulting core
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o water 11evel, and the resulting core damage.
This analysis possibly became available several weeks aftepfthe accident.
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"(d) Q
$$E leg temperatures'in excess of 700 degrees F had
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existed during-the morning of March 28, 1979.
A:
IL_do not. recall when I first became aware of hot leg temperatures in excess of 700 F.
I did not know about such conditions on March 28 or March 29, 1979.
Beyond that I cannot pinpoint how or when I became aware of high reactor outlet temperatures.
"(e)-Q Temperatures in: excess of the saturation temperature indicated the core was or had been in a condition to be cooled by steam rather than water.
'A
'I do not recall when I first became ' aware of tempera-tures in excess of saturation temperature.
I did not
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know about such conditions on March 28 or March 29, 1979.
Beyond that'I cannot pinpoint how or when I became aware of reactor outlet temperatures in excess
-of saturation.
For both (d) and (e) the probability of my learning of these details had to increase sig-
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nificantly on Friday March 30 and beyond.
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"(f) Q
- On-MErch 28,'1979, the TMI-2. reactor was in-a condi-tion not covered by emergency procedures.
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A I do not recall when I'became aware of " conditions
- not' covered by emergency procedures."
By the summer of.1979Lthere were numerous reviews of procedures and,
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operator response including an ACRS meeting, NUREG-0600, and efforts of the Keaten Task Force.
"(g) Q Certain GPU and/or B&W personnel on site on March 28, w
5979, were uncertain prior to noon on March 28, 1979, as to whether the TMI-2 core was being adequately cooled.
A I do not recall when I became aware of GPU or B&W site personnel's uncertainty about adequate core cooling.
The Herbein briefing on the afternoon of March 29, 1979 made mention of uncertain core cool-ing.
I most likely became aware of the views of var-ious site personnel via early GPU interviews which probably became available to me during the second week ~after the accident.
"(h) Q' The in-core thermocouple temperature readings for any part of the day of March 28, 1979.
A I do not recall when I first became aware of in-core thermocouple. readings on March 28,1979.
I think my first, general awareness'came from the G. Miller tape reconstruction of the day of the accident.
The G.
-Miller' reconstruction probably became available to me ab'ouh two weeks after accident.
It is my understand-ing that the thermocouple data was " lost" for some time and found-in a desk drawer in the control room about one month after the accident.
I then became aware of the actual measurements and their spatial distribution. '
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"(i) Q The. neutron detectors mounted inside and outside the reactor pressure vessel indicated increased neutron I
leve}s on March 28, 1979.
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i do not recall when I first became aware of the in-creased neutron levels on the day of the accident.
I think I learned of this effect and its implications
.concerning core water level sometime during the first two weeks after the accident from a member (s) of the Indastry_ Advisory Group'that was assisting in the re-construction of the accident.
An analysis was con-ducted which indicated'that these neutron measure-ments could be used to infer reactor vessel water level.
' "(j) Q.
The high' radiation levels detected'by the radiation monitor mounted at the top of the containment build-ing during the morning of March 28, 1979.
A I-think I first became aware of the high radiation levels.in the containment building from the J.
Herbein briefing on Thursday afternoon, March 29, 1979..The information was stated as uncertain and-tended to be discounted because of an uncertain ef-fect Nf-the shielding surrounding the detector.
2 "k)
Q The hydrogen explosion and/or combustion which oc-curred during the early afternoon on March 28, 1979.
A --
See. September 4, 1984 Licensee response.,
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"(1) Q The actuation of the containment sprays associated with the pressure spike.
A It is reasonable to assume that I was told of spray v
initistion in the course of discussions of the pres-sure spike to support the conclusion that it was real. -This would have been March 30, 1979 at the earliest.
However, I do not now recall any specific discusison of spray initiation prior to J.
Floyd's description during the congressional tour on May 7, 1979,'although I am aware now that both the G. Miller reconstruction and individual GPU interviews to which I had access in April contain references to the spray initiation.
"(m) Q Any instructions by Mr. Miller or other GrU personnel not to activate any equipment in the reactor building because:it might cause a spark and/or a hydrogen ex-plosion.
A.
After identification of hydrogen as the cause of the pressure spike and with recognition that the effort to remove the remaining hydrogen from the primary coolant system and continuing-radiolytic decomposi-
-tion'Nf water were adding hydrogen to the containment
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building, there was concern about the possibility of further hydrogen combustion.
I had no knowlege of imitations on equipment operation in containment on March 28 or 29 but do not recall when or if I might t G
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o have subsequently been informed of such possible lim-itations.
My awareness of possible limitations on
.the, operation of equipment on the day of the accident W
Eap'-hsve come from NUREG-0600 in August, 1979, or from the Rogovin SIG Report and the subsequent Rogovin/Frampton Memorandum of March 4, 1980 to the NRC.
Supp. Response to Interrogntory No. 17 Mr. Dieckamp'did not know at or around 8:00 a.m.
on March 28, 1979, that the.POEV had been open from about 4:00 a.m.
to about 6:20 a.m.
Supp. Response to Interrogatory No. 18 Mr. Dieckamp did not have knowledge or information around 8:00 a.m.
on March'28, 1979, that the HPI had been throttled
-during the time the PORV had been leaking.
Supp. Response to Interrogatory No. 19 Mr. Dieckamp did not have knowledge or information around 8:00 a.m.'on March-28, 1979, that hot leg temperatures in ex-t
~
cess of 700 degrees had existed on that' day..
F
3 Supp. Response to Interrogatory No. 20 Mr. Dieckamp did not have knowledge or information on March 28,-il,9,797,that temperatures in excess of the saturation temperature indicated that the core had been cooled by steam rather than water.
Supp. Response to Interrogatory No. 21 Mr. Dieckamp did not have information on the morning of March.28, 1979 that the core was not being adequately cooled.
Supp. Response to Interrogatory No. 22 Mr. Dieckamp did not-have :nowledge or information around 8:00 a.m. on March 28, 1979, that the TMI-2 reactor was in a condition not covered by emergency procedures.
'Supp. Response to Interrogatory No. 28 Mr. Dieckamp did not instruct emergency team personnel to cease the depressurization strategy and begin a repressuriza-tion strategy.
Supp. response to Interrogatory No. 34 See Licensee's September 4, 1984 Response.
Mr. Dieckamp does not recall detailed discussion of plant parameters or con-
-ditions.,
- g.
Supp.' Response to Interrogatory No. 39 P
Licensee's' supplemental response to this interrogatory willbeprovi,fedwithin'thenextfewdays.
Supp. Response'to Interrogatory No. 48
. Licensee's September 4, 1984. response is complete and re-quires no supplementation.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE
% 4.4644 Ernest L.
- Blake, Jr.,'P.C.
Da' rid R.
Lewis 18s:0 M Street, N.W.
Wasnington, D.C.
20036 (202) 822-1000 Counsel for Licensee Y
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.EELATED CC:IgEs?OpD_,Bi@
00CHETED September 11, 1984 USHRC 84 EP 13 P1 :43
. UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION jg g,q
- CC5Eiih6 & Siin'a BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In.the Matter of
)
)
. METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
).
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station,. Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Supplemental.
Response to.Three Mile Island Alert's First Set'of Interroga-tories and First Request for Production" were served this lith day of-September, 1984, by hand delivery to the parties identified with an asterisk and by deposit in the U.S. mail, first class,-postage prepaid, to the other parties on the attached Service List.
IM[
Ernest L.
Blake, Jr.,
P.C.
A 3
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rs
' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION p;
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
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-)
(Restart Remand on Management)
(Three Mile Island Nuclear
)
Station, Unit No..1)
)
SERVICE LIST
_Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission-John H.
Buck Washington, D.C.
20555-Atomic Safety & Licensing Appeal Board Thomas M.
Roberts, Commissioner U.S. Nuclear Regulatory Commissiom U.S. Nuclear-Regulatory Commission-Washington, D.C.
.20555
' Washington, D.C.
20555 Administrative Judge James K. Asselstine, Commissioner Christine N. Kohl U.S. Nuclear Regulatory. Commission Atomic Safety & Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commission Frederick Bernthal, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington,-D.C.
20555 Administrative Judge Ivan. W.
Smith, Chairman Lando W.-Zecyf Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commissior U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
-20555 b
.e.
Administrative Judge Mr. Henry O. Hukill Gustave A. Linenberger, Jr.
Vice President Atomic Safety.& Licensing Board GPU Nuclear Corporation U.S. Nuclear. Regulatory Commission P.O. Box 480 Washington, 4L. C.
20555 Middletown, PA 17057 a-@
Docketing ahd Service Section (3)
Mr. and Mrs. Norman Aamodt Office of the Secretary R.D.
5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C.
20555 Ms. Louise Bradford Atomic Safety'& Licensing Board TMI ALERT
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Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C.
20555
- Joanne Doroshow,. Esquire Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel
'1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C.
20002 Washington, D.C.
20555
- Lynne Bernabei, Esq.
G vernment Accountability Jack R.
Goldberg, Esq. (4)
Office of the Executive Legal 15 5 C nnecticut Avenue Washington, D.C.
20036 U.S N c ear Regulator:/ Commission Washington, D.C.
2055i Ellyn R. Weiss, Esq.
Harmon, Weiss & Jordan Thomas Y.
Au, Esq.
2001 S Street, N.W.,
Suite 430 Office of Chief Counsel Washington, D.C.
20009 Department of Environmental
- Resource s Michael F.
McBride, Esq.
505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W.
Harrisburg, PA 17120 Suite 1100 20036 Washington, D.C.
Michael W.
Maupin, Esq.
Hunton & Williams 707 East Main Street P.O.
Box 1535 Richmond, VA 23212 gg l
O 4