Text

Proposed Findings of Fact & Conclusions of Law on Dieckamp Mailgram Issue Re Mgt Phase.Certificate of Svc Encl
	ML20106D126
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Site:	Crane
Issue date:	02/08/1985
From:	Bernabei L, Doroshow J; CHRISTIC INSTITUTE, GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
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February 8, 1985 1

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'65 FE311 AIO :21 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION kN....k.3,, gy:

S:(4.cH Before the Atomic Safety and Licensing Board t

In'the Matter of

)

METROPOLITAN EDISON COMPANY

)

Docket No. 50-289 SP

)

~(Three Mile Island Nuclear

)

(Restart - Management)

Station, Unit No. 1)

)

mU THREE MILE ISLAND ALERT'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON DIECKAMP MAILGRAM' ISSUE h213OO108

' O~

ADOCK O M h r

PDR

TABLE OF CONTENTS I..

INTacDucTIoN

....................................... 1 II.

Is the Dieckamp Mailgram False or Inaccurate............

7 i

A.

Control room operators and management understood the significance of the s occurred................. pike at the time it

............... 7 1.

General awareness of pressure spike and related events by TMI personnel.................

9 2.

Interpretation of the spike by Jose Chwastyk and Brian Mehler..........ph

.............ll 3.

Interpretation of-the spike b and John Herbein.............y Gary Miller

.............. 27 4.

The pressure spike and hydrogen burn were common knowledge _amon March 28.............g site personnel on

.............. 39 5.

Awareness of'GPUSC engineers of. pressure spike

(]}

and hydrogen on March 28 and 29, 1979..........

52 n

.B.

Conclusion concerning false statements in the 4

"Dieckamp Mailgram"..............,.................. 62 III.

Dieckamp Knew at the Time He Sent-the Mailgram on May 9, 1979 that the Mailgram Was Inaccurate and Contained Material False Statements..............................

64 A.

The purpose of the mailgram........................

64-B.

Dieckamp's knowledge of the interpretation'of the pressure spike by plant and corporate staff.... 66 1.

Miller-Herbein' discussions with Dieckamp....... 66 C.

Broughton-Keaten communication with Dieckamp....... 76 1.

Broughton reported to Keaten...................

77 A

2.

Keaten reported to Dieckamp....................

81 3.

Dieckamp's awareness of core damage on March 28 and March 29, 1979 demonstrates his awareness

{J of'the hydrogen burn...........................

82 D.

Conclusion.........................................

86

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.IV.

Assuming that Dieckamp Did Not Know the Statements in His Mailgram Were False at the Time He Sent the Mail-gram He Should Have Known They Were False..............

87

~A.

Dieckamp's unduly restrictive definition of the 4

issue before this board............................

88 B.'

A' complex technical analysis is needed to determine the pressure spike.was caused by a hydrogen burn......................................

90

+

C.

Dieckamp's analysis of Chwastyk, Mehler 'and Illjes' interviews.........................................

93 D.

The IE investigation and report on information flow during the TMI-2 accident.....................

98

(

E.

Lowe's alleged discovery of the significance of the pressure spike late on March 29, 1979.............

103 F.

Information available to Dieckamp prior-to May 9, 1979..............................................

109 G.

Conclusion........................................

110 V.

Dieckamp Should Have Corrected the Mailgram Once He Determined :that' Statements in the Mailgram Were False.110 VI.

Conclusion............................................

112 Appendix A:

Acceptance Criteria for Emergency

~

Core Cooling Systems for Light Water Nuclear Power Reactors (Fed. Reg.)

SUPPLEMENT TO-LICENSEE'S APPENDIX B:.

List of Exhibits SUPPLEMENT TO LICENSEE'S APPENDIX C:

TMIA Adopts Licensee's Appendix C and Supplements

'Ihfl A 2 /8 /83 UNITED STATES OF AMERICA NUCLEAR REGULATORY 00hMISSION Before the Atomic S_afety and Licensing Board In the Matter of

)

METROPOLITAN EDISION COMPANY

)

Docket No. 50-289

)

(Restart-Management (Three Mile Island Nuclear

)

Phase)

Station, Unit 1)

)

THREE MILE ISLAND ALERT'S PROPOSED (d

FIRDTRDS DF FXDI' AND CDRCEDST5RE 5F LAW C

_DR DTECRIMP MXIECRXW TENDE --

I _ INTRODUCTION l

l '.

At the_ time of the Unit 2-accident on March 28, 1979, TMI Unit I had been shut down for refueling.

On July 2,

1979, the' Commission directed that TMI-1 be maintained in a shutdown condition, and determined that the public interest would best be

' served if hearings preceded any restart of TMI-1.

The Commission L

-based its actions on a conclusion that Illn view of the variety of issues raised by the accident at the Three Mile Island Unit No. 2 facility, the Commission presently lacks the requisite reasonable assurance tha't the same licensee's Three Mile Island

Unit No. I facility, o nuclear power reactor of similar

. design, can be operated without endangering the health and safety of the public.

(

)

This Licensing Board was established to hold hearings on TMI-l's restart by the Commission Order and Notice of Hearing dated August 9, 1979, Metropolitan Edison Comgany (Three Mile Island Nuclear Station Unit No. 1), CLI-79-8, 10 NRC 141 (1981).

2.

" Managerial capability and resources" was explicitly 1

identified as an unresolved issue by the Commission in its August 9 Order, 10 NRC 141 at 144-145 (1979).

The Commission's Order of March 6,-1980, CLI-80-5, 11 NRC 408 further delineated certain

" management issues" which it deemed pertinent to a study of a

management capability.

Among these issues are:

(10) whether the actions of Metropoli tan Edison's cor-porate or plant management (or any part or individual member thereof) in connection with the accident at Unit 2 reveal deficiencies in the corporate or plant manage-i ment that must be corrected before Unit I can be

( ("N operated safely.

l L) 3.

This Boardl presided over hearings concerning issues raised by Board Issue 10, as well as all other issues directed

_ for review by the Commission in its Augus t 9 and March 6 Order, l

1980, resulting in an August 27, 1981 " Partial Initial Decision (Procedural Background and Management Issues)," 14 NRC 281 (1981). ("PID"),

4.

In resolving Board Issue 10, we focused our inquiry In determining whether any particular actions on the part of Licensee reflected positively or negatively I The original Licensing Board members included Dr. Walter H.

e Jordan and Dr. Linda W. Little.

These members were replaced by current Board members Sheldon J. Wolfe, Esq., and Dr. Gustave A.

l Linenberger, Jr.

Ivan W. Smith, Esq. has served as Board l

Chairman since the formation of the original Licensing Board.

O I

2 l

l

on Licensee's management competence, and whether any of the witnesses considered there to be more subtle f actors, such as management at titude, which were deficient in Licensee's management during the events qf(])~

following the accident.

Included in this latter inquiry was our interest in Licensee's responses to external stimull, such as the Staf f's inspections, as well as Licensee's internal reactions to the THI-2 accident, such as whether Licensee evaluated and, if so, in what manner, the performance of individuals in the company during the accident.

PID, Paragraph 463.

5.

We devoted particular attention to the issue of informa-tion flow during the accident.

We considered cruelal to a full examination of the issue the management implications of a mailgram sent by GPU President Herman Dieckamp, to Congressman Morris K. Udall, Chairman of the House Committee on Interior and Insular Af fairs which has NRC oversight jurisdiction, on May 9, 1979, with copies to at least two NRC Commissioners.

See, Joint

(( )

Mallgram Exhibit 1-C Item (142)2, Appendix B, at 117-1-to 117-2; JME 29 at 190-191.

The' central question was whether Dieckamp j

Ldeliberately or negligently made false and inaccurate statements in the mailgram.

I 6.

The mallgram stated, in pertinent part,

.There is no evidence that anyone interpreted the pressure spike and the spray initiation in terms of reactor core damage at the time of the spike nor that 1:

anyone withheld any information.

Ibid _.

2 Joint Mallgram Exhibit 1 includes-Part A, the Joint Mailgram Stipulation to which Licensee,~Three M:lle Island Alert and the c

NRC Staff stipulated; Part B which is an index of all exhibits t

contained in this appendix; and Part C-which contains 144

~

separate exhibits or-items. 'These exhibits will be cited as JME 1-C(l), 1-C(2),.etc.

i

}

3-i

7.

In cur August 1981 PID, as reachsd on overoll eenelusion resolving all "information flow" questions, including the imp 11-

{

cations of the "Dieckamp Mailgram", favorable to the Licensee.

PID at paragraph 506.

8.

Intervenor Three Mile Alert ("TMIA") appealed our con-clusions on, inter alia, Board Issue 10.

On May 24, 1984, the Appeal Board issued a decision which, inter alia, agreed wi th TMIA that this Board had not adequately developed a record on either the overall question of information flow, or on the specific issue of the "Dieckamp Mailgram," ALAB-772, slip op. at pp. 121-134, ultimately finding the record incomplete on both the competence and integrity of current Licensee management.

ALAB-772 at 158.3 9.

The Appeal Board determined that to properly resolve the mangement issues directed for consideration by the Commission, (O

further deveiopment of the record on tne "Di ekamp Mailgram" issue was necessary due to the f act that Mr. Dieckamp was and continues to play a critical role in managing the affairs of Licensee.

The Appeal Board noted,

...Dieckamp is still a high level " presence" at GPU Nuclear.

Although he was recently replaced as Chairman and Chief Executive Officer of GPUN, he remains a Director there and thus will continue to participate in the management of GPUN, albeit to a far lesser extent.

Notice to t he Commi s s i on, ' e t al. (February 6, 1984).

It is not unreasonable to expect that, as a former i

Chairman and CEO, Dieckamp will have a more commanding voice in directing the af fairs of GPUN than many of his 3 The Appeal Board chose not to remand on the broader issue of reporting failures only because two principal figures, Gary Miller and John Herbeln, had lef t Licensee's organization to take positions in GPU's non-nuclear operations.

Sen gener,all_y, ALAB-772 at 121-127.

O 4

e

fellow members of the Board.

Moreover, he sent the mallgram to Congressman Udall in his capacity as President of the parent firm, GPU -- a position he still holds (along with Chief Operating Officer and

(

Director).

ALAB-772 at 133.

Thus, our direction from the Appeal Board was to consider the -implications of Mr. Dieckamp's actions in terms of the influence he har in the overall management of the corporation.

10.

The Appeal Board agreed with our initial determination that the "Dieckamp Mailgram" issue is important to an overall evaluation of management competence and intergrity.

In addition, we believe that Licensee's current position that Mr. Dieckamp's mailgram is correct and accurate and that Mr. Dieckamp had no duty at any time to correct it are additional reflections on the integrity of GPUN's current management.

Seh generalth Licensee's Proposed Findings of Fact and Conclusions of Law in the Form of a Partial Ini tial Decision on the Dieckamp Mailgram Issue.

11.

The Appeal Board directed us to focus on the following two issues:

])

whether anyone interpreted,the presure spike and containment spray, at the time, in terms of core damage; and

2) the sources of the information which Mr. Dieckamp conveyed in his mailgram.

12.

In a July 9, 1984 Prehearing Conference Order, we elaborated on the scope of this issue.

We rephrased the issue to whether, Mr. Dieckamp's mailgram was false or inaccurate; whether he knew or should have known at the time he sent it that it was f alse or inaccurate; whether he expected the mallgram to be O

5

relied upon in the regulatory process; and whether he had any duty to correct the mailgram upon learning of its misstatements.

Memorandum and Order Following Prehearing Conference (July 9, 4(O 19.c at..

i

13. TMIA was the lead intervenor on the remanded issue of the Dieckamp Mailgram.

Also participating in the remanded proceeding were the licensee, the NRC S taf f and the Commonweal th 4-j of Pennsylvania.

14.

The hearings on this issue were held on 17 days from November 14, 1984 through December 14, 1984 and on January 9, 1985. Twenty-four witnesses testfied. The parties stipulated into evidence 144 prior interviews, depositions and portions or com-plete reports as Joint Mailgram Exhibit 1 -C.

See, note 2, supra.

4 1

1 l

l l

'O 6

l

s II IS 'lilE D_IECKAMP MAILGRAM FALSE O__R INAOCURATE?

A. Control Room Operators and Management Understood the

$lgnRTeance of the Splice at the Tidie It Occurred 15.

As we explained in our earlier decision, The pressure spike referred to lin the mailgram] was a sudden increase in containment pressure from about 3 to 28 psig, followed by a rapid decrease to 4 psig, at c bou t 1:5 0 p.m. on Ma rch 28, 1979.

It was caused by a sudden burning or explosion of hydrogen, which would be symptomatic of core damage.

PID paragraph 499.

16.

The Board first examined the question whether at or near the time of the pressure spike, which was reflected on pressure records in the control room, anyone understood that it was caused by a combus tion or burn of hydrogen produced as a product of a zirconium-steam or zirconium-water reaction.

This reaction occurs only at temperatures greater than 2000 degrees F when the zirconium cladding and other elements react with steam to produce hydrogen and zirconium oxide.

The reaction is an authocatalytic exothermic zirealloy-steam reaction.

Stigulation of Parties on Mailgram Evidence, JME l-A.

17.

The pressure spike occurred about 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after the trip of the reactor at 4:00 a.m.

This pressure spike actuated containment building sprays, which operate under a logic of actuation only when two of three independent sensors detect high pressure.

JME l-C (142) at 22.

Coincident with these events, some individuals in the Unit 2 control room at the time of the spike heard a loud thud or noise.

See e.g., JME l-C (12 2 ) a t 1

112.

One person in the control room described it as " shock waves."

JME l-C (8) at 5.

Additionally, an ES or Engineering 7

Sofoguards signal cas receivod at that tima cnd many visual and some audio alarms were actuated.

See g, Tr. 29,476 (Mehler);

2 JME l-C (142) at 22; (143) at 54.

(n

'v 18.

At the time of the spike's occurence, operating person-nel were also aware of incore temperatures in the range of 2500 degrees F, which indicated that ECCS criteria had been exceeded and that temperatures had reached the point where the zirconium cladding was reacting with steam to produce significanet amounts of hydrogen.

Sti2ulation of Parties on Mailgrarn Evidence. JME 1-A; S_ee eA JME l-C (67) at 39.

Expert witnesses testified 2

that flammable hydrogen is reached when hydrogen reaches a volume of four percent of the total containment building, and that the only method by which this amount of hydrogen could be produced within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months of the accident's initiation is through a zir-conium-s team reaction.

Tr. 28,200 (Lowe); Tr. 28,200 (Linen-(

berger/Lowe); Zebroski, f f. Tr. 28,441 at 7; Tr. 28,530 (Zebroski).

S ee a l s_o, JME 1-C (6) a t 195.

19.

The Board finds that the operators awareness of these temperatures led them to an analysis of the condition of the reactor as one in which hydrogen could be produced up to and beyond flammable limits.

Therefore, we believe that TMI-2 opera-tional staf f's awareness of incore temperatures beyond 22,00 degrees aided them in analyzing the pressure spike correctly as a hydrogen burn or explosion at the time it occurred.4 S,e e2 a l s_o, JME 1-C (4 ) a t 5 9 -6 8, 7 3 -7 4, 13 0.

4 The ignition of the hydrogen is more correctly termed a rapid burn than an explosion.

'O 8

i l

20.

In sum, tho Board finds thct ocntrol rcem cporotors and i

management not only understood the significance of the pressure 4

(

spike at the time it occurred, but as a result of their analysis I

of the pressure spike, changed the mode they had been using to e,oo l the reactor.

Although no one at the time was able to F

develop a complex analysis of the degree of core damage demon-strated by the spike or hydrogen burn, it is clear that operating personnel viewed the spike as an indication that their efforts to cool the reactor had been hindered and were unsue-l cessful.

1. Ge_n_e r a l Awa r e_n_e_s_s _o_f _P_r_e_s_s_u_r_e _S@ _a_n_d _R_e_l _a_t _e_d _E_v_e_n_t _s _by g, gg 21.

The following individuals in or near the TM1-2 control room at the time of the spike, or in communication with those on-I i.

site, testified in early interviews of an awareness of the pres-(

sure spike, the thud or explosive sound caused by the hydrogen burn, the actuation of the containment sprays or the receipt of an ES signal: John Flint, at JME-1-C (11) at 7; JME-1-C (109) a t 1

39-40; Craig Faust, JME l-C (2) at 11; Ed Frederick, JME l-C (71) a t 10-11; JME l-C (112) a t 2-5; Joe Logan, JME l-C (136) a t 53-i 54; Fred Schelmann, JME l-C (134) at 4; NRC Inspector J. Higgins,

'JME l-C (19) at 24; JME l-C (129) at 25-26; Adam Miller, (137) at 4; Gary Miller, JME l-C (23) at 20, 26; JME l-C (83) at 31-32; JME l-C (85) at 25-26; JME l-C (93) at 28-29; JME l-C (122) a t 112, 114-115, 117-118, 125-127; JME l-C (138) at 100-104.

Michael Ross, JME l-C -(33) at 3-4; JME l-C (124) at 5; JME l-C (81) a t 42, '43; JME l-C (124) a t 54, 56-57; George Kunder JME l-C (37) at $1-52; JME l-C (72) at 27; Michael Benson, JME l-C (126)

O 1

9 i

t

, - - -,.., ~ -,,

-,,_.,___._._m__

,,m,__,___.,.w__.

_,,___,._,_.._,__.__,...,,.4.,..~...,,_,_,,,_,,.,,.,.,,.,.,

at 4-11; Donald Berry, JME l-C (13) at 17; (JME l-C (114); JME l-C (113) at 6-9; Lynn Wright, JME l-C (24) at 25-26; JME l-C (116) h at 4-7, 11, 20; Lee Rogers, JME l-C (100) at 49-51; Walter Mar-shall, JME l-C (92) at 11-13; JME l-C (31) at 17, 23-25; Hugh McGovern, JME 1-C (111) at 3-4.

See also, JME 114; JME l-C (5) at 143-145, 193-194; JME l-C (143) at 54-92; JME 1-C (10 8) a t 138-139; JME l-C (107) at 48, 66.

22.

Those coming on shift later in the day after the spike also recall learning about it that day.

S_ e e, e A Ted Illjes, JME 1-C (36) at 2-7; Charles Mell, JME l-C (60) at 6-7.

23.

In addition,.the following individuals answered "Yes" to a question on a questionnaire distributed to present and past GPU System and B&W employees during discovery in this proceeding, whleh asked whether on March 28, they were aware 'or informed of lj the pressure spike, the " thud" or noise indleating the hydrogen

'(V burn: Donald A. Berry, Guilford E. Stambaugh, Jr., George T.

Steuerwald, William H. Zewe, Daryl L. Wilt, G.M. Olds, Mark S.

1-Coleman, Michael S. Richards, Howard C. Crawford, Beverly A.

Good, Charles E. Rippon, Dale J. Laudermilch, Michael L. Kuhns, i

l' Walter J. Marshall, Brian A. Mehler, Adam W. Miller, M.J. Ross, f

George K. Wandling, Dani.el M. Shovlin, J.B. Logan. TMI A Ex. 3 2 A.*

l 24.

There is also evidence that knowledge of the spike may have reached corporate headquarters in Parsipanny, New Jersey on March 28, although the individual who has so testified attempts

[

In the same interview to deny knowledge.

Cronenberger, JME 41, at 12-13.

l 25.

The Board finds that the pressure spike and associated

O eveat were reaerei kaowieone et the ite oa Meren is.

i i

10

4.

2. Inter 2retation of the Pressure Spike b_y Joseph Chwestyk a,nd_ lirlan Mehler.

26.

~(O There is considerable evidence that eore uncovery and significant eore damage was a major concern during the early hours of the accident.5 This concern was evident early on March 28, providing the context within which to evaluate whether key per-sonnel understood the significance of the pressure spike at the 5

The-following individuals have testified in early interviews that core uncovery and significant core damage was recognized

-early in the accident, including the day of March 28:

B&W representatives John Flint, JME l-C (11) at 7 JME l-C (14) at 29, 33, JME l-C (56) a t 24-25, JME 1-C (55) a t 21-25, 27-2 8; and Lee Rogers, JME l-C (87) at 35-38, JME l-C (100) at 12-17, 35-37 Wi11 lam Marshal 1, JME l-C (92) at 13-14;

NRC Inspectors

.Higgins, JME l-C (79) at 44; and Karl Plumlee, JME 1-C (140) at 142; Instrument Technician Nelson Bennett, JME 1 -C (53) a t 13, 17-18; Operator Ed Frederick, JME l-C (71) at 14-15; George Kunder, JME l-C (18) a t 29, 45, JME l-C (3 7) a t 5 2-5 3, JME 1-C (72) at 17-18, JME l-C (80) at 59, JME l-C (118) at 45-46 Gary Miller, JME l-C (10) at 17, JME l-C (23) at 22, 23 (Tapes 159 and

'160) at 60, JME l-C (83) at 17-20, 25, JME l-C (93) a t 11-12, JME (O

a t 28, JME l-C (61) a t 16, 21-23, 25;,l C (122) at 144, JME l-C (138) at 97; Jo Mike Ross, JME l-C (81) at 18, 28, 44, JME l-C (124) at 9,14-16; Gary Broughton, JME l-C (48) a t 6; Rober t Arnold, JME 1-C (26) at 19-20, 25 JME l-C (84) at 21, 14-15, 17, 46, JME l-C (.21) at 4-5 Herman Dieckamp, JME l-C (66) a t 129, JME 1-C (86) a t 4, 7-9, 18, 21: JME 1-C (123) a t 9-10. See a l s o JME l-C (5) a t 4-6, 8,12-13,114,14 0, 157, 185,

'189,1H, Jhis,1-C (6) a t 299, 30 6-3 0 7 ; JME l-C (14 3) a t 3 5-5 4, 95-96, 117-118 JME l-C (100) at 116.

In particular, in-core temperatures were considered accurate, and believed to be an indleator of core temperatures and possible core uncovery on March 28.

See Miller, JME 1-C (2 3 ) (Tape s 15 9 a nd 16 0 ) a t 5 5-5 6 ; JME l ~G,8 5 ) a t 2 5, 3 2, 3 4-3 7, JME l-C (122) a t 673 Filn t,- JME I-C ( 11) a t 10, JME l-C (14) a t 4-.8, 19-20, 25 JME l-C (56) a t 2-3, 25-27, 33-40, JME l-C (55) at 20-21, JME l-C (109) at 4-10, 16-17, 21-32 Zewe, JME l-C (119) at 33; Instrumentman Tom Wright, JME 1-C (5 2) a t 11-14; Instrumentman William Yeager, JME l-C (54) at 17-19 Ins trumentman Gilbert JME l-C (91) at 12, JME l-C (112) at 5, 28, 29.

See also, JME l-C (5) at 12-14,186; JME l-C (6) at 185; JME l-C (I U)~ R ~17, 22-38, 94-95.

The concern over core damage and high in-core temperatures also reached corporate headquarters in Parsipanny.

See Crei tz, JME l-C (94) at 6; Hilbish, JME 1-C (7 4 ) a t 3 7 -3 8.Te~e, Paragraphs 87 to 95 Infra for a more detailed O

discussion of We, accuracy of in-core tTGTin,ocouple temperature reedians.

11 4

time of the event in terms of core damage.

27.

Brian Mehler, a shift supervisor at Unit 2, arrived in

(( )

the Uni t 2 Cont rol Room at about 6:00 a.m. on March 28.

Tr.

29,428-29,429 (Mehler).

He testified that he concluded in the morning period that there had been some core damage.

Tr. 29,430 (Mehler).

In testimony to the Hart Committee investigating the accident Mehler stated that after radiation alarms were received during the morning of March 28 he determined that there was " fuel damage" and that perhaps one-third of the core had been uncovered. JME l-C (68) at 7; Tr. 29,431-432 (Mehler).

28.

Joseph Chwastyk, a shift supervisor in Units 1 and 2, i

started work around noon on March 28, 1979.

Tr. 29,108; Tr. 29, 110. (Chwastyk).

On that day he supervised operators Theodore Illjes, Joseph Kidwell, and Charles Mell.

Tr. 29,109 (Chwas tyk).

Chwastyk testified that shortly after his arrival at work he (O

recalls being bricted on specific temperatures, pressures, and radiation levels.

Tr. 29,112. (Chwastyk).

He recalls also that upon his arrival at Unit 2 the hot-leg temperatures were pegged at 720 degrees.

Tr. 29,112-113, 29,114 (Chwastyk). He testified that he discussed the possibility of core damage with other operational personnel near the time of his arrival and that based on the information available to him at that time he concluded that Unit 2 had suffered some core damage.

Tr. 29,113 (Chwastyk).

He based his conclusion on the hot-leg temperatures and the radiation release which he characterized as " pretty significant".

Tr. 29,113, 29,190 (Chwa s t yk).

29.

Chwastyk relieved William Zewe, a third shift super-

-()

visor, at the console after his briefing on the status of TMI-2.

12

Tr. 29,114 (Chwa s t yk).

He basically directed operations and reported directly to Station Manager and Emergency Director Gary Miller. Tr. 29,118 (Chwastyk).

Chwastyk stated that he stationed himself in front of the consoles and within the area labeled

" operators base line" in l i cens ee's figure of the control room.

Tr. 29,116-118 (Chwastyk); Lic. Mailgram Exh. I at 1.

He situ-a ted himself in the Control Room, and f rom that vantage point, he could easily see the reactor building wide-range and narrow-range pressure recorder strip chart. Tr. 29,124 (Chwastyk).

30.

Mehler was located in the same area at the time of the pressure spike at 1:50 p.m.

Tr. 29,476-79 (Mehler). He testified that the Shif t Supervisors' of fice, where Miller is said to have been, was located about 35 to 40 feet f rom the panels in the control room but easily within hearing distance of the alarms (O

C' received at the time of the spike.

Tr. 29,477-478 (Mehler).

31.

Chwastyk stated that since he was standing near the console he saw the pressure recorder move " straight up" and then fall rapidly. Tr. 29,124 (Chwastyk).

He testified that he as-sumed the alarms which were actuated at the time of the spike caused him to look at the console.

Chwastyk said it took only "a couple of heartbeats" for the spike to rise and fall.

Tr. at 29,124-29,125 (Chwastyk).

32.

Mehler testified that he became aware of the pressure spike when the alarms were actuated, and an ES signal was received. He s ta ted that Ross and an NRC inspector in the control room were aware of the ES signal.

He testified further that operators, 1

including Lynne Wright, were securing equipment.

He saw the 13 1

f I

reactor building pressure recorder jump, and he then became aware of I

the actuation of the containment sprays.

Tr. 29,476-479 (Mehler).

(O 33.

Marshail testiried that he was aware of the pressure spike, the alarms and the actuation of the containment sprays.

Walter Marshall, JME l-C (92) at 11-13; JME l-C (31) at 17, 23-

)

25.

He testified in a more recent deposition taken in the course

.of discovery in this proceeding that he believed Miller was in i

the contrcl room at the time of the spike and aware of the thud or explosive sound caused by the hydrogen burn from remarks made

{

by Miller at the time.

Furthermore, he stated that he believed

. Miller was aware of the actuation of the containment sprays from his position in the back of the console at the time of the spike and actuation of the sprays.

TMIA Exh. 32G at 1, 4-5 34.

! (O McGovern in an interview with Marshall at about 3:00 t

a.m. on Ma rch 29 told Marshall that at 2:00 p.m.

the following l

occurred:

...an RX building pressure spike that went off scale on narrow range meter -- definite spike straight up, straight back down -- had full RX building (Spray pumps

&BX-VPS,DH-V8 's ) isolation and cooling.

Someone secured spray pumps, shut BS-VI's and DH-V's (Hugh did) and

[-

unisolated equipment for building.

JME l-C (1).

i 35.

Other pressure indicators, including the steam genera-tor pressures and the reactor coolant system pressures indicated a coincident spike downward at the time of the pressure pulse.

j JME 1-C (143) a t 56; JME l-C (63) a t Appendix TH.

j

36. Chwastyk said that at the time of the spike he saw the containment sprays become energized and begin spraying sodium i

14

-. ~. _.. _. _ _ _ ~.. _ _. _ _,. _ _ _ _. _. _ _ _ -._.._.. _ _.

hydrcxide in the reactor building.

H2 said he m2da the assump-tion that everybody in the control room was aware of the spike (Q

simply because it was a " major variance" from what had been taking place previously. Tr. 29,126 (Chwastyk).

Mehler agreed that everyone in the control room knew about the sprays and c.

believed that Miller knew about the spike as well.

Tr. 29,482-i 483 (Mehler); JME l -C (8 9 ) a t 2 9.

He stated that both he and Chwastyk were " highly concerned and a little scared" by the high pressure.

JME l-C (98) at 11. Tr. 29,484 (Mehler).. Chwas tyk has s ta ted, "i t scared the hell ou t of me."

JME l-C (99) a t 20-21.

37.

Chwastyk and Mehler discussed the fact that actuation of the containmnet sprays indicated that the pressure spike was a real pressure excursion since at least two out of three indepen-dent sensors needed to record pressure to 28 psi to activate the sp: ays.

Tr. 29,103 (Chwas tyk); 29,480, 29,487 (Mehler).

('

Chwastyk testified that his conversation with Mehler further convinced him that the spike was real.

Tr. 29,317 (Chwastyk).

38.

Chwastyk also immediately sent someone back to inform Gary Miller that they had "some sort of problem."

Tr. 29,131 (Chwastyk).

39.

Chwastyk then directed the operators to' secure the containment sprays after the pressure dropped.

Tr. 29,127, 29,227-228 (Chwastyk).

See_, JME l-C (32) at 30; JME l-C (35) at 9,

10; JYE l-C (117) a t 9-10.

He also ordered certain checks be made to verify containment integrity and to determine other parameters.

Tr. 29,127-128 (Chwas tyk); JME l-C (117) at 32-36.

Mehler confirmed that an order was given to check to determine if

]

the containment was breached by the pressure spike. Tr. 29,486 15

.u (Mehler).

c. Conclusion

167.

The Board concludes that the group of GPUSC engineers sent to the site early on March 28 in order to analyze the accident and provide technical support learned of the explosion in the reactor building sometime during the evening of March 28 or early morning of March 29, and interpreted it to indicate the release of hydrogen or noncondensible gas into the primary reac-tor coolant system.

This supports our finding that the hydrogen burn was common knowledge at the TMI site on March 28, and was

(

interpreted to signify core damage at the time it occurred.

B. Conclusion Concerning False Statements in the EDieckamp Mill 1gg m"

~~~~~~~ -- ~~-

168.

It is clear that the significance of the pressure spike was understood at the time of its occurrence on the afternoon of March 28.

GPUSC engineer Gary Broughton stated that operators coming off-site for debriefings in the Observation Center 18 spoke of the hydrogen explosion.

JME l-C (48) at 19.

Similarly, Shift Supervisor Zewe testified that hydrogen was discussed as the cause of the spike by early morning, March 29 -- significantly before the Licensee-acknowledges such recognition.

JME l-C (119) 18 The operator debriefings are explained at JME l-C (49) at 5;

\\-

JME l-C (31) at 4; JME l-C (48) at 11; JME l-C (121) at 46.

62

a t 42-43; JME l-C (4) a t 59-6 8, 73-74,130; JME l-C (5) a t 6-9, 7 3,14 7,19 4-19 5 ; JME l-C (14 3 ) a t 1-2, 5 4-9 2, 9 6-9 7.

10 169.

We find that both the site operations personnel oper-ating TMI-2 on March 28, licensee personnel generally present at TMI-2 on March 28, GPU Service Corporation managers in Parsip-pany, and those sent to the site to analyze the accident, inter-preted the pressure spike which occurred in the TMI-2 containment building at 1:50 p.m. to indicate a hydrogen burn, and some core damage.

Therefore, we find that Dieckamp's mailgram, which con-tains the statement that no one interprreted the pressure spike or containment sprays in terms of core damage, is inaccurate and false.

170.

We also conclude that Dieckamp's statement that no one withheld any information concerning these events, is inaccurate f O aa r > =e-

nc orriei i t nac ne a9uerter ia

aiastoa aa in Bethesda did not become aware of the hydrogen detonation until March 30. JME l-C (4) a t 60-61.

Commonwealth of Pennsylvania officials, including Lieutenant Governor William Scranton, J r.,

who were briefed in Harrisburg one hour after the detonation, were not informed of the hydrogen burn until March 30. JME-1 C (143) at 57; JME 1-C (142) at 44.I9 Thus, we find the mallgram to contain significant, false information.

19 The significance of this withholding of information can not be I

overstated.

Both Commisioners and the NRC Staf f manning the Emergency Response Center indicated that they would have ordered an evacuation if they had been informed of the hydrogen burn at the time it occurred.

JME l-C (4) at 110.

On the basis of less serious indications about the reactor's s tatus, the Commission did move to recommend a precautionary evacuation on March 30. JME O

(l-C (4) a t 68-70, 82-8 4,110; JME 1-C (143) at I n.2 ; JME l-C

> a')

t 5 5-5 8-63

_.- _ __- -. _._ _.,-- ~ _ _ _ __- _ _ _ _ _.._._._ _-_

III DIECKAMP KNEW AT THE TIME HE SENT THE MAILGRAM ON MAY 9 ~I979 THXT THE MAILGEXM WA$ INXCCUEXiE AND-D5NTXiNEDNATERTAEFAENENTXTENENTE.

A.

The Pur_ pose of the Mailgram 171.- On May 7, 1979, a congressional delegation visited TMI-2..In the course of this site visit, James Floyd, Supervisor of Operat ions.for Uni t 2, pointed out to members of the delega-tion, which-included members of Congress, staff of the House Committee on the Interior and Insular Affairs, and NRC Commi s-sioner Victor Gilinsky, that the reactor building pressure strip

- chart which recorded the pressure spike was in view of control room personnel at the time the spike occurred.

Mr. Floyd stated

~

that NRC inspectors in the control room at the time viewed the spike.

hiestatedfurtherthat the actuation of the containment I

sprays indicated the spike was real because at least two indepen-dent. pressure sensors were required to cause its initiation.

172.

On May 8, 1979, the New York Times printed an article describing Floyd's briefing and stating that although control room personnel and NRC inspectors were aware from the spike that the core was seriously damaged they did not report the damage for two days to the NRC.

Di eckamp f f. Tr. 28,316, a t 2 8,316-U.

173.

Dieckamp wrcte a mailgram the next day to Congressman

- Morris-Udall, Chairman of the House Committee on the Interior and Insular Af fairs, with copies to NRC Commissioners Gilinsky and Richard Kennedy. M. at 28,316-V; JME l-C (29) at 190-191.

Ac-cording to Dieckamp, he wrote the mailgram to correct what he j

perceived as " misinformation in the New York Times article."

Id.

at 12.

64 8

O

--.--,.-e...

..m-,_.

,,.,,,.,y,,y.,_.,_.m.,.,__,m_,_,..,__

174.

During the hearings, Dieckamp claimed that the mail-

_ O.

gram was not intended to have any official regulatory purpose.

Tr. 28,752 (Dieckamp).

We reject this testimony.

Dieckamp sent the mallgram to Commissioner Gilinsky who was on the site tour, and to Commissioner Kennedy, who used it at a later time to

-answer certain questions posed by the House oversight committee.

{

JME l-C (29) at 190-191.

175.

Dieckamp denied sending the mallgram to any Commis-s toner other than Gilinsky, until conf ronted with the copy he l

sent to Commissioner Kennedy.

Tr. 28,962-964 (Dieckamp).

More-over, a draft of Dieckamp's mallgram indicates that he intended to send it t o al l NRC Commi s s i one r s. TMI A Ex. 14; Tr. 28,752-754 (Dieckamp).

1()

176.

The Board finds, therefore, that Dieckamp intended to L

use the mailgram to convince at least two Commissioners that the licensee did not withhold information about the spike and hydro-J gen burn f rom the Commission for two days.

We have determined that this statement by Dieckamp is a material false statement.

See,Section II, supra.

Moreover, it appears that Dieckamp sent it to Commissioner Gilinsky because of discussions he held with 4

Gilinsky on-the site tour during which Gilinsky expressed concern that licensee had not reported information about the accident to the NRC in a t imely f ashion. Tr. 28,755 (Dieckamp).

177.

Moreover, it was clear to Dieckamp that the NRC con-sidered the mallgram to be submitted to the agency for regulatory purposes when, during a Commission meeting held on October 14,

('

1981, Commissioners questioned him on the mailgram and its inac-3 l

l 65

)

L i

j euraeles.

Additiona'11y, the NRC Staff included it as an issue to

'be-investigated in its information flow investigation. Finally, i

if Dieckamp had any doubt that the Commission considered or j

relied on the'mailgram, that doubt should have been erased when C

i j.

this Board included it as an item necessary for resolution of j

Board Issue 10.

See Section I, sugra.

178.

We conclude that the Dieckamp mailgram was intended to l

be, and was in f act treated as, a statement by licensee to the NRC to convince agency officials that licensee had not withheld information about the single most significant event occurring on the first day of the accident.

B.

Dieckam2's Knowledge of the Interpretation of the l

l i

Pressure S2 h DX Plant and Corgolate Sta7f i

)

1. Miller-Herbein Discussions With Dieckag i

179.

Dieckamp was in Harrisburg on March 28, 1979, for a i

meeting with the Pennsylvania PublIc Uti1ities Commission ("PUC")

4 on business unrelated to TMI-2. He admi t ted to only a few con-versations during the morning of March 28 about the then ongoing accident or transient at TMI-2.

Dieckamp, Tr. f f. 28,316 a t 5-7.

On cross-examination Dieckamp explained that during his first conversations with Walter Creitz and Robert Arnold around 9:00 j

a.m. on March 28 he learned generally about certain parameters of l

the reactor which he described in previous interviews.

Tr.

28,381-383; TMI A Ex. 3; JME l-C (66) a t 122; JME l-C (86) a t 3-5.

L 180.

It appears to this Board that Dieckamp was informed in I

his conversations with Arnold and Creitz of the possibility of offsite radiation releases.

Moreover, his testimony that he did 66 I

..- ~

a not understand how radiation releases could occur if the emer-gency core cooling system ("ECCS") had operated properly, indi-cates that he.was aware of the significance of this information.

JME l-C (66) at 123; JME 1-C (86) a t 4.

181.

At about 11:00 a.m. Dieckamp at tended a briefing by the Lieutenant Governor at which a generally optimistic picture was given of TMI-2. A short time af ter that briefing he spoke with either Creitz or Arnold.

Dieckamp testified that he does not know whether in this conversation he learned of offsite releases above background levels., Tr. 28,389-390 (Dieckamp).

He insisted that he did not learn at any time of specific reactor parameters on the first day of the accident, nor of the strat-egles being used to stabilize the reactor that day. Tr. 28,402 (Dieckamp).

182.

Dieckamp further testifled that he attempted to attend licensee's briefing of the Lieutenant Governor scheduled for about 2:30 p.m. because he wished to learn about the plant's status.

When state officials did not permit him to attend, he testified that he merely greeted Met-Ed of ficials Herbeln, Miller and Kunder on the steps of the State Capitol and a short time later continued on his way back to Parsippany.

Dieckamp testi-fled that he made no other at tempt to contact site personnel to determine the status of the plant.20 20 Dieckamp did admit on cross-examination that apparently he had a conversation with Arnold around 3:00 p.m.

since Arnold previously testified to that fact. Tr. 28,405-406 (Dieckamp);JME 1-C (26) at 28.

Dieckamp continues to argue, however, that i

Arnold in this conversation, did not convey any knowledge of information to him about speelfle parameters of the troubled reactor. Tr. 28,406 (Dieckamp).

s 67

183.

Dieckamp testified that he returned by car to Parsip-pany, although he testified on at least one prior occasion that he did not remember whether he had driven or flown back to his home in New Jersey.

Tr. 28,406; JME l-C (66) at 13; JME l-C (86) at 13.

184.

He also testified that he remembers that he returned to his home alone, although the company informed him, in prepara-tion for this hearing, that two other individuals accompanied i

f rom Harrisburg to New Jersey. Tr. 28,406-407.

185.

Dieckamp stated that the only thing he remembers about the time after he left the State Capitol, and before he arrived home in New Jersey that evening, was a radio communication in which Lieutenant Governor Scranton stated that the TMI-2 accident i

was more serious than the company had previously indicated.

O Dieckamp understood that Scranton meant the Company had misled the Commonweal th, and was shocked when he heard this news.

Yet, E

j according to his testimony, he made no attempt to investigate or Inquire into the situation, but " continued on [his] way home."

Tr. 28,408-410 (Dieckamp).

186.

Dieckamp claimed that he had no direct recollection of c

any of his actions f rom 2:30 p.m.

In the afternoon until he i

returned home, a period he described as a " time gap."

Tr. 28,892 (Dieckamp).

187.

Dieckamp testified that he spoke to Arnold in the evening, after returning home, and learned that site personnel y

had taken the plant solid and started a_ reactor coolant pump.

i Remarkably, Dieckamp claimed that he had not discussed any speel-O fic plant conditions with Arnold at that time.

Tr. 28,410 l-j 68

(Dieckamp).

l) 188..The Board finds this testimony to be non-credible, espeelally when juxtaposed with the testimony of Herbein, Miller and Kunder who have similar " time gaps" concerning the afternoon of March 28.

See infra.

2 189.

Dieckamp was extremely involved in TMI-2 prior to the time of the accident and more than usually knowledgeable about the plant for a corporate executive at his level.

Tr. 30,380-381 (Herbeln); 28,612-615 (Dieckamp).

Dieckamp directly supervised Arnold and W'illiam Verrocht when they headed the design and construction group building TWII.

During the construction of TMI Dieckamp kept himself informed about problems which occurred and attended meetings on specific programs and contracts with major contractors.

Because of his background and interest in the technical issues which arose during the construction of TMI, Dieckamp of ten communicated with Herbein directly even though he j

was not Herbein's supervisor.

Tr. 28,613-615 (Di eckamp )..

190.

Prior to coming to GPU, Dieckamp worked for over 20 years at Rockwell International (or its predecessor North Ameri-can Aviation), serving for three years as President of Atomics International, a Division of Rockwell Dieckamp f f Tr. 28,316 at 2.

191.

The Board finds incredible Dieckamp's professed lack of interest in the ongoing accident at TMI-2, in light of his i

l extensive experience in nuclear technology, his special interest 1

in TMI since 1973, his involvement in bringing outside technical support-to assist in the " recovery ef forts," and his extensive

()

testimony about the accident to state and' national governmental bodies concerned with the accident.

Moreover, we cannot believe 69

that Dieckamp, who was so dis turbed about the May 8,1979 New York Times article that he wrote a mailgram to both Congressman Udall and two NRC Commissioners, would sit by calmly while the Lieutenant Governor told a national audience that Metropolitan i

Edison had misled.the public about the seriousness of the TMI-2 accident.

192.

Fyrthermore, the testimony of Walter Creitz, former Met-Ed President, indicates Dieckamp was informed of off-site radiation above background levels and later misrepresented to the PUC that there were no such measurements.

The Board finds that Dieckamp's misrepresentation to the PUC about the seriousness of the accident seriously damages his credibility.

Specifically, Creitz stated that he so informed Dieckamp in a conversation prior to noon on March 28, 1979.

This was the second meeting he held with Dieckamp that morning, of~offsite releases above back-ground levels.

Creitz believes that he probably mentioned a reading of 3 MR/ hour.

Creitz Dep. f f. 29,708 a t 25-29.

Dieckamp's notes f or March 28 indicate that he was told of the 3

- MR/ hour reading by Creitz since this figure appears immediately to the right of Crei tz' phone numbers. TMIA Mailgram Exh. 3 at 2.

S e e a l s_ o TMI A Ex. 9, a t 5 -6.

2 4

193.

In addltlon, it appears that the NRC, in a Preliminary Notification issued on March 28, stated that at 10:4 5 a.m.

radia-tion levels of 3 MR/hr had been detected 500 yards offsite.

JME l-C (143) at. App. E.

Therefore, site personnel did have i nforma-tion which they passed to the NRC of of fsite releases of 3 MR/ hour. measured at 10:45 a.m.

The Board finds credible Crei tz' 70 r

,e-

---.-,,--.yp-,,.v,r---y.--

y n--.,----w

---v--7--

-,y-

.-r.-

l 1

testimony that he informed Dieckamp sometime prior to Dieckamp's Q

second statement to the PUC around 11:30 a.m.

of offsite re-leases.

Dieckamp told the PUC at 11:3 0 a.m.,

after speaking to Creitz, the following: "There is no evidence of any radiation that is detectable above the background levels in the area."

TMI A Ex. 4 a t 2; Tr. 28,398 (Dieckamp).

It is clear to the Board that Dieckamp had available to him information indicating offsite releases above background.

Yet he told the PUC without qualification that there were no such releases.21 194.

We find Dieckamp's misstatements to the PUC during the morning of March 28, 1979, weigh heavily in our decision not to credit his testimony about discussions between himself and site personnel later that day.

Dieckamp claims he met Herbein, Miller I

and Kunder on the steps of the State Capitol around 2:30 p.m.,

O af ter-he was excluded f rom the briefing of the Lieutenant Gover-nor.

Although he testified that he spoke to the three gentlemen, his only memories of that conversation are that he expressed concern about the absence of senior people f rom the site, and gained an impresion that the plant was in a stable condition.

Dieckamp f f Tr.

2 8,316 a t 7.

195.

Herbein and Miller, in almost identical language, 21 Dieckamp's fi rs t statement to the PUC at 9:00 a.m.

omits information about the seriousness of the TMI transient.

Although he did know of some of f-normal radiation releases and had some

_ question about the proper functioning of the ECCS, he stated:

"All the indications that we have are that the plant is safely shut down.

I am unaware of any impact or release which would have an interaction with the general public in the environ to the p l a n t."

TMIA Mailgram Exh. 4 at 2.

n v

71

describe their conversation with Dieckamp on the steps of the O

st t c 9 tai-

" rd ia r

11 a

=d r doat ta eaav r i

tion is "Mr. Dieckamp asking who was back at the Island minding the store.

And, in addition he indicated that they wanted to talk to me during the briefing, that apparently they didn't want j

to talk to him."

Tr. 30,378 (Herbeln).

196.

Miller stated that he could not remember any of the conversation he held wi th Kunder and Herbein on the-way to the State Capitol, and all he could remember about the brief discus-sion with Dieckamp was that Dieckamp " asked me who is minding the store..."

Tr. 30,214 (Miller).

Kunder has no recollection of this encounter other than "a sense of urgency or promptness on the part of Mr. Dieckamp to have us go in and brief the Gover-nor..." Tr. 30,071 (Kunder).

197.

It is not credible that all four participants in this discussion, including the three Met-Ed of ficials with the best understanding of the TMI-2 accident, would remember nothing about the conversation except an off-hand remark by Dieckamp.

Further, we do not credi t Dieckamp's tes timony tha t he did not ask ques-tions about the status of the reactor, and that Herbein or Miller did not-tell'him about the specifle plant parameters. Tr. 28,402 (Dieckamp); 30,215 (Miller); 30,378-379 (Herbeln); 30,070-071 (Kunder).

198.

Not only was Dieckamp particularly interested in TMI, he would likely be one of the GPU officials kept most completely

(

. informed about an incident of this magnitude.

Given his deep i

[]

involvment in TMI after the accident, including his admltted 72

- ~ -

involvment in bringing of fsite technical support to the site, we do not believe Dieckamp would adopt such a nonchalant attitude

(

toward the on-going accident while he was in Harrisburg.

Dieckamp ff Tr. 28316 at 9-11.

199.

Dieckamp stated that he wanted to attend the briefing of the Lieutenant Governor scheduled f or 2:30 p.m.

because he wanted to learn about the incident. Yet he made no ef forts, according to his testimony, to obtain the information first-hand, either from Herbein, Miller and Kunder after they c'ompleted their briefing of the Lieutenant Governor, or f rom other site person-nel.

Tr. 28,403-405 (Dieckamp).

The Board does not believe Dieckamp would attempt to obtain information about the status of the reactor from a briefing of Co.nmonwealth of ficials rather than

)

directly from those within his company, nor that he would simply give up his attempt to obtain the information once excluded from the Commonwealth briefing.

200.

Equally striking to the Board is the " time gap" which appears to exist in the recollections of Dieckamp, Herbein, Miller and Kunder.

Dieckamp stated that other than hearing the radio commentary f rom the Lieutenant Governor he has a " time gap" f rom 2:30 p.m. until Wednesday evening when he returned home to New Jersey.

Tr. 28,892 (Dieckamp).

Herbein said he does not remember much about the trip back from the briefing to the site.

He assumed Miller managed to go back to TMI and to the control room, and he to the Observation Center -- and he could not remem-ber whether Miller and Kunder stopped at the Observation Center

()

on the return. Tr. 30,382-383 (Dieckamp).

Miller testified that he had absolutely no memory of the time when he lef t the State 73

House until the time he returned to the site other than getting out of the car at the processing center.

Miller stated that he could not remember anything about the ride back including whether Herbein and Kunder returned with him. Tr. 30,220 (Miller) Kunder testified that the time period after he left the Lieutenant Governor's briefing was "somewhat of a blank. You are talking about an hour or two or three that I don't specifically recall my, you know, exactly what I did."

He also stated that he did not have "any recollection of just where I went, but I do know I returned back to the TMI area, probably into the plant, but I can't recall that particular time period with any degree of c l a r i t y."

Tr. 30,072-073 (Kunder).

201.

The Board does not believe that Herbein, Miller and

, O Kunder have no bet ter memory of the one and one-half to two hours f rom the time they completed the briefing until the time they returned to the site.

Their testimony is especially incredible if one believes that Miller protested leaving the site in the first place.

Moreover, an hour and one-half would be an unusual-ly long period of time for the ride back to the site.

It is not credible that Dieckamp would have a similar " time gap" during which he cannot remember whom he was with, whether he drove or flew back to New Jersey, or anything to do with the event other than one radio news brief which he allegedly ignored.

i 202.

The evidence brought before us about Dieckamp's deep involvement in TMI both before and af ter the accident lead us to '

conclude that Herbein and Miller briefed Dieckamp on the status of the' reactor at some time during the af ternoon of March 28.

i f

I 74 L

This briefing necessarily would include informing him of incore thermocouple temperature readings greater than 2200 degrees F, and the hydrogen burn which had occurred only a short time prior to Miller's departure f rom the site.

203.

We also find that Herbein misrepresented information to the Lieutenant Governor during the afternoon briefing.

This further discredi ts his and other Met-Ed of ficials' testimony that they did not know about the pressure spike at the time of the briefing and did not convey that information to Dieckamp.

204.

Herbein stated in this briefing that Met-Ed had mea-sured no offsite radiation releases even though he and Met-Ed officials knew that such measurements had been made.

JME l-C (142) at 42.

Herbein testified in this hearing that if he had O

known of of f site reieases he wooid have teid the ueutenant Governor, but that he was not sure that Met-Ed knew of such i

releases. Tr. 30,374-375 (Herbeln)

However, as discussed above, Creltz testified that sometime before noon he was informed by

- Unit 2 control room personnel of of fiste releases which he re-por ted to Dieckamp.

Crei tz Dep. f f. Tr. 29,708 a t 24.

4 205.

Moreover, the NRC's preliminary notification confirmed that such measurements had been made at 10:45 a.m.

Therefore, the Board helleves that Herbein and Miller knew of these measure-ments and misrepresented the situation to Commonwealth of fletals

[

by denying such of fsite releases.

206.

If, as we believe, Herbein and Miller told Dieckamp I

about the pressure spike and hydrogen burn on March 28 he inten-tionally made false statements in his mallgram when he stated that no one understood the significance of the pressure spike and 75

7-_..

m-_

t p

containment sprays on March 28.

C.

' Brough t on-Kea t en Consnun i ca t i on wi t h Di eckamg 207. Even if we find that Dieckamp was not informed of the hydrogen burn and incore temperatures exceeding 2500 degrees F by flerbein and Miller on March 28, we believe the GPUSC engineers who were sent to the site informed Dieckamp through Robert Keaten early on March 2L of the hydrogen burn in the containment build-4 ing, and of the hydrogen or noncondensible gases present in the pressurizer.

Therefore, Dieckamp knew on March 29 that GPUSC engineers sent to the site had interpreted the pressure spike to be a burn or explosion of hydrogen produced from the zire-water reaction.

208.

It is necessary first to establish the reporting i

relationships which existed between the GPU Service Corporation group sent to the site on March 28 and GPU headquarters in Par-sippany.

According to Broughton he continued to report to his immediate supervisor Keaten until Richard Wilson came to the site l-to set up a formal organization.

At that time he began reporting l

to Wilson.

Tr. 31,128 (Broughton); TMIA Ex. 31 at 93-94.

l 209.

Wilson arrived on site during the afternoon of-March 29 and chaired the first meeting of the Task Force held at 3:30 p.m.

in the Processing Center.

TMIA Ex. 18 at 3.

Therefore, we assume i

. that Broughton maintained his usual reporting relationship to Kosten until Wilson arrived-on site during the afternoon of March

. 29 to set up the formal Task Force group, directed by Dieckamp.22 22 Broughton contends that when he spoke about a formal i

organization in his deposition he was talking about the formal i

organization set up on March 30 to provide direct support'for i

plant opera tions. Tr. 31,139 (Broughton).

However, it is clear t

'76

~..

~,

'( )

210. 'The Board-finds, therefore, that Broughton maintained a formal reporting relationship to Keaten only through the morn-Ing of March 29, and beginning that afternoon, reported _directly l

to Wilson who arrived at the TMI site to set up the Task Force.

211.

As stated in Section II (A)(4), su2ra, Broughton was i

aware of incore thermocouple temperature readings greater than 2200 degrees F which would lead him to believe that a zire-water reaction had produced significant amounts of hydrogen, and that l

.the 28 psi pressure spike recorded in the reactor building was caused by the combustion of that hydrogen.

As explained below, 4

j we believe that Broughton reported these findings'to Keaten who in turn repor ted them to Dieckamp on the morning of March 29.

(

l.

Broughton Regorted to Keaten 212.

Broughton has testified that he cannot remember whether he reported to Keaten anytime on March 28 or March 29.

Tr. 31,125-126 (Broughton).

However, Broughton admits that as a matter of routine he would have reported back daily to his i

management. Tr. 31,127; 31,132; 31,204.

Given Broughton's ex-

~planation in his deposition that he reported to Keaten through the morning of March 29 and thereaf ter to Wilson, we conclude i

that there was no such organization formed on March 30, and what Broughton was referring to both in his deposition'and in his testimony in this hearing was the Task Force which Wilson headed which was divided up into two-sections: Events Analysis and l

Recovery Planning. TMIA Ex. 18 at 3.

In fact, Broughton states this explicitly later in his testimony when he testified his funetton did not change'much with the more formal organization since he was merely assigned to work in the Events Analysis section.

Tr. 31,158 (Broughton).

He also mentions that at the t

time the more formal organization was set up "we planned to begin interviewing operators..."

Ibid.

This decision was made at the Task Force meeting during the afternoon of March 28.-

77

[]

ithat-any reports made to Keaten would have occurred prior to the first meeting of the Task Force at the TMI si te at 3:30 p.m.

on March 29.

213.

Keaten's notebook contains one set of notes with the following notation at the top of the page: "TGB call 3/29/79?/3/301".

The original of these notes indicates that "TGB call 3/29/79" appears in the same color blue ink as. the notes themselves.

The rest of the notation, including the question mark and-the.second date 3/30, appear in red ink.

Keaten testi-fled that "TGB call 3/29/79" was wri t ten at the same time as the-2 notes themselves for that entry.

IIe further testified that he added-the second date in red ink some time prior to turning the 4

notes over to NRC investigators because he believed that he had O

placed the wrong date on the notes when'he originally wrote them.

TMIA Ex. 10 at 11; Tr. 31,260-31,261;31-271 (Keaten).

4 214.

Keaten further testified that he wrote the first three pages of these notes to record information he obtained from a telephone call f rom Broughton.

Tr. 31,262;31,265 (Broughton).

The first notation states "HD at 10:45 Airport".

This apparently.

refers to Dieckamp's arrival at the Harrisburg airport. Tr.

31,133-(Broughton)

The second entry is "l:00 Senators-briefing".

l According to Broughton, this refers to the congressional briefing l

which was conducted in part by Dieckamp during the af ternoon of Ma rch 29. Tr. 31,139 (Brough t on).

215.

The Congressional briefing which was conducted during

.]

the afternoon of March 29 took place around 2:30 p.m. according l

to the Rogovin Repor t. Tr. 31,310 (Kea ten); JME l-C (106) a t 841.

78

r 216.

The1 third entry, whleh continues onto the following page, is "S.O.E." which means Sequence of Events.

Following this r

title is chronology of the major events occurring on March 28,

.ending with the notation " Finally 7-8 p.m.

... pump started".

On 3

the next page, irmnediately following is an entry which appears to follow the sequence of events, "Present Status".

Under present status.the following appears:

' Bubble in reactor i -

Non-condensables in Pressurizer

--lots-Explosion in containment 1000 ft3 [atl 1000 psi 280 degrees F 260-280 Could be 100,000 ft3 TMIA Mailgram Exh. 10 at 11-13.

B217.

roughton has testified that on March 29 he was aware

{ y of all the information which appears under the section Sequence of Events, but not the information which appears under "present status".

Tr. 31,141 (Broughton); TMIA Ex. 31 at 70-71.

218.-

We find that the preponderance of the evidence indi-cates that Broughton and the other GPUSC engineers at the Obser-t vation Center on March 28 and through the early morning of March 29, obtained data sufficient to compile the Sequence of Events as 1

well as the evaluation of the present status which appears in Keaten's notes under the March 29 entry.

219.

For example, it appears likely that through the hard l

data brought by Lentz back to the Observation Center, Broughton's f

group learned of the pressure spike and hydrogen burn in the containment building at about 1:50 p.m.

This data included the

()

alarm printout and copies of the pressure spike strip chart.

See Sec t ion !! (a)(4), sugga.

79

220.

Prior testimony also indicates that there were discus-sions among the Broughton group engineers about the possibility of a bubble in the reactor vessel.

JME l-C (48) at 6 (Brough-ton); JME 1-C (47) at 14-15 (Len tz).

221.

Finally, we believe that the information available to 5

i the GFUSC engineers would lead them to believe that any bubbles which " remained in the primary reactor coolant system by the morning of March 29, 1979, and which had not been collapsed af ter a reactor coolant pump was started on the evening of March 28, l

were composed of hydrogen or non-condensible gas.

Therefore we believe that they knew by the mornTng of March 29 that the bub-b!es which remained in the system, including those in the pres-w surizer, were noncondensible gas and not steam.

Tr. 28,472-478

[

(Zebroski).23 222.

The Board concludes that pages 11 through 13 of the Keaten notes are notestof a-conversation Keaten held with Brough-

~

ton on,the morning of March 29.

The most compelling evidence Y

'i supporting this conclusion is the fact that Keaten wrote down the

'h'

~~

date of March 29 at the time he wrote down the notes. Second, we C,

believe that Broughton and.others in his group had obtained.all 23 Th'ere are two other indications from Keat en's - notes that they were written on March 29 and net on March 30.

First, the calculation of the volume of-gas in ~the primary system, either 1000 or -2000 cubic feet, ~is a much rougher calculation than that made by William Lowe and Moore during the night of March 29. See TMIA Ex. 7 ' a t 1, which-contains a notation that there had been 1500 cubic feet of noncondensable gas calculated in the pressure vessel and pressurizer; Lowe, ff. t r. - 2 8,151 a t' 12.

-Secondly, the primary. system pressure and temperatures which are noted under "Present' Status" are those which were measured at least as early as 1:30 p.m. ~on March 29, and probably during:the early morning of March 29.

TMIA~ Ex.2 at 5; Tr..31,148 (Broughton).-

80 y

the information in these notes by Thursday morning.

Third, it O

appears that the purpose of Broughton briefing xeaten was to assist in preparing Dieckamp to travel to TMI on Thursday.

l 223.

Clearly the first two i tems record Dieckamp's schedule for March 29. Tr. 28,643 (Di eckamp).

There could be no conceiv-able reason for Keaten to record on March 30 Dieckamp's sched-ule for the prior day.

Moreover, the timing of the congressional briefing is incorrect, since the briefing took place around 2:30

-p.m.

and not 1:00 p.m.

If Broughton informed Keaten of the time of the briefing af ter the f act he would have stated the correct time, whereas the time of the briefing might be misstated prior to the time of its occurrence.

Tr. 28,643 (Dieckamp).

Finally, we believe that Broughton did not report to Keaten but to Wilson 4

after the morning of March 29.

Therefore, we find these notes record Broughton's briefing of Keaten on March 29.

2. Keaten Reported y _Dieckamp 224.

Keaten has testified to the NRC that after taking these notes, including the section entitled " sequence of-events" and "present status" he met with Dieckamp to convey to him the information contained in the notes.

JME I-C (45) a t 7.

Keaten testified at the hearing that "It-had been prearranged that I i

would get a telephone call f rom Mr. Broughton, that he would give me a rundown on what they had learned and then it had been arranged that I would go and brief Mr. Dieckamp on wha t I had l

l ea r ned."

Tr. 31,248 (Kea t en).

225.

Keaten currently, and at the time of his original NRC interview in 1979, stated that he received a briefing from Broughton and in turn briefed Mr. Dieckamp on March 30, 1979. JME 81

r (45) a t 7; Tr. 31,392 (Kea t en).

O 1-C 226.

We find that Keaten did in fact brief Dieckamp on what he had learned f rom Broughton, but did so on the morning of March 29 when he first received'this information from Broughton.

It is reasonable to infer that Keaten's notes under the 3/29 date were writ ten to prepare Dieckamp to travel to the TMI si te on the morning of March 29.

227.

If Dieckamp were briefed by Keaten of information Keaten obtained f rom the Broughton group on the morning of March 29, Dieckamp knew at that time that si te personnel and GPUSC

' technical personnel had already understood the pressure spike to be caused by a hydrogen burn in the containment which indicated core damage.

O 3.

Dieekate, s Awareness of Core Damage on wareh 2. and March 2,9 1979 Demons t ra tes His A_wareness o7, _the.

2 Hydroge_n_ Burn.

228.

On the morning of March 29, Dieckamp signed a memoran-dum authorizing the formation of a Task Force to analyze the 1

accident and assist in a recovery. operation, after discussing with Arnold.the severity of the accident.

Arnold has' testified

'that Dieckamp spoke to him about significant core damage in this

~ discussion.

JME ' l-C (8 4) a t 2 4-2 6, f f Tr. 2 8,6 3 5 ; Tr. 2 8,6 4 0.

Although Dieckamp ' claimed that "significant core damage" meant little more than " cracked fuel, failed fuel pins such that they lost their integrity as far as containing gas, radioact ive gas,"

we find that Dieckamp meant core damage caused by a zire-water reactlon.

Dieckamp f f Tr. 28,316.24

~

24 It appears _that Dieckamp was informed by Arnold on the morning

-of March 29 that HPI had been throttled the previous day. JME l-82

~

t 229.

Further, Wilson briefed the Task Force at the begin-j ning of its first meeting at 3:30 p.m. on March 29, 1979.

He stated the following, according to GPUSC engineer Julien Abramovici:

"...we assume that the core is damaged...a financial los s...tha t you los t 'a core, that that's equal to X amount of dollars...In other words, we're not looking to restart the reactor in the immediate future because of this potential core damage."

TMIA Ex. 20 at 49-50.

230.

Notes taken by Broughton and Abramoviel of the meeting corroborate that Wilson gave this assessment at the beginning of the meeting.

Abramoviel's notes read: "As sump t i ons: 1 year out-age; 30 mi11 ion core lost; 20-30 mi11fon".

TMIA Ex. 38 at 2.

Broughton's notes of the meeting state as a goal of the meeting

" Detailed assessment of core damage".

Tr. 31,542-543 (Wilson);

.O TMIA Ex.

39.

The notes also state "one year, 30 million core and

$20 -$30 million cleanup" Ibid.; Tr. 31,541-542 (Wilson).

231.

The Board believes that Wilson could make this assess-ment of serious core damage only if the Broughton group at the site had transmitted to GPU Parsipanny headquarters hard informa-tion about the accident, including the high incore. temperatures and hydrogen burn.

Moreover, Wilson's assessment of the serious-l i

ness of the accident could only be derived from his immediate l

l superior Arnold, or from Dieckamp who signed the memorandum l

L

. establishing the Task Force.

It.is unlikely that Arnold, in discussing with Dieckamp on the morning of March 29 would have withheld from him any information concerning the status of the O

c (84) at 27.

This wouid tead Dieckamp to the conclusion that there had been some core damage beyond failed fuel or cracked fuel pins.

l l

83

O reactor or the degree of core damage.

Therefore, we believe I

Wilson's assessment of the accident and the degree of core damage suffered at TMI-2 are evidence supporting our conclusion that Dieckamp was aware of the hydrogen burn on the morning of March

-29, and of TMI-2 had serious core damage.

232.

Finally, we find further corroboration that Dieckamp understood the serious nature of the accident on March 28 from a memorandum written to him on March 29 from Bud Cherry.

TMIA Ex.

5.

Cherry was Vice President of Planning for GPUSC at the time of'the accident.

He reported directly to Dieckamp.

He is one of the individuals whom Dieckamp asked to assist him in gathering together outside technical support in the aftermath of the acci-dent.

Cherry had an extensive nuclear background.

Tr. 28,413-O 28,414 cDieekamp>.

233.

Cherry in this confidential memorandum to Dieckamp described communication problems during the first day of the accident.- In doing so, he described the individuals within Met Ed. and GPUSC 'who were informed and had hard data and information about-TMI-2 on the first. day of the accident.

234.

Cherry stated that he believed Arnold was the only one to whom he spoke during the' day, who appeared to have hard infor-mation about the condition of the reactor.

He stated that Met-Ed headquarters personnel were "not up to speed" on the accident and at least one, and perhaps two press releases underplayed the seriousness of the accident.

Id. at 1-2.

At one point Cherry e

told Creitz to' contact Arnold "to get an update" on the situa-tion.

Finally, Cherry stated that problems in obtaining and communicating hard information about the accident persisted 84

i

{^}

throughout the early afternoon until he talked to Dieckamp and got "his view of the status of the reactor."

Cherry wrote, "I

think it was really only at that point that I had the full understanding of the situation and the condition of the plant."

Id. at 2.

235.

In light of Cherry's nuclear background and the sub-ject matter of this confidential memorandum, it appears that Cherry credited Dieckamp with having the best hard information on the status and condition of the reactor on the first day of the accident..This would be true only i f Dieckamp were in f act informed of the high incore temperature readings and the hydrogen burn which would lead him to the correct assessment that TMI-2 had suf fered serious core damage.25 236.

We conclude, therefore, that Dieckamp's underestanding by the morning of March 29 that TMI-2 had suf fered serious core damage, demonstrates his awareness of the hydrogen burn occurring at 1:5 0 p.m. on Ma rch 2 8.26 25 The circumstances under which this memorandum was produced

.1 discovery in this proceeding also demonstrates its reliability.

Apparently Dieckamp produced the original of this confidential memorandum for the first time at his deposition.

It was not produced to the NRC in the courselof any prior investigation.

Given that the memorandum speaks frankly-of the communication problems within the GPU and Met-Ed organizations on March 28,- the Board gives it great weight.

l 26 Dieckamp testified that he did not learn of the pressure spike until Arnold informed him sometime on March 30.

According to Dieckamp Arnold ' told him of the Task Force's analysis of the i

pressure spike recording during the night in terms of a zirconium-water reaction which led.to production of hydrogen to o

r l'

-85

i i

D. Conclusion 237.

The Board finds that Dieckamp knew that the statements in his ma11 gram, that no one interpreted the pressure spike in terms of core damage at the time it occurred and that no one l

withheld information, were false at the time he wrote them.

i t

i a

i flammable limits.

Dieckamp, ff Tr. 28,316 at.9.

r

. Moreover, Dieckamp tes ti fled that he cannot remember any-briefing by Keaten concerning the information contained under the en t ry "TGB cal l 3/29/79".

Tr. 28,646-647 (Dieckamp).

Dieckamp's notes for March 30, 1979 do not reflect _either the conversation.he describes with Arnold about the-pressure spike or the conversation Keaten describes with Dieckamp.

TMIA Ex.

3.

Dieckamp currently possesses no notes for March 28 other than two pages taken during the morning of March 28 and no notes for-March ~29.

Tr. 28,622-623 (Di eckamp). - He-has'no explanation

-of why no such notes exist.

Ibid.

The Board finds, further that Dieckamp's notes of March 30 lack' any record of a conversa, ion with Keaten.

The Board finds t

tha thisLsupports an inference that Keaten's briefing occurred

- O oa =t areh 2., and not March 30.

86

~

IV.

ASSUMING THAT DIECKAMP DID NCyr KNOW THE STATEMENTS IN HIS--MAILGRAM WERE TALSf IT TNf~TlIWE-NE SYNT~ THE (O

iarto'arar r"otmo "^wrotoest <urv werE ExrSc.--- ---

238.

This Board finds that Dieckamp should have known that statements he made in his mailgram were false at the time he made them.

A minimal investigation on his part would have demon-st rated that there was in f act "some evidence" that on March 28 licensee and GPUSC personnel properly interpreted the pressure spike to indicate a hydrogen burn and core damage.

239.

Dieckamp cannot sustain his current position that the

" thrust" of his mailgram is accurate.

He uses the standard of whether there is " absolute proof" that operations personnel prop-erly understood that the pressure spike was caused by a hydrogen burn and indicated core damage.

Dieckamp ff Tr. 28,316 at 15.

This is a distortion of the issue before the Board.

(O 240.

The issue is whether there is any evidence of a proper interpretation of the spike and whether IIcensee improperly withheld information f rom the Commission about the spike or hydrogen burn.

It is not Dieckamp's or the Licensee's responsi-bilt ty to determine what information " passes muster" and needs to be turned over to the NRC.

Clearly, all potentially useful information about critical reactor parameters was required to be I

l disclosed to the agency during the accident.

241.

We believe that Licensee's four arguments in support i

of Dieckamp's pos i t ion, have eroded under close scrutiny during L

this hearing.

Licensee's f our arguments are:

1)

A complex analysis, beyond the training and capabilities of TMI-2 operators was required to

( hs determine the pressure spike was caused by a hydrogen l

burn and demonstrated core damage; 87

2)

Prior Chwastyk, Mehler and Illjes' interviews do not provide " absolute proof" that they properly interpreted the pressure spike as caused by combustion

'( h_)

of hydrogen produced through a zirconium-water reaction; 3)

The conclusion in NUREG-0760 that on March 28, 1979 no one in the control room at Unit 2 properly interpreted the pressu~re spike supports Dieckamp's mallgram statements; and i

4)

GPU consultant William Lowe was the first person to discover the significance of the pressure spike at 11:00 p.m. on March 29, 1979.

242.

As explained below, we find the information available to Dieckamp on May 9, including operator interviews, provided him with adequate information to conclude that some individuals ap-preciated the significance of the pressure spike on the first day of the accident.

A.

Dieckamp'Ts Boird.s Undulv Restrictive Definition of the Issue BeTore tE

(()

243.

Dieckamp testified that prior to sending the mailgram on May 9 he reviewed Miller's reconstruction of the events of March 28, transcribed from a taped conversation of a number of key TMI personnel, JME l-C(10).

Miller prepared this statement to help Dieckamp prepare testimony for the Nuclear Regulation Subcommi t tee of the Senate Commi t tee on the Environment and Public Works (Hart Commi t tee).

Dieckamp ff Tr. 28,316 at 11.

Dieckamp also reviewed virtually all early Met Ed operators' interviews; sat in on discussions concerning preliminary reviews of sequence of events; and ecoordinated the activities of the l

Industry Advisory Group ("I AG").

Dieckamp ff Tr. 28,316 at 11.27 27 Licensee presented testimony f rom Edwin Zebroski and Thomas Van Witbeck that Dieckamp was intimately involved in analysis of the

<O l

88 s

=.

244.

Dieckamp was also involved in reviewing reports from

( O operator. interviews, ineiuding those interviews eendueted bv Robert Long and Donald Reppert.

Dieckamp apparently gave an order early in the interview process that no report was to be issued prior to his review and approval.

The language he uses in instructing Long in this regard demonstrates an intent to suppress information which would be unfavorable to the company.

According to the transcription of a group intervice conducted by Long, Dieckamp gave him the following instructions:

4 He r e's the status of this thing here:

We start a review wi th the VP's and Herman last night; they said,

" Hey, you got some conjectures in there."

We're gonna have to, but they said, "Take th t out and only give us a

stuff that you can actually document, either from the control room logs or from an interview; not something you inferred" and when we're to have that to them tomorrow af ternoon and then its to go j

p

- on the street as soon as they've said OK. And tha t's.

()

what we're working toward.

And I've jus t got direct orders from Dieckamp that says I've got to keep that contained and not give it to anybody unt il we get their approval.

TMIA Mailgram Exh. 12 at 4.

245.

The Board finds that Dieckamp's instructions regarding i

operator interviews show that he personally wished to maintain 4

l tightLcontrol over the interviews and restrict disclosure of information about the accident to only " documented information.

Dieckamp's at titude toward the Long investigation parallels his attitude in addressing.the question-before this Board, that is, wh' ether anyone interpreted the pressure spike in terms of core accident-in the period immediately af ter the accident, beginning on March 30, 1979.

Zebroski f f Tr. 2 8,441 at 12; Van Witbeck f f

- Tr..28,261 at 3-4.

i 89

+>

.tg

-ry wm

>www

-'w.*-

y-w-w+y

,y.,,yqnwway.m 4.,y w.-..y-y-w--,gewy-w.-

- - ~ - -

e.wy----r---_._y e-i

damage.

246.

Certainly, one of Dieckamp's main responsiblities in O

the post-accident period has been to to ensure that all relevant i nformation is disclosed to the Commission.

Therefore, it is particularly disturbing that in sending the mailgram, and con-tinuing to defend its clearly erroneous content, Dieckamp has signaled to this Board that his concern is not with whether or i

not the company withheld potentially useful information about the

. pressure-spike and hydrogen burn during the accident, but rather with whether or not anyone completed a detailed technical analy-

- sis of core damage which under NRC requirements was required to be disclosed.

247.

Dieckamp's narrow view of licensee's responsibility to disclose information to the NRC reflects poorly on his integrity and capabilities.

(

B.

A Complex Technical Analysis Is_ Needed To Determine the Pressure Spike was Caused by a Hydrogen Burn.

248.-

Licensee contends that a complex technical analysis was required to understand the significance of the spike, and l

that Met-Ed operators were not technicall'y trained or capable of

(

. making such an analysis.

In support of this position, Licensee

[

presented the testimony of Tom Van Witbeck.

Van Witbeck testI-

- fled that he only appreciated the pressure spike as an Indicator of core damage in the April 2 to 4, 1979 time period.

This testimony is unconvincing.

L 249.

Van Witbeck admits that he failed to even speak 'to j

site personnel explicitly about whether'they interpreted the

-O pressure spike eorreetiy at the time, or whether they had with-o I-L g-

-y,,,----s-

--y yw+-

c, w w w w.

o,.--ev.wy-7

,-,-,v,.w

,,w..w7.-g

mu-

-y---

- -. - +

--,.,,,%3 v-e-

+s

held information about the spike or hydrogen burn from the NRC or the public.

Tr. 28,265-266 (Van Witbeck).

Further, he did not

(-()

speak to Dieckamp about this issue at any time during 1979 or 1980, to his knowledge.

Tr. 28,264 (Van Wi tbeck).

Therefore the Board finds it difficult to understand what he knows about site personnel's awareness of the hydrogen burn on March 28 or Dieckamp's investigation into that matter.

250.

The reliability of Van Witbeck's testimony on this issue is further questionable, given his past focus on accident I

related events.

The Sequence of Events which Van Witbeck's Accident Assessment Group prepared included only events which could be proven or demonstrated f rom direct plant indicators and does not include events which must be drawn from " inferences or 4

conclusions" from direct indicators.

Tr. 28,290-291 (Van Wi t-

( O beck). -Therefore Van Witbeck's work on the 5equence of Events

.i did not include a description of operators' interpretation of the pressure spike at the time it occurred and would provided no guidance to Dieckamp on this matter.

Tr. 28,291 (Van Wi tbeck).

251.

Similarly unreliable was the testimony of Licensee witness Zebroski, who arrived at the site on March 31.

His assignment at that time was to assess core. damage.

La t er in May, he became Director of the Nuclear Safety Analysis Center which conducted a study of the accident based on " detailed analysis of instrument records".

The NSAC studies avoided reliance on recol-lections of plant personnel.

Therefore Zebroski did not focus at any time on the issue of whether licensee personnel properly interpreted the pressure spike at the time it occurred to indi-00 cate core damage or a hydrogen burn.

Zebroski ff Tr. 28,441 at 91

i 3-4, 10; 28,463; 28,526 (Zebroski).

Zebroski's testimony clear-()

ly does not support a conclusion that through conversations with the NSAC analysts, Dieckamp made a diligent effort to inquire 2

into whether site personnel properly interpreted the pressure spike at the time it occurred.

252. -Licensee suggested during the hearing that it took weeks or months for experts such as Zebroski and Witbeck to understand and analyze the extent of core damage at TMI, even after it was recognized that the spike was caused by combustion of hydrogen produced by a zirconium-water reaction. Tr. 28,264 (Van Wi tbeck); Zebroski ff. Tr. 28,441 at 5-9-11; 28,522.

The inference licensee suggests we make is that given the difficulty of this analysis, site personnel could not have properly inter-preted the spike at the time it occurred.. See also Lowe f f. Tr.

2 8,151 a t 8 - 11.

253.

However this Board rejects Licensee's interpretation of the issue.

The Board is not concerned with the issue of whether site personnel on March 28 made a detailed technical

+

analysis of the extent of core damage from their observations of the spike, but rather whether they understood,in general terms, that the spike indicated a burn of hydrogen produced by a zirconium-water reaction.

As Chwastyk emphasized during his t

. testimony before this Board on March 28, 1979 site personnel were most interested in stabilizing the reactor and not in making fine analyses of the amount of core damage.

Tr. 29,180 (Chwastyk)

!. ( )

254.

By the early morning of March 30, Dieckamp had told 92

l l

top EPRI officials, whose assistance he was seeking, that the

-( }

accident at TMI was very serious and that "significant core

(

damage ]was] apparent".

Tr. 28,452-453 (Dieckamp); TMIA Mailgram Exh. 6 at 4.

Moreover, in an introductory IAG meeting on March i

31, which Dieckamp attended, the general working assumption was that there was a minimum of 15 percent core damage.

28,480-485.

(Zebroski).

i 255.

Clearly by March 30 and 31, licensee officials, l

including Dieckamp, had already assessed the core damage at TMI f

as very serious. This was apparently based on a proper analysis f

p of the pressure spike, which Dieckamp himself characterized as the Rosetta stone of deducing the degrees of core damage.

Tr.

28,364 (Di eckamp).

f 256.

Because it required a complex analysis, we reject O

licensee's argument tha; site personnel could not have properly interpreted the pressure spike in terms of core damage because it required a complex analysis.

C.

Dieckamp's Analysis of Chwastyk Mehler and Illjes' 1

IntervTews.

257..

Dieckamp's argues that although Chwastyk, Mehler and Illj es' interviews cons t i tute "some evidence", ' they do not con-stitute suf ficient evidence to convince him that Chwastyk, Mehler 4

and Illjes properly understood the pressure spike.

Tr. 28,757 (Dieckamp); Dieckamp ff Tr. 28,316 a t 13-15.

We find Dieckamp's analysis. of. these interviews in his testimony to tur misleading.

258.

For example, Dieckamp states that Mehler is uncertain about the timing of equipment limitations.

Dieckamp f f Tr. 28316 O

at 13..

However, it is clear that a fair reading of Mehler's i

93

interviews would indicate that he was absolutely certain that March 28 was the date he was given an instruction not to activate

(

equipment in the reactor buildidng until a New York Times article appeared discussing his testimony to this effect before the Special Inquiry Group.

JME l-C (89) at 13,14; JME l-C (68) at 13; TMIA Mailgram Exh. 17.

See, discussion,Section II A, supra.

Dieckamp's testimony is misleading insofar as it suggests that

.Mehler has always been uncertain of the date of the instruction.

In fact the preponderance of his testimony indicates he remembers the instruction on March 28.

259.

Dieckamp also suggests that the basis for Illjes' recollection of an evening discussion on March 28 of the hydrogen explosion, is his connection of the event to the time when the containment pressure recorder chart was removed for photocopying.

((

.Dieckamp ff Tr. 28,316 at 13-14; 28,808-811 (Dieckamp); JME l-C (36) at 6.

In fact, in at least two separate statements, Illjes does not link discussion of the hydrogen explosion with xeroxing of the chart in at least two places in his May 23, 19 79 NRC interview.

See, JME 1-C-36 at 6,

10; Tr. 28,808-810 (Illjes).

260.

Moreover, Dieckamp f ails to mention that Illjes reaf-firmed his early testimony in a September 24, 1980 NRC interview, stating three times that he recalls a discussion of hydrogen or noncondensible gas on March 28.

See JME l-C (127) at 6,9.

Indeed, Dieckamp testified to the Board that he was not certain he had read Ill jes' second NRC Interview.

Tr. 28,817 (Dieckamp).

261.

Dieckamp also testified that he did not believe that

{

Chwastyk understood the' pressure spike to be caused by a combus-tion of hydrogen caused by a zirconium-water reaction, for the 94

following reasons:

-( ( )

1) In a May 21, 1979 interview, Chwastyk does not mention hydrogen or core damage.

Dieckamp ff Tr.

28,316 a t 14;

2) In an October 30, 1979 interview, Chwastyk does not identify it with a specific assessment of core damage although he refers to a hydrogen explosion. Tr. 28,857 (Chwastyk);

3)

In a September 4, 1980 interview, while mentioning both a a zire-water reaction and "some core damage" Dieckamp can establish no " absolute proof" that Chwastyk understood the pressure spike to indicate core dsmage, Dieckamp f f Tr. 28,316 at 16.

262.

Dieckamp has entirely distorted the issue, from whether the Chwastyk interviews indicate "some evidence" to the question whether they cons t i tute " absolute proof."

Moreover, we 4

simply cannot understand how Dieckamp reached the conclusien that Chwastyk did not understand the significance of the spike. Simpij

_O because Chwastyk did not take the time during the afternoon of March 28, 1979 to complete a complex analysis of core damage is no basis to assume Chwastyk did not understand the hydrogen burn.

263.

Further, Chwastyk did not use the words " hydrogen" or

" zirconium-water reaction" explicitly in his earlier interviews because specific questions were not asked of him.

Chwastyk in fact _ testified that everyone at that point in time understood that TMI-2 had suf fered serious core damage,.so there was no need to mention it. Tr. 29,213 (Chwas tyk).

264.

Dieckamp maintains today that Chwastyk did not under-stand the pressure spike to indicate core damage or a zire-water reaction, even though he concedes that Chwastyk appeared to

. {

, correlate the cycling of the EMOV wi th the spike. JME l-C (88) at I

19-21; JME l-C(99) at 14-15; Tr. 28,847; 28,849-853 (Dieckamp).

95

f Further, he was aware of hot leg temperatures greater than 700

(

degrees, high incore temperature readings and high radiation levels, conditions which together would lead one to consider the

. possibility of a zirconium-water reaction.

Tr. 28,860-865 (Dieckamp).

265.

The Board finds that it reflects poorly on Dieckamp's 1

integrity that he refuses to acknolwedge the Chwastyk, Mehler and Illjes' interviews as "some evidence," since they each explicitly state some understanding that the pressure spike indicated a hydrogen burn and core damage.

266.

Moreover, Dieckamp's position entirely fails to incor-porate the findings of an internal company inquiry into the mat ter, which indicates that Licensee employees properly inter-O vret a t" pre=="r

=95* -

"hea coarroatea -ith tai = iatera 2

(

company I'nvestigation, Dieckamp testified that it did not change his mind about the accuracy of statements in his mailgram. Tr.

28,888 (Dieckamp).

267.

Under cover of a-September 17, 1980 memorandum Licen-sing Manager Ed Wallace transmitted to Arnold all information of which he was then aware regarding the company's understanding of core damage following the TMI-2 accident.

One of the attachments to this memorandum is an " Untitled Piece" completed by Bill Behrle, Scott Guilbord and Don Reppert on Arnold's.-direct ion.

In that' attachment, under a heading " Licensee's Knowledge" of " Core Damage / Fuel Uncovering" appears, in relevant part, as follows:

On Wednesday, Chwastyk (Shift Supervisor) was aware of high incore Thermocouple readings, assumed there was some core

,l i

damage, realized magnitude of problem when it.took 50,000 gallons of HPI to fill the 88,000 gallon RCS, and knew there 96 w

u

r l

was core damage fran the explosion in the building.

(}

TMIA Mailgram Exh. 15 at 2, 13..

268.

Later in this same attachment under the heading

" Licensee' Knowledge" of the " Pressure Spike / Hydrogen" the following is written:

Two of the licensees employees (Chwastyk and Mehler) who were aware of an actual pressure spike may have believed on Wednesday that it was due to a hydrogen explosion.

Id. at 17.

269.

The untitled piece appears to be an analysis of the various NRC and other interviews of licensee employees up to the time of the. September 1980 memorandum.

Given that. Arnold had directed that this analysis be conducted, and given that at least

.some of the individuals responsible for the analysis also kept 4(])

close track of employee interviews for the company, (Behrle, Wilson and Reppert) as a part of their regular business duties,

~ the Board attaches great weight to their conclusion that some licensee ~ employees may have understood on the first day of the accident that the spike was caused by a hydrogen explosion and indicated core damage.

270.

Since Dieckamp.acknowledgee that he performed no such detailed analysis, :Dieckamp ff Tr. 28,316 at-12, the Board finds it incredible that he so cavalierly rejects the analysis specifi-cally ordered by Arnold.

It' appears to the Board that no matter how great the volume of evidence presented to Dieckamp, he would refuse to acknolwedge that licensee employees and managers under-stood the significance of the pressure spike at the time it occurred.

97

D. The IE Investigation and Report on Information Flow During tiie TMT Y Acc13ent

(

271.

Dieckamp relies on various investigative reports to support the " thrust" of his mailgram that the pressure spike was not understood at the time it occurred.

Dieckamp ff Tr. 28,316 at 16-17.

However, none of the reports cited, except the NRC investigation into information, flow specifically focused on the issue of whether information, including that concerning the pres-sure spike, the hydrogen burn and core damage, was withheld from NRC and Commonwealth of Pennsylvania authori ties.

272.

The NRC Staff presented testimony from Norman Moseley, i

investigative team leader for the Office of Inspection and Enforcement Inves tigation enti tled "Inves tigation Into Informa-tion Flow During The Accident At Three Mile Island," NUREG-0760

( h (1981),

to' support the NRC S taf f's pos i t ion that although Dieckamp's mailgram's was inaccurate, Dieckamp did not intention-ally make false statements in the mailgram.

Mr. Moseley's tes t i-5 many was based entirely on information he derived in the course of the NUREG-0760 investigation.

Tr. 29,832 (Mosely).

273.

TMIA presented testimony f rom former NRC investigator

+

David Gamble, who participated in the NUREG-0760 investigation.

Gamble testified that the NRC inquiry was sharply curtailed and its conclusions pre-determined and not supported by the facts. In light of what we find to be credible and convincing testimony from Gamble we attach no weight to ei ther NUREG-0760 or Moseley's testimony.

Therefore, we find that NUREG-0760 provides no sup-for Dieckamp's position.

O

. port 274.-

In essence, Moseley testified that he believed 98

Dieckamp was sincere when he stated in his mailgram that no one

(,-)

interpreted the pressure spike in terms of core damage.

Moseley f f Tr.29,816 a t 4.

Moseley supported this statement with his observations of Dieckamp in the course of an interview conducted of Dieckamp for the NUREG-0760 inves t iga t ion; Moseley's conclu-sion that no one present in the TMI-2 control room understood on Ma rch 2 8,1979 that the pressure spike was caused by a hydrogen burn; and Moseley's belief that "it was beyond the range of credible operator knowledge to infer that amounts of hydrogen sufficient to reach a flammable concentration in a two million cubic foot containment might exist at 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after the initia-t ion of the event."

Ibid.

275.

Moseley's testimony that the thrust of Dieckamp's mailgram was accurate, was not supported by the facts uncovered

(

in the course of the NUREG-0760 investigation.

Mosely stated i

that Chwastyk, while a credible witness, was inaccurate in his recollec+'on at the time of the spike, he attributed it to a hydrogen burn.

Tr. 29,839 (Moseley)

Moseley bases this on the fact that Chwastyk, to his mind, had trouble dif ferentiating the time he knew certain events occurred.

Tr. 29,969 (Moseley).

However, Moseley could not cite a single interview in which l

Chwastyk demonstrated such confusion Tr. 29,973 (Moseley).

l Moreover, the Board knows of none.

l

[

'276.

Moseley also concluded that Chwastyk did not u'nder-l l

stand that a zire-water reaction caused the burn and spike.

Yet

'Mosely never questioned Chwastyk about his training on the zire-

!.(

water reaction or his understanding of Appendix K; whether he had 1

read any books on the zire-water reaction; or whether he had 99

(-

g considered sources for the hydrogen other than as a product of v

the zire-water reaction.

Tr. 29,837-838.28 U

"8' Similarly, Moseley never looked into training generally at TMI-2 to determine if there was training on the zirconium-water reaction or ECCS criteria.

Tr. 29,872 (Moseley).

Therefore it A

is hard to understand how he could assert that it was not wi thin W

the range of credible operator knowledge that hydrogen could be produced up to flammable limits within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months af ter an initiating event.

100

277.

Second, Moseley's observations of Dieckamp during his 4

one strike the Board as peculiarly unreliable.

First of all, the O

inte, view itseif provided no opportunity to test Dieekamp s ered-

.ibility.

The questions which Moseley asked Dieckamp were gener-l ally conclusory, and asked for opinions not for facts.

Tr.

29,898-900.

Secondly, Moseley approached the interview, which focused on the mallgram, with an extremely narrow working defini-tion of material f alse s tatement -- that i s, one submitted to the NRC in some of ficial manner, Moseley knew at the time he inter-viewed Dieckamp that he would not find the mailgram to be a l

material false statement. Tr. 29,893-897 (Moseley).

288.

Third, the Board observed that Moseley appeared to find the entire issue of the Dieckamp Mailgram beneath his atten-tion.

Moseley appeared to be more interested in protecting Dieckamp than in determining whether information about the pres-sure spike and hydrogen burn had been improperly withheld from the Commi ss ion.

~

the malIgram contained 289.

Although he determined that inaccurate statements, apparently Moseley.never bothered to tell l

the Commission.

Tr. 29,846-847 (MOseley).

Further, Moseley testified that he believed Dieckamp should have correted the l

l mailgram.

Tr. 29,946.

However, he explained that it was a rather minor inaccuracy even though it had consumed great NRC l

Investigative and hearing resources.

Tr. 29,946.

When asked why 1 1

.he believed Dieckamp should have. corrected the mailgram, Moseley explained simely that it would have saved himself a lot of grief.

Tr. 29,976 (Moseley).

The Board finds that Moseley was not

~

sufficiently concerned in his investigation about the adequate 101 r

l l

flow of information to the NRC.

A

(,/

290.

On the other hand, we find Gamble's criticisms of the IE investigation and report to be incisive and determinative in our decision not to afford NUREG-0760 or its conclusions any weight.

Gamble was an int est igator f rom the NRC's Of fice of Inspector and Auditor assigned to the investigation to protect the interests of the Department of Justice, to ensure that any information be preserved which might be useful to any future criminal prosecution. Tr. 30,510, 291.

He made the following serious criticisms of the inves-tigation:

1)

Moseley directed that the three major portions of the investigative report be drafted prior to any significant investigation;

2) Moseley attempted to restrict full and complete e

questioning of witnesses by imposing a protocol where interviewers could only ask questions on a pre-approved list; follow-up questions by other than the chief interviewer were permitted only at the end and after being approved by Moseley; and in some cases by entering into agreement with corporate counsel whereby the areas of question were restricted.. Gamble f f Tr.

30,587 at 3-5; Tr. 30,548; 30,559; 30,561-564; 30,579-580; 30,660 Gamble);

3)

At least one original member of the Task Group, Ronald Haynes, appeared to have a conflict of interest.

Tr. 30,729 (Gamble);

4) Significant information which was already on the public record was never discussed during the course of the investigation and did not appear in the final report.

Tr. 30,5 31; 5)

Moseley did not employ investigative techniques which would have ' led to a better development of the factual record.

Tr. 30,706-711 (Gamble); TMIA Mallgram Exh. 22, Enclosure 2.

292.

Gamble's cri ticisms lead us to find that the conclu-sions of NUREG-0760 are net supported by the facts.

Moreover, 102

(

Gamble's criticisms of NUREG-0760 provide further reason for titis Board's refusal to credit the conclusions of that report.

These O

include:

1)

Significant facts were left out of the final report 4

or not fully developed, Tr. 30,532; (Gamble);

2)

The repo r t's characterization of Plumlee's testimony did not give it adequate weight, Tr. 30,714-719 (Gamble);

3)

The Task Group's conclusions were not adequately supported by the facts, including conclusions rega.rding whether anyone in the Unit 2 control room properly interpreted the pressure spike, Tr. 30,804.

(Gamble)

See TMIA Mailgram Exh. 24 at 1.

293.

We give no weight to NUREG-0760, its conclusions or Moseley's testimony on the issue before us.

E.

Lowe's Alleged Discovery of the Significance of the Pressure Spike Late on March 29, 1979.

294.

Licensee argues that Dieckamp was entitled to rely in

()

ser. ding his mallgram, on his understanding that William Lowe was

{

the first to correctly interpret the pressure spike to indicate a hydrogen burn and core damage.

Dieckamp f f Tr. 28,316.

Lowe claims he was the first person to discover the significance of the pressure spike at 11:00 p.m. on March 29, 1979.

295. Lowe testified that on March 29 he followed Unit 2 Superintendent Joseph Logan into the Control Room when operators l

l had lost control of the pressurizer level.

At that time Bensel showed him the containment building pressure strip chart trace showing 28 psig at 1:50 p.m. on March 28, 1979.

Lowe says that he concluded immediately that the spike was caused by a hydrogen ignition and the hydrogen had been produced from a zirealloy-water reaction.

Lowe testified that he asked for a second pres-l

{

103 I

i L

'l

-sure reading and was pointed to the wide range trace at the bottom of the same chart.

He also reviewed building temperature traces which confirmed the spike.

Lowe, Thomas Crimmins and Moore then calculated the bubble size and the amount of zirconium cladding which would have to oxidize to produce that amount of hydrogen.

Lowe contends that from these calculations they con-cluded the core was very seriously damaged. Lowe f f Tr. 6-7; 11-13.

296.

The Board is not convinced that Lowe was the first person to discover the significance of the pressure spike.

We have seen substantial evidence in this proceeding hearings that both Met-Ed operations personnel and GPUSC engineers reviewed and understood the significance of the spike on the first day of the accident.

297.

Further, we believe that Lowe's testimony itself con-tains many contradictions.

For example, although Lowe now con-tends he was the first to correctly analyze the spike, in a conversation in 1979 with a Special Inquiry Group investigator he explained in response to a direct question that in fact he did not know whether he was the first to recognize the significance of the spike.

Tr. 28,154-155; 28,157-158 (Lowe); JME l-C-104.

298.

Moreover, his prefiled written testimony is clearly misleading in seriously understating his understanding of the seriousness of the accident on March 28.

Lowe states in his testimony that Thorpe informed him at about 4:20 p.m. on March 28

' t h a t'

" core cooling is recovered".

Tr. 28,160; Lowe ff Tr. 28,151

(]

a t 3.

Yet according to a memo Lowe dictated to the file on March 28, Thorpe in fact reported to Lowe at that time, that " Plant 104

thinks core is recovered, but proof not yet es tabl ished." TMIA

()

'Mailgram Exh.

1.

299.

The Board understands Thorpe's statement in this memo-randum to indicate that at some time prior to 4:20, Licensee's staff believed the core was uncovered.

The language in this memorandum is not susceptible to Lowe's peculiar rephrasing that cooling of the core has been restored or reinitiated.

Tr.

28,159-163.

Lowe's artful phrasing of Thorpe's assessment of the status of the plant at that time downplays the seriousness of the accident and casts doubt generally on Lowe's credibility.

300.

The Board also finds Lowe's story incredible because it appears that there were general discussions about the pres-sure spike, hydrogen burn and hydrogen build-up in the reactor building during the afternoon of March 29, fully eight hours prior to Lowe's alleged revelation.

The first meeting of the Task Force was held at 3:30 p.m.

on March 29 in the processing center at Unit 1.

According to Lowe's calendar of activities for the early days of'the TMI-2 accident, the Task Force was divided into two " teams".

The Events Analysis Team was composed of the i

following persons:

Richard Wilson, Chairman F

l Ed Wallace Donald Reppert Gary Broughton l

-George Kunder James Moore (f

Lee Rogers 105 l

The Recovery Planning Team was composed of:

(

Ron Williams, Chairman Thomas Crimmins William Lowe D..Klingeman (not present)

Robert Long TMIA Mailgram Exh. 18 at 3.

301.

As discussed in section III, supra, Wilson opened the meeting by stating that the company had assumed there had been core damage in the range of $20 to $30 million, and that a one-year outage was anticipated.

Although different individuals attending the meeting have differing recollections about the meeting, what is striking is that the pressure spike, hydrogen i

burn, O

or production of hydrogen to flammable limits was discussed in some manner.

302.

Abramovici, for example, stated a concern that there was a hydrogen build-up.in the reactor building to four percent which led to a discussion about hooking up a hydrogen recombiner.

p TMIA Mailgram Exh. 32H; JME l-C(5- ) at 12-13.

See also JME l-C (78) a t -128 (Floyd).

311..

Broughton and Wilson r.ow,. - no discussion about the 9

108 k)

pressure spike or hydrogen burn at the Task Force meeting at 3:30 p.m. on March 29. Tr. 31,159 (Broughton); 31,530-531 (Wilson).

312.

The Board finds f rom the testimony of Abramovici, Kunder and Crimmins, that there was discussion of the pressure spike and hydrogen burn at the March 29 afternoon meeting of the Task Force.

Further the pressure spike trace may have been reviewed at the meeting.

This conclusion is compelled by the consistent testimony of these three central individuals who came from different corporate organizations..

The Board also con-cludes that the group discussed setting up of a hydrogen recombi-ner to deal with hydrogen greater than the containment building design limit of four percent.

There appeared to be general understanding by members of this group, including Lowe and Kun-der, that the only means to produce within two days hydrogen I) greater than 'the containment design limit was by means of a zire-water reaction.

Tr. 30,075-077 (Kunder); Tr. 28,197-200 (Lowe).

Therefore we find that members of the Task Force, including Lowe, Broughton and Kunder, determined as early as 3:30 p.m. on March 29, that the pressure spike was caused by a zirconium-water reaction which produced build-up of hydrogen to flammable limits.

313.

We do not find credible Licensee's claim that Lowe was the first to understand the pressure spike during the late even-ing of March 29 not1 credible.

We ffind further that that this theory-falls to support Dieckamp's claim that the " thrust" of his mailgram is correct.

F.

Infornation Available to Dieckamp Prior to May 9, 1979.

314.

The Board finds that several operator interviews available to Dieckamp prior to May 9 Indicated that the opera-109 t

tions staff ff interpreted the pressure spike to be an explosion and in response took steps to repressurize the reactor, a serious departure from the strategy they had previously employed.

These interviews indicate to the Board "some evidence" that the spike 4

was properly understood to have been caused by a hydrogen burn.31 G. G)NCLUS ION.

320.

We find Dieckamp should have known that the statements in his mailgram were, and are today, false.

Moreover, with minimal investigation, he would have discovered that licensee personnel properly interpreted the pressure spike as a hydrogen burn and and in response changed to repressurize to stabilize the reactor.

The Board finds unconvincing licensee's arguments in support of the " thrust" of Dieckamp's mailgram.

321.

Licensee has continued to defend the accuracy of the maiIgram.

The Board belleves that Dieckamp and Iicensee's in-transigence on this point, given the extensive evidence presented of Met Ed and GPU Service Corporation awareness of the signifi-

-cance of the pressure spike on March 28, 1979, reflects poorly on management competence and character.

I V

DIECKMfP SHOULD HAVE CORRECTED THE MAILGRAM ONCE HE DETERRTRED'TRAT 37XTE@Tfr37 TRE-@lLMAYMTFALSE.

322.

Licensee argues in fts Proposed Findings that t

l

"[g]iven the fact that the mailgram was accurate when sent, that i

its thrust remains a reasonable conclusion today, and that all subsequently adduced contrary evidence was fully known by all concerned, it was certainly unnecessary for Mr. Dieckamp to I

inform the mailgram recipients that the prefatory phrase 'there Q

U is not evidence' was no longer l i t eral."

Licensee's Proposed 110 l

t

i Findings of Fact and Conclusions of Law (January 28, 1985), at

'.)

94.

323.

None of the statements contained in the above conclu-sion is true.

As discussed in Part II, supra, the Board believes Dieckamp did possess evidence, and in fact positive knowledge, that Met-Ed and GPU Service Corporation personnel properly i

interpreted the pressure spike as a hydrogen burn on the first

{-

day of the accident. Therefore Dieckamp knew at the time he sent it that he was making false and inaccurate statements in the nellgram.

324.

Even if he did not know on May 9, 1979 the statements were false, the reality is that on May 9, 1979, persons such as Chwastyk, Mehler and Illjes had properly interpreted and re- sponded to the pressure spike at the time it occurred. If Dieckamp had done any investigation he would have discovered this substantial evidence at that time. See Section IV, supra. L 325. Moreover, Dieckamp's statement that the " thrust" of the mailgram is correct although the words may be literally false i makes no sense to this Licensing Board. Licensee and its top management are obliged to be meticulous in fully disclosing all material information within their possession to the NRC in order for;the NRC to carry out 'its mission to protect the public health .and saf ety. Tha t responsibility cannot be-any more important than during an accident. Thus licensee's f ailure' to provide informa-tion about the pressure spike and hydrogen burn to the Commission on March 28 seriously compromised the Commission's ef fectiveness in carrying out that mission. This fact licensee does not appre-111

1 i I ciate, even today, after multiple investigations, inquiries and hearings on this matter. VI CONCLUSION. 326. The Board concludes that Dieckamp's mailgram of May 9, 1979 contains false statements since licensee personnel did properly interpret the pressure spike and containment sprays to indicate a hydrogen burn and core damage. Moreover, the highest i. levels of licensee m:nagement, including Dieckamp, were aware of the pressure spike and its significance by early on March 29. Yet licensee f ailed to disclose this information to the NRC or to Commonwealth of Pennsylvania authorities until March 30. The Board therefore finds false Dieckamp's claim in the mailgram that the're was'no withholding of information. 327. The Board has also found from the extensive record . developed in this hearing, that Dieckamp knew that his mailgram was f alse at the time he sent it since he was informed during the f f af ternoon of March 28 by Herbein, Miller'and Kunder of their understanding of the pressure spike, and later on the morning of March _29 through Keaten of the GPUSC group's evaluation of the hydrogen burn. 328. Even if Dieckamp did not know on May 9, 1979 that the statements in his mailgram were f alse at the time he sent it, he should have known given the extensive information available to the company that licensee employees understood'the pressure spike to be a hydrogen burn and responded by changing to a repressuri-zation evolution. A minimal investigation would have uncovered .O the simaie faet that the maiieram co#taiaea rai e tateme t - i 329. We conclude. licensee management has demonstrated ex-112 l

tremely poor character in continuing to defend false statements () in Dieckamp',s mailgram of May 9, 1979. Licensee's refusal to accept reporting responsibilities to the NRC demonstrates a basic lack of integrity which prevents this Board from finding licensee management has adequate integrity and competence to operate TMI-2 safely. Respectfully submitted, .f f f C m v oanne Doroshow The Christic Institute , 1324 North Capitol Street Washington, D.C. 20036 / 7 Y O-p / b. 4 7h h / Ly e Bernabei Geor e Shohet Government Accountability Project .ISJ5 Connec t icu t Avenue, N.W. Mi te 202 Washington, D. C. 20036 Attorneys for Three Mile Island Alert DATED: FEBRUARY 8, 1985 113

1 l z O APPENDIX A Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors. 39 Fed. Reg. 1,002 (1974) (codified at 10 C.F.R. S50.46); 36 Fed. Reg. 24,082 (interim criteria); 36 Fed. Reg. 12,247 (interim criteria). hi

1k 9 e 3 002. g ' hamperature of the aircalor cladding _ RULES AN) RECULATIONS x, ' evidence that more of the stored heat 8 50.M Aeneptance Crieeria for Em.e. f abould not exceed 2300*P, is replaced by. would be removed than calculated, al. semey Ome Coeling Synaeme fee IJsha y two criteria, lowering the allowed peak though there is not yet an accepted way Water Neelear Power Reactors. -

w. '

aircaloy temperature to 2200*P and pro. of calculating the heat transfer more (a)(1) Except as provided in para-viding n limit on the maximum allowed accurately. It is probable that this repre* graph (a) (2) and (3) of this section Ic a! oxidation. The other three criteria sents a conservatism of several hundred 1IAC are retained, with some modi. degrees P. in stored energy after blow. each bolling and pressurized light-water n of the wording. These three cri. down, most o' which can reasonably be nuclear power reactor fueled with urana-um oxide pellets within cylindrical E t the hydrogen generation from expected to carry over to a reduction in Inetal-Urter reactions, require Inainte. the calculated peak temperature of the Zircaloy cladding shall be provided with an emergency core cooling system nance cf a coolable core geometry, and r.irealoy cladding. IECCS) which shall be designed such provide for long-term cooling of the (3) Rate of heat generaffon. It is as* qu;nched core. sumed that the heat generation rate that its calculated cooling performance - O The most important effect of the from the decay of fission products is 20 following postutated ioss-of-coolant acci. h (hanges in the required features of the percent greater than the proposed ANS dents conforms to the criteria set forth in paragraph (b) of this section. ECCS tech cvaluation models is that swelling and standard. This represents an upper limit bursting of the cladding must now be to the degree of uncertainty. The as* coohng performance shall be calculated LA B l taken into consideraticn when they are sumption that the fission product level in accordance with an acceptable evalua-saon l calculated to occur, and that the mazi. is that resulting from operation at 102 tion model, and shall be calculated for a ' M' anum temperature and oxidation criteria percerst of rated power for an tnftntte number of postulated loss-of-coolant ac. $; 36 F 13must be applied to the reigion of clad time represents an improbable situation, eldents of different aises, locations, and e ?I8II swening or bursting when the maximum with a conservatism that is probably in other properties sufficient to provide as. U . temperature and oxidation are calcu. the range of 5 to 15 percent, ne use of aurance that the entire spectrum of " erst . lated to occur there. Another important the Baker-Just equation for calcule'ing postulated loes-of. coolant accidente is ' ehanne is the requirement that, in the the heat generation from the steam oz!. covered. Appendiz K. ECCS Evaluation

k. OI E T tion steady state operation just before the dation of zirealoy should also provide Models, sets forth certain required and L (D) postulated accident, the thermal con. some conservatism, but the factor is acceptable featt.res of evaluation models.

A. are, ductance of the gap between the fuel uncertain-Conformance with the criteria set forth OI t' in paragraph (b) of this section with pellets rnd the cladding should be cal. (4) The reak temperature criteriott. cul ted taking into consideration any The limitation of the peak calculated ECCS cooline performsnee calculated in P* Increase in gap d.me:ulons resulting temperature of the cladding to 500* F accordance utth an acceptable evaluation from such phenomena as fuel densin. and the stipulation that tids criterlon be mc<tal, may require that restrictions to A eation, and should also conalder the ef. app!!ed to the hottest reeton of the hot

imped on reactor operation.

S' fects cf the pre *ence of fission rsnes. test fuel rod provide a substantial degree i2n With rupect to resetors for susch D When these egects are taken into con. of conservatism. They ensure that the operating !! censes have previously been 9" sideration a higher stored energy may core would su3er very 12ttle damage in issued and far which operating licenses be calculated. Other changes in the the accident. tiny stue on or before December 28.1974-i L evaluation models are mostly in the Pur uant to the Atomic Enargy Act of it s The time within uhleh actions re-I direction of res. lacing predeus troad IM4, ts aminded. and <ecuons 552 and quired or permitted under this subpara-C' conservat;ve assumptions with mme de. SU of title 5 of the United States Code..; rad (2r a-*:st occur shall begin to run tailed calcu!auens shere new excertmen. the following amendments to Title 10, on 30 days a!!er pubucatloc of the rule in the Ftorut. Itzersm. tal trformation is availab'e or s here bet. Chapter I Code of Federal Regulations, tub Wehin sit months following the tere 9ulational methods have been de. Pjtrt 50, are published as a document Te i Alb!ect to coddcation to be erective on date specified in parneraph ta)(2t ill of L/ Wording of the dennition of a loss. February 4.1974. this section an evaluation in accordante M with paruraph (als!) of this section Cf-coolant accident has been mad 1%d to

1. A new lenience is added to i 50 34 shall be subnutted to the Director of conform to it4 :en d-accapt*d u.; ale, lim.

431'4 of 10 CFIt Part So to read as Iting it to breaks in r! pes. The nc v ree-follow 8: Regulation. The evalustion shall be ac-ul*31ons also require a more complete companied by such proposed changes in I documentation of the evaluation models g p,3 g r,,n,..n,. og.p,J;,,,,;on., r,y g,. technical sperinca tions or license amend-f C n;ol ;n form.ition. enents as may be necessary to bring rese-that ara used. tor operation !n conformity with para-h3 Commmion be!!aes that the im. 'ag.,, graph s aill! of this section. plementatten of *De new regubttons will a s n anja s hn Any Ikeruce may request an ed c i ensure an a&quite mar;tn of.erform-m ance of the ECC3 Jhod!d a demu bass !wtuNed !N of-coolant accidents shall tensjon of the six month period referred pgg g IOCA ever occur. This marmn is pro. [ ormed n for good came. Any such request shall Le vided by ecnservative itatures of the 5 6 f t cvaluation models and by the criteria which constructicn permita gnay be is-subndtted not less than 45 days prior to themselvIs. Some of the major pointa sued after December 28,1974. expiration of the six-month period and shall be accompanied by af5 davits show-thit contribute to the conservatine na. ing precisely why the evaluation i.s not ture cf the evaluations and the criteria

2. A new sentence is added to i 50.34 complete and the minimum time believed 3

are as fouous: (b)(4) 10 CFil Part 50 to read as follows: " (1) Stored heaf. ne assumption of necessary to complete it. 'nte Director of 102 percent of maximum power, highest $ 30.3 8 Contents of applicationat tech. Regulation shan cause notice of such a ?. nical information. request to be published promptJy in the l ' allowed peaking f actor, and highest esti-FEDERAr. Rzctsyre such notice shan pro-manted thermal resistance between the UO. and the cladding provides a calcu-ib) *** vide for the suhmiulon of comments by lated stored heat that is possible but (4) * *

Analysis and evaluation of interested persons within a time period unibly to occur at the time of a hy. ECCS cooHng perfortnance fonowing to be estabushed by the Director of Regulation. H, upon reytewing the fore-t pothetical accident. WhlJe not neces, postulated loss-of-coolant accidents

.sarily o margin over the aztreme.co%g. shall be performed in accordance with lationconcludesthatgoodcausehas been J., ? going subminfons, the Director of Regu. it represents at least an assumption the requirements of I 50.46 for faci!! ties g -an accident happens at a time for which a 11 cense to operate may be shown for an extension he may extend which is not typteal. lasued after December 28,1974, the alz-numth period for the shortest ? P (2) floto-dones. he calculation of the additional time which in this judgment p

~

win be namamary to enshte the licen888 S heat transfer during blowdown is made

2. A new 150.46 is added to 10 CFR to furnish the =Amhabne required W -

y, in O very conservative manner. Dere is Part 50 to read as follows: paragraph (sH2HID of this section, Re= e. (* PsDBAt el41571a, V0t. 39, NO. 3-JetDAY, JANUARY 4 MF4 . E, ? 1 L.

2 RULES AND REGULATIONS 1003 se Emw. quests for extensions of the ais. month other thinsa, that the proposed facility puter programs and all other informa-f*' ( penod. submitted under this subpara-meets the requirements of subparagraph tion necessary for appWaHan of the enl-graph, shall be ruled upon by the Direc- (1) of this paragraph.. culational framework to a specine LOCA. a para tor of Regulation prior to expiration of (b)(D Peak claddisig temperature. such as mathemattoal snodels used, ses that period. 'Ibe calculated mawimum fuel element tt. tty) Upon subminatan of the evaluation cladding temperature shall not exceed sumptions included in the programs, pro ' b required by subparagraph (11) of this sub-2200* F. ' eedure for treating the program kaput tindricaf paragraph (2) (or under subparagraph (2) No.rimum claddisp oxidsfion.'Ibe. and output information, apac*ation of led with st116.1f thesix-monthperiodisextended) calculated total oxidation of the clad-those portions of analvsis not inchaded la estem the facility shall continue or commence ding shall nowhere exceed 0.1'I times the computer programs, values af param - =d such operation only within the limits of both total cladding thickness before oxida-eters, and all other information noems-rmance; the proposed technical specifications or tion. As used in this subparagraph total sary 40 specify the calculational proce-It accl..n license amendments submitted in accord. cxidation means the total thickness of (d) The requirements of this section dure. '.t forth A ance with this subparagraph (2) and all cladding metal that would be locally con-are in addition to any other requirem ICC8 Z technical specifications or license condi-verted to oxide if all the oxygen absorbed applicable to ECCS set forth in t eulltedI trons previously imposed by the Commis. by and reacted with the cladding locally The criteria set forth in paragra

Talua. $

aaon. including the requirements of the were converted to stoichiometric tirconi-with cooling performance calcula d for o ?- Interim Policy Statement fJune 29.1971, um dioxide. If cladding rupture is calcu. tnt ac. ^ 36 FR 12248), as amended (December 18, lated to occur, the inside surfaces of the tion model, are in implementat accordance with an acceptable evalua. S. and - 19~1. 36 FR 24082), cladding shall be included in the oxi-de as. er s Further restrictions on reactor op. dation. beginning at the calculated time general requirements with respect to im of cration 3-111 be imposed by the Director of rupture. Cladding thicknere bcfore ox. ECCS cooling performance design set 2 14 la cd R6ulation ifJ2e finds that the evalua. Idation means the radial distance from forth in this Part. includmg in particular .t, tion

v submitted under subparagraphs insidt to outside the claddtne. after any Criterion 35 of Appendix A.

6 cn,g .L and (lid of this subpararaph s2: calculated rupture or estiling has oc.

4. A new Appendix K !s added to 10 odeh.

re, n3t corui= tent with subpararrach (!> curred but before altr.ificant cx!dation CFR Part 50 to read as follows:

font, d G.t persgra: h L ' r.nd r.= a reW: such Where the ca?cuh.t e d conitions of Arrmrx fc-Eccs Eva:.ranon Moorts citt r.

t'one are sq.t d ta protect the tr:. nut.' prenure snd temperCute lead 1 Require.d and Acceptable Features or wd in )

.. he Mth.n 's: .f t u to a prediction of tladd.ng s9 dimr with y"{'

.. t tor l hema tr - from tha opcNttng or tilhout rh.ddin': rapturt. the unoM- ,,g L.: be q t m. J mer ' ( f IW13.t a;rr ph m ) of dized claddm;: tluck.ee sha'l be defined

3. ar.orruto ar r acec=raett rearrars or t..

subpar.arrr.Th 82' rr. V be gratsted a the ch.dd;n? ctoss-secticinal ater. tak. T'rt rvatvanon roact.a }ut t t. 9.t Comnm. ::r. ic.r goed c6uu. hp. en at a horizontal piane at the eltva. ins.. c y as ico su-b o t mritrn sh:li tw sub. tion of the ruptute. if it o: curs. or at the the her.t suur e Itsted in paragraphr 1 to e A Sorr er. o.t nec* ductr.r tar LOCA For i unw.

. %.- ta i k-thu. 45 dan pnor to eleu.tna e' the h: chert ch-ddine tem-belew it au.', be ruined that trae reactor f.74 I

t: cat < uW. v.l.U h the idant would per.tutt :f no rupturc ir calcul:ted to or. Las been treraur.t continueus'.e er a powe- } oL..N N t e leured tn opctr.te is ac-cut, dit ded by the atersp circumfer-3'j rg - 3,(, ' j ] a rt.- cad. Ant e rath th( prortdures of said ence r t that e'evat.on v 3 on ruptured ch.d. run. c a.LNrarra) h ini. Any such re::uert ding the circumference does tact include strun.eut uou error), witt. the martmum -pl) ru'e Sha* be fijed vi:h the Secretary of the the rupt urc openina. peaHnr facto

anewes by t;.e technica3 C: nmhdon vi.o shM1 cause notice of (3 E!crtmum h W ocen ocn cra f b71.

stapee sue peakt w factors repre= entire sneetr eattom. A rance c.f posvr distrmutton ths it recei;-t to be rubbshrd promptly ir. The calculated total amount of hydrogen reser ot f tthuttom that n ar occur over the cf the Trrrr>t. Ern!rra : such notice sl'ar. geturated from the chemteal reacticn of core tuetin:e st an be studied and the one ree 3: .de fcr the tutmisMon of commer.t. tht chiddmr with watcr or stearn shall eclecte d shoute be that u nset resul ic., L: Inten tsted per3on3 within 14 dar.s not esteed 0 01 times the hypothetical ,"h*t c1 Ig.n; PcognL Rretstem publication. amount that would be generated if al of e eaks and aan e re. L.e D.rttter of Re utatinn shnh submit the met:.1 in the cladding cyhnders sur. ranure., e yeco 12. f..' r.cs s at to r.nr requt sted exemption roundmg the fuel. excluding the claddm; The steady atste temperat ure etstr 3, ts., in:rta! Stored Enem in the ri.et t s.dA fhe day IN!ouin; eXTiration of surrcundm; the plenum volume, sere and sto ed enerry L. tr e fue: betere t th* 0;niment pt r.: / c. to geut pothettra; acciden' sha!! be calculated fo? ' vu ' Any rsour't fcr an eu mptian t 4 ' Confob.'c prom ef rr. Calculated the burr..up that yie!ce. the htet eat enteu-7 20.:t ted under subparanaph w chan:c. Au core Fcomctry shall be such 1[ed eyd$.r.(t$1= att re to-c' tn!r subpar 4rait (2' must shotv, that the core ternauts s.menabic to cool-ep ana: e. u g g td

-~ appsopriate afLdsvits and te

hni. Ing.

accornpitah this. the the ma conductivstr et ca submivions, that it would be in the t5: Lorap ferm coohno. After any cal-burn.up, thatt be eratuated as a runction or the co pubhr interest to allow the licensee a and temperature. taatng into con-x spec 1 Sed additional period of time with. culated successful initial operation of to 1 the ECCS, the calculated core tempera. anderation diserences in initial density. and ud *.. in which to alter the operation of the ture shall be maintained at an accept. Sb* UO. and the cladding shall be een3uated the thermal conductance et the sap between lacility in the manner required by sub. ably low value and decay heat shall be as a tunetam or the bm-up. aunt tato 4.L.(. 4 ' paragraph (iv) of this subparagraph (2). removed for the extended period of time sonsiderauma ruel denmacasson and espan. gg. ' 'Ibe request shall also include a discus. fg< alon of the alternatives available for ps. required by the long-lived radioactivity M " Cu'"drod Qin"s~* Id N Fema!ntng in the tnre. o g2 tablishing compliance with the rule. (c) As used in this section: dimenalon with sta tolerances, and cladding c~' (38 Construction permits may be is. (1) loss-of-coolant acc1 dents

2. rsesion Rest. Ptssion beat aban tw cat.

crwp. i nued after December 28.1973 but before (IDCNs) are hypothetical accidents eulated using reactivity and reactor asnetten De ember 28. 1974 subject to any ap. that would result from the loss of reactor shutdoun reactivittaa tuutting trom t phrable conditions or restrictions im. Wed pursuant to other regulations in coolant, at a rate in excess of the capabil. pnaturn and v ida aban tw stun their 165 chepter and the Interim Acceptance ity of the reactor coolant makeup sys. tem. from breaks in pipes in the reactor g","g[*M3*'r"

P tles Criteria for Emergency Core Coo!!ng coolant pressure boundary up to and in* distribution shapes and peaking factors nn.

Sutenu published on June 29. 1971 (36 clud!ng a break equivalent in size to the dicated to be studied abote. Rod trtp and in. F.R 122488 as amended (December 18 double-ended rupture of the largest p!ae to occur. seruou mar be assumed it ther are cateutated !!71. 36 F.R. 24083: Provided, how. In the reactor coolant system.

s. Decay of Actinides. The best from the e7 * *, that no operating license shall be (2) An evaluation model is the cal, radioactive decer or actinides. IncJuding ed for facilities constructed in ac. culational framework for evaluating the "g($*,"dpt,uto

$ ur ance with construction permits is. behavior of the reactor system during a ,,i aa iso u n. 8 p aued pursuallt to this subparagraph, un. postulated loss.of. coolant accident shau be cateulated in accordamm with ruel t] I'ss the Con 2 mission determines, among (1DCA). It includes one or more com. ercae calculations and known endionettre properties. The settnade decar boet chosen .JJ* k$. NDisAt RfCittf t, VOL. 39, NO. 3-4tIDAY, JANUARY 4,1974 x

a r 1954 RUtB AND MGULATIONS 7 s senE to ~ e .k gu.n,.that appro.pria.te tot the Stres to the the lassest pipes, witat th,e epttt ares egnal ter th.ot.. higbe.t coeurat.d = _a a,ea the,ip f.com si nes.fuma.gymedhm 'fhe fe!!owing of. R Ntyr rust temperature during the IOCA.

4. PfasWa Product Decap. The beat gen.

b. Discharge ModeL Por all timan

. ta e.1. a sunt in the m. aftas s aarvation of maounaatuam equation * (1 tent. erailon ratas from radioactive decay of f!ssion the diacharging Suld has been calculated to products aba!! be assumed to be equal to 1.2 be two-phase in cozcpoaltion. the discharge paral change of momentum. (2) mom)entu the values for inanite operating time rate shan be calculated by use of the Idoody convection. (3) ares change mornentum Sua e ANS Standard (Proposed Ameetesa model (P. J. h!oody, "3tarimum Flow Rata (4) momentuza change due to compresalbtl.' C itT. (5) of a Single Component. Two-Phase 11!xture.* pressure less resulting from wall b Society Standards " Decay Energy at friction. (6) pressure tone resulting from area Jo trsal of Heat Tra*L3fer, Treves ase Rates Fot!owing Bhutdown of imericava Snctery of Mecianical Empimeers. 37. No6 change and (h gravitational acceleration Uranlum-Pueled hermal Reactora. Ap. February. 1965). The calculation shall be Any omission of one or more of these terma ~ 1 proved by Subcoemittee ANS-5. ANS Stand. under stated circumstances shall be JustlSed ard) Committee. October 1911). The trac. conducted atth at least three enJuee of a by comparstive analyses or by esperimental diacharge coef5clent app!!ed to the postna. tion of tPe Icca;17 generated gamma energy data. lated bre&E area, these values spanning the that is d > posited in the fuel sincluding the

4. Crtiscal Reaf Fist. a. Correlationa devel-I range from 0.6 to 10.1! the resulta Ladiete eladling) tcar be de*erent fror.s 1.0; the oped from appropriate steady-state and saIue used shall be JustLSed by a suitable that the mm.timum clad temperature for the trssstent. state erperimental data are accept.

calcu!Etion. hypothetical accident is to be found at an

8. Maf2J-Water Reactiost Rats. 'Ibo rate evec Iceer value of the discharge coe Scient, able for use in predtettrig the crittcal heat af energy release. hydrogen generation, and the range of discharge coe!5cients shall be f!uz (CHFF durtng 14CA transtents, ne computer programs In which these correta.

eLaddLng oxidation frcan the meta 2/m; ster re. extended unttL the maximum clad tampara. tions are used shalt contain snftable checks P5. m ture calculated by this variaticut Dee beam actico aba:1 be calculated using the Rahar. to nasure that the physical paramureers are 'Y ach&s ted. , Anst equation (Bater, I., Just. I C:. "5tMtan

c. Kad of BZotodoses. ( a fmh== On2;* to Within the range of parameters speelnad for*

( d' ' er 3feenf Water Reactions at E!gn '!)mpera. Pressurtand Water Reactors 4 For Netuated authors. f f use of the estrMath== by their regective .D

2. Suome. III. Erpertmentat and nearetteal StudJes of the Zlroontum. Water Reaction.* cold leg breata, all emergehey cooung water

b. Steady etate CNP ectrelations hccept-c.

AlfIr8848. page T. Afay 1962). The reaction Injected tnto the inlet lines or the reactor ! - s* eball be assumed not to be steam !!mited. For vessel during the bypaso period shaII In the able for use te IDCA transients Include, 1 N(_;. rod 3 whose cladding is calculated to rupture calculat$ons be subtracted from the reactor but are not limited io, the fo!)owing. I (1) W J. I. S. Tong. " Prediction of De-during the LOCA. the inside of the c: adding vesset calculated inventcry. This may be er. parture from Nucleste Bot!tne for an Axtany shall also be assumed to react af ter *he rup. ecuted in the calculatico during the bypass period. or is an aDernative the arnount of Non-unFcrm Heat Pluz Dtatributton/* Jour. ture. The calculat:cn of the reaction rs'.e en th7 Inside cf the eladd:ng shM1 a:w fc;Iow c:neri;etcy core coo.tr.g water enlculated to nal of Nt.c! car Energy.1*cl 21,241-248.1967. (21 P& W-7. J. S. Ce::ers*edt. R. A. tre. be in.ec*ed dur*.ng the tg.us pert:,d rcar be W J CNer chn. R }L Wtison. L. J. Stacest. the Baker.Jt:st eqt:r.**cn. st tri:n at 'he tune subtr.ated 24ter in the ell:u?A!!on fro n the when the claddeg :s eticuhted to r*:pmre.

T*.**r emuning in t1:e tr:et 11ces. d vn.

Bund:e Cooled by PrMeurived Wa'er." Tico. "Cer**! *lon of Crt*feml Heat F*ux in a and estecding areund the claddi:3 tr.r.er eticumfirence and utally no tesa than 15 comer. u.d r*seter veuel caer p;enum sfter Phee Flo*a vnd Neat 2Tassfer in Rod tnchts each way frors the locatica cf the the byp.us perted. Ttta b pusing sha:1 end Buwfles. AI ME. New Tert.1369, rupture with the reactica asstaned not to be in the esteidatica at a *:me destgo2ted as t3) #ticia-Iery. J M. Hea:zer.J E Hench. the Nr.d s;,f bvpa C aper w!uen the et, Pu!. don s,r entrMnment rnechanPc2s respon. E. Ju.he*L 3. Levy " Des!rn Buts for Critical ateam 11rnated. este fcr the b c9w.an 1re caleu:a'ed r.ct to &tt F*ux Condition in Eat:ing Water Re-

8. T.cador InfeeMs #c tf T-t'ss/re. Heat transfer inn pip:cer. enset nits a td r.on-acte r? " \\PID-5!84 C:: Cmpa:iy Private De ***ne.

ne er J. foypnas de.*.m!!on '"E"f' MT N fuel internal hardware sha.1 ',e ts-:en 1:no 'Uettin 9e accoun t. J st~n aha!! be j ist:2ed 41 M. r 'e * % of'N*ed Nec*!rn BurnOJt D2*A" Pm.4. F W -*'e'n. "An Appr3Is11 by a

tt r T. Pretstart:cd tv :!ct Rncro' Pr:wyto. eyer
men *.bte cc n5:na*:en of ann!- ts at:d 11 tt n Acreptsh:e me*hcnts top Seemsfary Neaf Tr.zns/ce. Heat tran fe-red de:tmr 4 end et vpa,s" :nclude. but are not 1/'"" IO N

t ns M Me 1%stitt te of Mechanu*al En. to betzm primary and

- re nd ary sistems

,r.a!*d ;o. the follee ig: (D Predictica of e3n Rarsteft P. G. Darne:t. "A Corre'ation thK ihett excharters es esnt ;*ners' m Se Nadt w:n e.:c's:4ticu c f downward '!ow "I UU~C';I U"'8 IOf "H'fi frnt? Hested An-

. shk /toen Irro necct:rt. that ae : nt:e in t-e N a~ t mer f sr the r?masteder of the r't!! ar.d I s Uses far f**ed.. *: rut Ultncut in I so Bos11:.f Water Rea:9rs 6 % 4 *.. '. ". f.s

c d: @ Pr'.:':*.Jcn of s thres. Mer.:y !!as;ed Rrw! BuLd.es.** AEEW R I

l C. swntiMc ar.3 s **rt tr

r t'tr c* nta w dd I.,r Imp:et s n t? ":Wat in the ups trd IOJ I
aftD FML as0 T *?r13!aL e 4*.1*:'*RS gg,gy.,. g.., M.. gg: ?.:d and:ttor.s 21:4a

.6) If ec'n E D nuns. "A Carreht'nn ,,,f., u,,7 P.t i ,y g.,7 n.g,7, of.9ed !.'ure e C*1t: cal est F'is for Water Each evt!3^.tica modCI shM II: l*;de a pro-d Maa:.'"7 %.Jr the Me% 28td she FCCS fn the Prew Ham W M M Ma/* IN-visfon fne pre 1;c*.N L1d.n2 s te!!t e 3rd f" witmi s'at1ts. T he n, dmg in the itetni y 1412. k ?.ho N J.: car Ccrpc ts'.cn. July 1970 rupture fic m ects'*e'stten cf 't e.us te*n. cf sed 1.1

1 ng the : ~ nn Or m'st wc*tona t

C of . 4 f','I4*1er s -a,'. ;rtste tror t perature d.r.*r:5 :*. n Of he ' w.*.; 'nd of ;;;e Tnd *: e p..:a.J fzCCSinp hn , fro:n *2e d:?erer.ce.;2 pr!'sure *,ets*e :t .r., %22d be A n n *.) j, , '[ g(, pu:qt a tv;sab'e tra!pta,4}. l insid2 t.nd on%:de cf th* !1dd.*ut. %:h la tf the Mra 1; P n L. Or/ in Oew re- ,,) ftacet!cna t.f t;;r e. To 'e seertMe '. e g eweihnJr ind r*:;.!:Are ack'2*st:*na.. All Se -]StTW2',n'!".

a d >*n r.s:Na M 9e *cr***.t"ce s W:: '
L I"

,aL T-r D* as b ft!.,nat ., g.ws of C HP a r.:ch thw rar ur.ce'r'stutv based en app:1:nole J.sta in ;uch a T n, that '. ves in p res tr.ct e" e ~ ?po' *nts anat'td. t.n tae

tperi.T etPal 1a*a rtm the tb3 degree cf swe :It and t=etdence,f rup.

ture tre not u.nderestunated. The decree rif 13J *h* r=scMr tere stM1 te ca* ulated Ptng g 4 gbout r rmte:3 that tacP:de res!.sric tartation of a*e "4 n % the sus!!1ng tad ruptre sha3 be taken into friet:on f acter Attla Ee-n Jd.s nutcber. and ." ar' st er'WY account in calcu;attons of cap conductance, real:*t;c t'so-phne tractma nauttip'Jere that ,3,jyfe of the data to demonstrate the ecnk etadding c2idation and ernbrttt ement, and have been adequate;v ver:.Std by cc:cparison servatism of the transtent corre:arlon. t ydrogera generation. with etperirner.tal data. er models that prove

d. Transtent CHF cwrelations acceptable

rbe e2culations of fuel and elsddtng tem, at least equally conser s*tre with respect to tcs use in I.DCA transante include, but are paratures as a ftruction of time shall use mastmum clad temperature cateulated dur. M Mted to, the followtng:

! values for gay conductance and other I.cg the hypotbetical acetdent. '!be modtSed (1) G.f.4as-of-Coolant AccJdent and E ggg.K tressnessi C#F. B. C. Slifer J. L ' thermal pararneters as functions of tem. Baroczy correlation (Baroczy. C. J., A Sya. l peretterv (nd other appitemble time-depend rner. e teena Drop.ge Carrelation for Two-Phase Pressurw gency Ccre Cooling &fodels for Deceral Elec* f, !,est variable). The gap eendnetance eBa!1 be h. W ar. W 5pmp. M s. trttr Bot Ing Water Reactors." NEDO-10329 ',,ged in accordaner 1rtt2r changee in gap No. 64. Vol. 62.1965) or a combina dtesensions one atry other oppftenble *ftazn correlatton (Thom. LIUR,tJos of the General Electrte Company Equatton C-32, Prediction 3p,g gg73, Wise. of Pressure Drop During Forced Ctretalation t Aftar CHP 1a Bret pree ted at an metal

6. sad 4rmeers """"*

Bo12tng of Water." faf. /. of fleaf e Maar M red locathe dur'ing blowdown. the car. M' g'. rrensfer. 7, 70b734.1964) for pressures eTaak caalat.noa sha&& not use nucleate bolling heat 6.R pysme 59ternetertrfter and Fame, s Its to or greatne taas seg pata and ene lear = transfer coersistmas at that locatloa outp-I. smalyses of hypothetical loeW-coolant ae. ttnellbMetson correlation (IdaettaeRt. BL C. sequentry during the blowdown even if the 2 lhearts, o spectrma of postvte ptpe breaks Nelson, DA, "ProdletSon of Pressure Drop omleulated local Suld and surface conditlana damit my considered. This spectrum statt en* would apperwntsy justify the reestanne-ut eues instanw=ue doubne-ended break" Durtng Pbreed Ctrentatton Botting er Water,* ar p= eta =to Deutig. Meet transfer aarump= g w sonettrg tn cross-eeettonal area up to and tn. Transeeftone of Aswr, 095-70s, IMs7 fe ""*h*'**''*"**"*** f( greeing that of the largest ptpe in the prt, pmesume towur than M ph to accep6 as halting (rowettingt etalt be per *attted wtuen T. b a sesry cumtent systeun. The analysts aisaA1 also a baste for cafeutsting res!!stic two-phase lust 18e6 by the emanlmend lacee Guad and k* ersets of kmrttudinal epitto in fttetten aratttptters. surface conditions during the redood por. 'r taon of a LOCA. 1,,,.i FfDftAt Rfol57tt, vot. M, NO. 3-FRfDAY, JAMUARY 4. H74

^

l,.,

p ,e t. h-i RULES AND RESULATIONS - 1005 y es..

5. Post-CHF Rest fraimsfer Correlations. a.

nate any calculated rapid osc"1aHana (portod ('7WR Full Length Eme gency Conting Rest Transfer (FL2CHT) Oroup 3 Test Repet." - cap;Q ~, Cornlations of heat transfer from the fuel less than 0.1 seconds). auch % cladding to the surrounding Buld in the post-

b. A method shall be spec 18ed for determtn-West 4nghouse Report WCAP-7544. Septeembar t/-

CHF regimes of tranaltion and Alm boiling Ing the enthalpy to be used as input data to 197th "PWR FLECHT Final Report supple, 1 aball be comnpared to applicable steedy-state the hot channel bestup analysis froen quan-anent." Westinghouse Report WCAP-7381,. and transient-state data using statistion1 tittee calculated in the blowdown analyals. October 1973) are not saoeptable. New eerg correlation and uncertainty analyssa. Such eensistent with the Sow distribution enicu. relations or anodMemalans to the F12CET. - heat transfer correlations are acooptable saly % ecmpartoon shall demonstrate that the oor. 1stions. .L, s r ,,,,,,,,g after they are demonstrated to be conearvad lemy,g - relatione predict values of heat transfer co-g,,, tive, by compartoon wt1A FLECIrF data. Sur i efBelent equal to or less than the mean enlue - i 's range of parametere canaistent with 1Als rasgg of the applicable experimental heat transfer 1, Single Fs(Jure Crtlerdoes. An analysis of tranatent to which they are appland, ..;-l' y amt,yy data throughout the range of parameters for saut y-r*' which the correlations are to be used. De posalble failure modes of ECCS equipment

During re811 and during reSood when se
eet-E,* '

comparisons shau quantJfy the relation of and of their ecocts on ECCS performance Sood rates are lees a.han one anch per second, t.4 anC k the correlations to the statistical uncertainty must be made. In carrying out the socident heat transfer calculations abau be beasd on evaluation the combination of ECC8 subsys-the assumption that cooling is only by steam. pt ' ; ; of the app!! cable data.

b. De Groeneveld Sow SIm botting corre-tems assumed to be operative shau be those and shall take into account any Sow blockage

.eut ^- ' 1ation (equation 5.7 of D.C. Oroeneveld. "An avausble after the most damaging single cateulated to occur as a result of cladding tie. - Investigation of Beat Transfer in the IJquid fa!!ure of ECCS equipment has taken place, swelling or rupture as such blockage amight 71sp cts DeScient Regime ** AEC1,.3281. revised De-

3. Contetsment Pressure. De contain-afect both local steam Sow and best transfer.

cember 1969), the Dougall-Rohnenow Bow ment pressure used for evaluating cooling ef.

6. Conocetite Beat Trossfer Coefletents for for i

B1m bo11 Lng correlation (R. S. Dougalt and factiveness during reSood and spray cooling 8 0111769 Water Reacroe fuel Rods Under Kpray an tag I w Et. Rahmenon '7dm Bolling on the In-aball not eseced a pressure calculated con. Cooling. Fouoving the plowdown period. con-s.de of Vertical Tubes alth Cpward Flow of terratively for this purpose. The calculation vective best transfer sh.411 be calculated using t? e Fluid at Lot-Qus:ltics.: &!7T Report aba!! inclode the e5ects of operation of all coefhrtents ba. sed on appropriate experimen.

&a.

l N un.ber 9079-29 Cambridge, Ef aasachusetts ins

alled pressare reducing systems and tal data. For reactors with jet pumps and 1

battng fuel rods in a 7 x 7 fuel namembly g bep:e:nber 19631. and the h estinghouse cor-proceses. ne. r rc :a nan of eteadt. state trar. sit 13n boiling 3 Ca?calaf ton of Reflood Rate for Presrur-array, the followinC 03ntective coemetents . Pr:r'tetary Bestreet Rebt;tta' Tes:Imeny 1:cs Refet Acartcas.The re'.11tng of the reme. are acceptable. Westinghouse T:ectrir Corporation." tor veMc1 at.d the tLme and rate of reSood:ng a During the period follos tr g lower 7 ? r 's. A E C. D d e R M f 0 - 1. pan 2 b l. Os. of the-tore stall bs cattulated by at: accept. plenu:n Sabing but prior to the core sprav s 9 M 1972i tre arrepta!le for uw in 11 e able n ode; that takts. Inic. ex.alderation the reacbtng raid S w. a conteef tve heat tran>- fer carMeat c.* eeru aba!: be appired to su m, .. e -CliF b;1:aar regir.w s In add.t*)n the ther:ui and bydraube charac ter:tt.cs of the 1:..t err, t> NIP r cerr&i.n of 1!cD,ncurh core nr.d n! th. reisetnr o s: n The pr.mnrr fuet tort.. b Dure.g the perr d Pier core enray a !.t.' :, at.d Klug 11 B 11:D::ac u:1.. systarr. co.lant pump

shmM be s'sumed to rta;beh rated flus' but pr r
to re$ond u.g.
4 1:.:ar L. E C. IUtse "Partta! T;trn D r...:4 with hatt locked irr.pelle?g tf thje Estumption jeads cor:terin e heat transfer c>ef5cients of 3 0,

% re-r at 2WJ pst: in a Round Vert.es' Tube 7 to tiu rns'in.un' calc u!st cl cledd.or terrper-t. !*H kesearch Corp. Techuma! T.eport C2 sture ot he rw.se the purr p rotor shan be SF 1.5. ar.d 16 B u-hr*f t 'T t shall be 1 N M37 t, i i19M s is sulta!.e fu-er be-e.ssurred to he rut.ttnr free. Tbe ratic of the aPrl'ec. to 11.e f ua! FN' it. the outer corners. out(r rev. 7. cat tc outer rom ard to thost 4 i.~ ts.i huce%te stid C!n-th.14 (% of si? tots' f etc f'% at the core eut plane to the t ? ' s-c orrtlet tor.s sha!! be re st: a:ted 64 tot.C 1:qut:* ibe. c.t the rere 1:. e* T.ane tear. Temv.n17.g in the interior. respecttre!y. of the aNmW f.9 r)ot e* f rutions h ab. ': bs ut+d tt d*terthine e After the tn.phsu refiondtur Eutd ela Tne Oracneteld c0rre16*le n thatt ried the tete em floa a:.d that; be de crtnined its P'!*ehes the lecel under cons:deration. a enu. 4 t'e tac d in the regi:n Lea 1:a los.p ea<.ure accord new sith epidicaNe espert nenta! dr.12 Te:th e beat tratWer coe f".rient of 2'. Bt u-4 s u.rd a rit y. (for enartp:t *PWR PLECP'T st ull Led th i [N .2. the tr** term qnue;este) c f the We=t. Emervr-het Cochne Heat Trantit ri Fina! h,. be'-f t-' F ' tha!! be arpted to a11 fuel rods ); a:.;::t3ue ccrrelatic a. s'd the er.*.rc 11.D..:.- p.+t ! - h estintu uff Re; ort WC A P-h65. Y U f 80Uf F C F8?c' Rf G*fo* Chan ne' Pn L 4L !&l:ch. ar d Kai.r corre;a st r 61.ai: rot Apr.; 1971. *lT.R Tuli 1#nnh 1.merrt ney Under Sg ag Coo *t.:p F. newir.f the blow - .1 hr used durts ths bl< s daa r a! e! ti.e tem-C.wlir Hr:6: Transfer #T11CHT! Ormip I down pe rind heat tratsfer frotr. atad e titm;* parature di"erence bet t et.. tt3e c:ad and the *Ien !;eper % esttugt.oute Re port WCAlw

07. the ch tane; bc 4 sbr /! be based on appri.

Il a

urated th.id errt emt d> ;ts*
T.

74E Jat:uar) IF70. **PW R FLECHT 4Fu!! prbt* exp4 MutenN d m For ret.rtors wah jet pumps and fuel rod.e in a 7x? fuel awem- .2e trans.tich tW tt r hen trtensfer shall 1*ngth E mergency Coofing Heat Transferl b!y arrar the fo; lev er test transfer coe.., a art be resp;;11e:1 fcr the r?=amd r of the Orttt. !! Te-t Repert." Westinehouse Repcrt cien t, and settir t time correlatio'n are LOCA bl9s dewn. ese, if the clad supe:he.t WCAP-7544. September 1970. *PWM FLECHT p:r acce ptable re*urus be!ow 300' F. eteept for the reEnod Faust neport supplement." Wettnghouse Re-a During t!ae period af ter lower plenutn pv?'tou of the LOOA shtn jutt!f.ed by the port % CAP-7931. October 19721 Smah:r.r but prt;r to core spray reaebin; A c A uh.ted I scal rud ar'd surf s.ce condt;iens The eSects on reflooding rate of the com. 6 Pwr Afo<tiv. The cLa acte-tet:cs of preswd rn in the secun.ulator S t.tch is d, rated tw a conrectate r&*helent of eeru a :stthr primary s3rtem pump fa m! Sow. c harp eJ f aller:r.e accumulator u ntes dis-s'iar 1,c apphed to tl.e f uel assembly chant:et

5 W*Nie er centrif un! aball be der:ted frorn char,c shan a!n be taken tuto account b Durmr the period af ter core spray a dvhamle modet that includes Enomentum

4. Stea'. Interaef ton tetth Eme'pene) Coet trhnsfer betu een the flutd ar.d the rotating Cochap Wate* da Pressartred We'er Resetors. reaches rated floa. but prior to setting of the channel a conteetire best transfee corSciene i**

member. %1th variable pump speed as a func-De thermal hydraulle interacuon between of 8 Btu-br 1-f t-8 'F4 shall be applied to both .he,, tion of time. The pump nodel resistance steam and an emergency core cooling water aldes of the channel box IT # taned for analyals abould be justt!!ed. De ah&M be taken into account in calculating the C. Wetting of the channel box shall be as. %h pump model for the two-phase regton shau core renooding rate.Dur}ng reSH and reDood. sumed to occur 80 seconds after the time be vertSed by applicable two-phase pump the calsulated steam now in unbroken reac-determined using the onrigflation tummed am perfortnance data. For BWR's after esturma tor cootant pipes shall be taken to be aero the TamanoucAl analysts (" Loss-of-Oootaaf Wag C tion to calculated at the pump suction the during the time that accumulators are dia-Accident and Emergency core Cooling men pump band may be assumed to vary unearly chargtng water into those pipes unless exper- &neral Eectrie Dolling Water Reactors

5.g 1

with quality, going to zero for one percent imental evidence is available regarding the Mal Doctric Cosnpany Report MEDO-i qunuty at the pump suction. so long as the remitstle thermal-byaraulle interaction be-30329. Srtl1971). hna!ysla shows that Core CoF etops befo'e tween the steam and the ljquid. In this case, 11 e quality at pump suction reaclaes one the erperimental data may be used to sup. . aterrarn cocrasrsrraftore ent. port an atternate s*sumption I. a A description of each evaluation mode 7 Core Flote Distetbt.ff an Daring Blair.

6. Rejt!! e'ad Actiood Neat Tren eer fo, shall be furntshed The description aball tm do:rn. ( Applies only to prewurtred water Pressurt:cd Wate' Reaefo's. For nflood rates 8U ClenUy coInplete to permit technical re-ree tors )

of one inch per accoud or higher. reflood beat view of the analytteal approach including th. ) transur ceidelents shall be based on applt. a The flow rate through the hot region of luations used. their approstmations in dt! t the core during blowdown abati be calculated cable esperimental data for unblocked cores [mnce form. the masumptions made. and the e.

*
a funetton of time. For the purpoae og including FLECHT rerutta ("PWR FLECITT

\\ "u ararueters or the procedure fa y he calculations the hot retton thoaen sha!! (Fuu Length Emergency Coo!!nr flest '2 Tans

t e tr ra t be greater than the aire of one fuel a*.

fer) Fanal Report." Westingborge Report with 'd* r r mbt). Calculations of averate f!?w and flow WCAP-7663. Aptt! 1971). The use of a cor-correlatto u e relation derived from FLECyrr data shall be b De desertption aball be sufBelently de 81 betwe n regions and any or demonstrated to be conservative for the tatled and spectSC to require algntocan cralculated to occur during blowdown as a \\,/ result of cladding sweutog or rupture. De tranatent to whicla it is applied; presently changes in the etaluation model to be spee r calculated Aow aball be smoothed to oltml* avaltable F12CIfT best transfer correlations tfled in amendments of the description. Fo i Pt0ERAL RECl$ tit. VOL. 39, NO. 3-ftl DAY, JANUARY 4.19y4 e x [ %. w8uI ~ !

. _.. _......... ~ - @g ~-. 1006 a. RULE 5 AND REGULATIONS ?[.; <. ~ - 1exts purpose, a signtaannt ehmese as as abangs -' PANT 220-GEDIT BY BROKERS AND 'CHAPTERV-FEDE est would rwult to a "-w eust etd. fMb -a,. e,he el,oe a,e.m d w ei ag m -d w== Sw-no==*..a c =, =. : nrasran goAnn 4 ;, o t nac as 1 EfecOve Jarmary 3,1974, t 220.8 (a) s-p ~d h me het pressously necepted - 6 6.J 4is c

e. A eneplete Noting es each computer pm.. San T1 la annanda/ te amad sa folkma:

M $,". / gram, as tae same form as used an as sena. I220A - -- .. geem N(. ~ -[ --*'quatican model, shall be furnlahad to $$he 4L $) NO2$WtgrW$ jDSS 98)3e Mr WelteF91 PART M2-WF'EEE 1 . & s. e ' Asaanse moergy wisessa. a$.

2. For anch computer peosram. entuucsa aceovnts. The mavimum loan value of._SetmOkesWMWUn,

' bY ;.- eenvergence abat be demonstrated by studies securtiles in a general aceount subjectio .W w w a.- d' ting or anding and en* i220.3 aban k Dar===ma 3L I QQ"t,p,'ennettivtty studies aban to Y' (1) Of a registered nonequity security he Federal Route Iman hank !

a. Appropriate held in tk account on March 11,1968, considers it advisable to amend I 5 performed for each evaluation model, to eval. -and continuously therealter, and of a unte the seeet on the caleurated resulta of of the Regulations for Districtof C variatsons in noding, phenomena mumed in margin equity security (except as pro.. bla Savings and Ioan Am@%

vided in i 220.3(c) and paragraphs (b) Branch OSces (12 CFR 682.1-l' the calculauon to predominate, including pu:np operation or lockins. and enlues of and (c) of this section) 50 per cent of the lating to matelinte oSces. for the parameters over their applicable ranges. For current market value of such securities. purposes of removing the require kems to which results are abern to be senal. . that (a) a satelijte OSce (other t e eIte$t praeu t' nom e (d) Merin reqWed for short safer. fully automated satcH1te omeet t 4 o e, p of the evaluatic n Irrwiel. er per1Jon6 thereof, Tbc amount to be included la the ad* cated within a rttall sales establisi shsn be compa ed wlth app!acab;e expera. Justed debit balance of a general account. auch a3 a department store or supc: mental isterniatien ket and (b) a fully automated sa Ger.em' b::.Sc..rdr for Acceptab1My-pursuant to 1220.3+de f 3 >, as margin re-fs r<.u.t3 ct ewua wn mode rmeved w.1; Qulted for short sdes of securities (other cSce be located either -within at sne.c tecu.u adequac3 of tN ca:cma-than exemned securitsen slall be 50 pcr retat sales estathshment or in a tm rre h< m schdu r ecc pm:.ce 3 u*. cent of the curnnt rnarket value of ea:h ping center, omce building or trans: tion terrninn). In addition the I security. consides it advisable to make et d c! a 1 t of a te a 3r.arrm ce ccare utu:r. comrr. raw te other Inim or ccnforming regulatory cl. s setsmue entw m n2 odt.. tauur set' PART 221-CRED'T By BANKS FOR THE reMng to Mte omecs. amun sete e:*erenect te tae reacters PURPOSE O.r PURCHA3ING OR CARPY-Acc rdmcly, the Federal Home te v.u-h tLe: noFr. ING MARGtN STOCKS Bank Burd bereby amends said i 5' b.t revising pararraph ia) sub ( F.. 16:. P d t.a2 8Mc3 ec $:at 948. 8:

3. ENectat January 3.19M. I 221.4(a)

E.. E.. el ELJ H n L.E C. :.:1. 6 CE C. (the Sup;1c:r.:nt to Regulation U) is subparagraphs (4) and (5) of para g+aphs it i and (8 8 of para,grap. 52 mi Dated at Wuhinrton D C. this 28th amended tc read as foDous: (gt, and the last sentence of parat is n, to read as set forth belos, em day of December 1973. .r j + 4 9pPjment. s January 4.197L Fer the Atomic Everrv Comnh! r. (as Manra.um loan ecJuc of stocks. For Since the above amendments ri i J Far:. C Br nrr. the purpo*er of f 22LI. the maximum restrictions, the Board hereby find-l m/ sa rcian cf thc comrmsior., loan value of any stock, whether or not notice and puthe procedure with re (Tn DAM 2C Fas4 3-M4.e:45 an.) tertd on a naticr.6! secudtles ex* to said amendmente are unnece M changt, sh:2 be 50 percent of its current Under the provisions of 12 CFE

Tltic 12--Banks and BenHn*,

market vrduc. as determined by an) rea. and 5 UjS C. 5531b); and a!nce pui CHAPTER li-FEDERAL RESERVE SYSTEM sonable method. tion of said amendments for the 3; period specified in 12 CFR fRit SuecHarrra A-soApo or covenNoms or 5 U.S C.553<di prior to the efectare rHL FEoCRAL RCstRvt SYSTEM (Re C. L Cl (s. These amendments are issued pur-of said amendments would in the op of the Board hke suant to sectics *T of the Securitics Ex. the same rea'on. wise be un MAXIMUM LOAh VAtUE OF STOCKS changc Act of 1934 (15 U.S C.'lBO. tides that said amendments shall bt-tre Board hereb3 Parts 207. 220 and 221 (Regulations 0,

b. The requirements of 5 U.S C. section efectiu as hereinbefore set forth.

T and U) are amended to change from 35 553 with respect to notice and public par

The amendments set forth below e percent to 50 percent the maximum loan value ofInargt. securities.This win have Licipation were not followed in ennnec-the fouosing regulatory channe

1. Paragraph ta) of I 542.1-1, erst the effect of decreasing the amount of 46on with these amenstrnents because fol-Q. '. '

" Nature of a salentte edRee", 3s ye margin required for stock-secured loans hwing such M ts would be Im. by adding the fouowing M.& f' - ~~ ~ 4

q. d.* ' ; s. '

. and short sales.. practicable des to the highty tachnReal e fully outernate!sateHite oScet % MLirr 207-5ECURfTtES CREDff BY PER. matun at he s@ct er kW

"t"'"'t*# **t*3Ut* '808 8' *"*
p a

SONS OTHER THAN BANKS, BROKERS and because It would be contrary to the operated *b W h public interest if this action were not im-ut h w Wher pemonne

1. Efective January 3,1974. I 207.5f a) mediately eEcettre. The requirements of e

ac ns Wh the puhuc (the Supplement to Regulatic:. G) 18 5 UAC. section $53 with respect to de-a n ted that this d@h la the n I amended to read as foDoua: ferred effective dates were not followed as the description of a fuDy autorn = $ 207.5 Supplement. b nW% ' (a Marimum loan value of margin cause these amendments relieve restric. (c) (1) (t) of I 582.1-1, which subriiv*. secutifics. For the purpose of I 207.1. the tions previously imposed, has Men &W. maximum loan value of any margin By order of the Board of Governors-

2. Subparagraph (e)(1) of I 587 securttv. except convertib 2 securities January 2,1974.

entitled ** Spec 1Sc provisions", preti: sub!ect to i 201. lid t, sha:1 be 50 percent required a satellite oSce (other th. (seal) CNr!Tra B. Fttostec, fuDy automated satenite of!!ee) to be ed b reas able cod. 84 (Fft Doe 14-831 FUed i-2 'f4.8:04 pm] cated in a ntall sales eaW^a=1 G yequired a fully ana-Jad sateiMne o u a. .w MDERAL R80l$758, Y0t. 39, NO. 3-MfDAY, JANUARY.4,1974

s J*

g, - ^ ' ' ' - - -

e ,f NOTICES cnd serwes cf the Department. Coor- , 122U dmates the public information acth1* For t!.e Atomic Diergy Com:nision. mer.: sin primr.ry aystemintegrity.devel. ties (f the Department at all levels. W. B.11cCoot, wment of impmud analWeal muhods rates the public asalts communica-Secrefery of the Commission. for piedicung core cochng perfortnance,. o processes with Department policies j j, and objectives, and establishes and en-lrR Doc. 71-0100 FUed 6-26-71;8:45 am] and performance of con!!rmatory experi-i. ments were recommended. {'.j g those policies which eCect a clear Extensive design analysir, and re-nt, and consistent flow of informa.' CRITERIA FOR EMERGE CY CORE search programs w,ere initiated by the - (, j' the seneralpublic and other audi. COOLING SYSTEMS FOR LIGHT AEC and the nuclear industry in the4e .,- rr' g q,. ences cbout Department programs and WATER POWER REACTORS areas, and much new information has W EM['1M C* scuvities. M been developed. Additionally, practices.~iA a ne D.pty Asshtant Secretary for Inferim Policy Statemen, in the design, manufacture insta!!ation. N - S @W f Pub!!c AKairs.(wnmunications) repre-sents the One of Pubhc Agairs on mat-The Atomic Energy Commission has and inspection of power rea,ctor primary-

7. s.

Liy 7: ters rehling to information flow and adopted the interim statement of policF systems have been markedly improved. f % WT processing and interface with various set forth below providing Interim accept-Later in 1969 an AEC Internal Study 5.. I% publics en substantive matters of De-ance criteria for emergency core cooling Group r,ecommen, ded greater emphasis on t %y M partment policies and positions related systems for light-water power reactors. quality assurance, and confirmed the use ... gt -; C : to: News services, audiovlsual and photo INrta'tu AccEPTANct Cancata rom Exza; of postulated unlikely accidents (such as P-the loss-of-coolant accident) as de-

j +4 services, publications and graphics serv-ctNcv Coar COOLING SYSTEMS roa sign bases for reactor safety.

[I L,g f 3ces, cad speakers bureau and speech Lacur-WArra Powra REAcTonS Y t The ongoing industry and AEC pro-writing. i $ grams have produced a large amount of" 'gM ' M C. The Deputy Assistant Secretary for" L cENEaAL, information not available at the time of Pub!!c Affairs (Operations) represents The' Atom!c Energy Commission has the O!!!ce of Public ARairs on matters recently been reevaluating the theoret-the earlier reviews. This new information a Mj relating to management and administra-ical and experimental bases for predict-has led to changes in the various emer "i ~, power reactors, and also in the analytical ~ ( )@- l,,d tion tf public afairs activities andinter-ing the performance of emergency core gency core cooling system designs for 'J t 4 face with pertinent Department pub!1cs cooling systems, including new informa-and (rganizations related to: Commun!- tion obtained from industry and AEC methods used in the evaluation of system (:~4

a F.< 'd 1 t*

s.It performance. Development by the reactor cati:ns planning and evaluation, fleId - sult of this reevaluation, the interimresearch progr'ams in this field. A vendors and independently by the AEC, e.W? p ' ' d-senices and agency liaison, administra-of new, methods of annlvsis-computer Aa R a? tive senices, general public senices, out* criteria of section IV of this policy state- ' codes-more complex and sophisticated W % M N side organization liaison, and special in-ment have been adopted by the Commis-M :W formation task forces. slon for use in the licensing of light-water by iat than those formerly in use, gave new insight into the processes ., m i? 9 $ Approved: June 22, 1971. ~ power reactors. 'lems, in predicting emergency, and prob. . : y) / M, Z core. cool-ELLIor L. RicMARDsoff. rr. sAcEGRotntD '

ing system performance.

91 Secrefary. Protection against a highly un!!kelF The nuclear industry as well as the (, { { [ra Doe.719:4s FMed 6-28-71;8:48 am) loss of-coolant accident has long been AEC has sponsored a great deal of con-V d an essential part of the defense in-depth firmatory experimentation in this fle!d. d**4 concept used by the nuclear power in* Blowdown experiments' performed on dustry and the AEC to assure the safetF nonnuclear simpIlfied models of pressur-w m U M Q hnnsulpoinu of nuclear power plants. In this concept, ized systems were used to check and cor- - * ' f ([ f

umnu, ild1Q)lM the primary assurance of safety is acci* yect the new codes. Some of these I

~ i4 Q [ Docket No. PRa!-36-2)

dent prevention by correctly designing. experiments in the small LOFT Semi-1 E.. t'~

constructing, and operating the reacAr. scale Blondown Systerfi at the National 3 NEW ENGLAND NUCLEAR CORP. Extenstre and systematic quality assur-Reactor Testing Station in Idaho showed Filing of Petition - ance practices are required and applied deviations from the predictions of the O Nr at every step to achieve this primary as-cedes then in use. For example, the ekner-,

, ;1 Notice is hereby given that the. New surance of sa'ety. Nevertheless, devia-gency core cooling water was ejected J'.E$

England Nuclear Corp., 575 Albany lated to occur,pected behavior are postu. from the system during the blowdown / tions from ex C M. Street, Boston, MA, by letter dated and protective systems are Although there are dIEerences between I'T '.

I Afay 28,1971, has filed with the Atomic installed to take corrective action as re-the small LOFT Semiscale experiments '

JT Energy Commission a petition for rule quired in such events. Notwithstanding and large power reactors, this experi-7 making 19 cmend the general license in su this, the occurrence of serious acci* mental result has been taken into ac. s ,136?4(b) cf 10 CFR Part 36 for export dents is postulated, in spite of the fact count where applicable in the evaluation 't

of tritium sith a specific actMty of not that they are highly unlikely, and engi* models of Appendix A by including the

.I 'more than 10 curies per gram of hydro

neered safety features are installed to conservative assumption that all of the

~ q . i. sen in labeled organic compounds. mitigate the consequences of these un* water injected by the accumulators dur. The petition requests that the specille likely events. The loss-of-coolarit acci-ing blowdow n is lost. lactivity restriction of **10 curies per dent is such a postulated improbable .The process of code development and . g ..{* L Nram cf hydrogen" be deleted. The pet!- accident; the emergency core cooling experimentation using models is ex-itior. st tes further that if the Conunis. system is one of the engineered safety pected to continue. The ' tion considirs that additional controls features installed to mitigate its p plans to place the necessar. Commission { y additional Tould be requ! red sith deletion of the consequences. emphasis on such work in Commission. fpecific tctivity restriction, the single Emergency core cooling system des!gn programs and expects the nuclear indus-47 o ph!pment restriction of I 36.24(b) could Wimultineously be reduced from 10 curies considerations were reviewed in a 1967 try to accelerate its eHorts. . Sp{ g In view of the large amount of new r*.1 Q D 1 curie. report to the AEC by an ad hoc Advisory information available, the AEC has Task Force on Pow er Reactor Emergency vai bl for pub!!c pec on t Core Coo!Mr. W Task Force recom-again conducted a review of the present 3 ', Wi dP Smmission's Public Document Room at mended that additions! assurance could sWe d emmney core cdng syskm j h }. M17 R Street NW., Washington, D.C. technology, and has reevaluated the and should be obtained that substantial ! Dated at Washington, D.C. this 23d fuel melting can be prevented by emer-basis previously used for accepting sys-3., v,

1 My of June 1971.

. gency core coo!!ng systems. Improve. .g 'y tem designs for current types of,11ghte., y ), j4 water reactors. 8 l ~. M ~.F ~ p

g I

' O YA1 3---T plottAt stGilttt, VOL. 36, NO.125-fuf 5 day, JUNE 29,1971 t..,. M iu & h $ h k;i. h..i d : f. & N )?Y 2 -, L... ,.,5 '.. r L

CM NOTICES br twint2n er tutterney cour surance of safety being neeldent preven-models are dMczibed in Appendis As coot:NC MstLM rERroRMANcE tion, schiesed by cor:ect design, These evaluation models are accep*abl N T14 course of a loes-of-coolant acci-construction. and operation and by ade-to the CommMon but their use is no dent, and the performance of the emer-quate quahty assurance. The loss of-mandatory. Other evaluation models may' gency core cooling system, are evaluated coolant accidents postulated in the crl-be proposed by applicants.for review in - n with a wquence of calculations. For cal-teria thus presuppose a highly unlikely indvidual cases. ji [V eintro! volumes (" nodes"), Each volume \\ rulction, the system is divided into many event as a starting point. C. Applicafion of criteria to reacfw These criteria are app!! cable to all licensing-1. Applicaffon to operating re. i 1 contains the heat sources and sinks ap. light-water power reactors except as actors. (a) For each reactor holding an 5 propriate to the component being mod-otherwise pro ided. Improvements are operating license on the effective date of.-; ij r.~ Gled. During the entire calculation, expected in analytical techniques, and these criteria and not covered by para. - temperattues in the core are calculated experimental programs are expected to graph (b) below, an analysis of the per-as function of time.The cooling processes provide increa. sed and improved knowl-fo2mance of the emergency core cooling J ne primary coolant flow during blow-edge about ECCS performance. On the system presently installed, using methods s,.., down and flow of emergency core cooling basis of such improvements in tech-equivalent to those in Appendix A. ahan ~4.1 w ter as it becomes available. nology, these criteria will be modified be submitted to the AEC as soon as prac-4' from time to time. ticable, but not later than October 1 ' C. Ideally, one would have available an-alytical methods capable of detailed re-The Commission believes that these 1971. Each such operating reactor shali )^ lh .1 .. alistic prediction of all phenomena criteria for emergency core cooling sys. be shown by that date to be in comp 11 ' known er suspected to occur during a tems provide reasonable assurance that ance with the criteria of sections IV A loss-of-coolant accident, supported in such systems will be effective in the un. and B. a! Gvery aspect by definitive experiments likely event of a loss-of-coolant accident. (b) Fbr reactors granted operating 11 directly applicable to the accident. In Nevertheless, in connection with wa*.er censes on or before January 1,1968, com. 5 power reactors yet to be designed and pliance with the criteria of sections Iy ,d ~. the absence of such perfection, adequate s-assurance of safety can be obtain~ed from constructed the possibility of accomplish. A and B will not be required until July 1 p4 ,R an apprcpriately conservative analysis ing by changes in design further im-1974. Each such reactor, to the extent

d J

based on avajlable experimental,infor. provements in the capability of emer-that it is not in compliance with the i mition. In preas of incomplete knowl-gency core cooling sypems should be criteria, shall be subject to the fonoring 5 considered. additional requirements:. edge, conservative assumptions or procedures must be applied. When A. Criteria for all lighf-tcafer potcer (1) An analysis of the performance of, further experimental information or im. reactors. These generM requirements the emergency core cooling system pics... a proved calculational techniques become have been the basis of AEC safety re. ently installed, using methods equivalent crallable, the conservatisms presently. view for some time. On the basis of to those in Appendix A, shaU be sub.~'- imposed win be reevaluated and a more today's knowledge, the performance of mitted to the AEC as soon as practicable'- but in no case later thah January 1,1972 - realistic approach will be taken. the ernergency core cooling system is A program ofimprovements,and b' < Detailed technical reviews have been judged to be acceptable if the. calcu. (2) lated course of the loss-of-coolant ac. schedule for efecting them before July 1, g performed by the AEC of the computer cident' is limited as follows: 1974, together with supporting analysis codes currently available for predicting emergency cor/ cooling system perform.

1. The calculated maximum fuel ele. based on an evaluation model equivalent ance. The AEC has developed sets of ment cladding temperature does not ex. to those in Appendix A, shall be sub-itably conservative assumptions and ceed 2,300* P. This limit has been chosen mitted to the AEC as soon as practicable, but in no case later than July 1,1972.

rocedures which together Mth the com-on the basis of available data on embrit-uter codes comprise three appropriately tlement and possible subsequent shatter- ' ra cabl* h ,[au ing of the cladding. The results of fur-in operating tec ques as te p i r d 8 n e cod used thIse evaluation models (described in ther detailed experiments could be the and worthwhile in improving emergency l P;rt 1 of Appendix A) are available from basis for future revision of this limit. core cooling system performance or the AEC. Codes used in the other two

2. The amount of fuel element clad, reliability.

i; An augmented inserv, ice inspection. (3) Gvrluation models (described in Parts 2 ding that reacts chemically with water cnd 3 0f Appendix Al contain proprietary 'or steam does not exceed 1 percent ~ of program shall be inaugurated promptly mLterial, for which summaries are or covering those portions of the system pip. soon will be publicly available. Other the total amount of cladding in the " - Gviluation models are under review by reactor. ing, pumps, and valves with a nominal diameter of 4 inches or greater and for the AEC. '

3. The clad temperature transient is whose postulated fatture the performance The three acceptab!e evaluation mod. terminated at a time when the core of the installed emergency core cooling els presently included in Appendix A are geometry is still amenable to' cooling, and system would not be in compliance with

,i different in many respects, and the sets before the cladding is so embrittled as the criteria. The augmented program ^* **" "I of conservative assumptions and proce* to fail during or after quenching-of Mechanical Engineers' Boller and 1 J~ diiTerences arise from two principal dures also diner from one another. These

4. The core temperature is reduced and Pressure Vessel Code, section XT, except causes: (1) DiRerences in approach and decay heat is removed for an extended that the frequency of inspection shall be cilculational methods of the different period of time, as required by the long. tripled.

En: lyses, leading to different areas where lived radioactivity remaining in the core. (4) Equ!pment shaU be installed as so prae a f needed t cilits imperfect knowledge or analysis require B. Crfferia for speci/!c reactors. Each s g g conservative treatments, and (2) differ. reactor shall be evaluated in accord-at least two different methods. 'Ihe tech-j encIs in hardware among the various ance with the general criteria of section nical specifications regarding allowable r::ctor designs, such as spray vs. flood IV.A. and using a suitable evaluation rates of identified and unidentified leak-cooling and hot leg vs. cold leg vs. direct model. Examples of acceptable evaluation age shall be reduced to the lowest practi. vessel injection. ~

2. Wrfances. ('s) The Commission may cal values.

) rv. surERIM ACCEPTANCE CRITERIA roa s A loss-of. coolant accident is a postulated accident that results from the loss of reactor authorize variances from these criteria EMERCENCY CORE COOLING SYSTEMS coolant at a rate in excess of the capability The criteria for acceptan'ce of emer. of the reactor coolant makeup system from a Westinghouse Electric Corp. proposals for gency core cooling systems have been breaks in the rmtor coolant pressure bound-subatmospheric and ice condenser contain. ary, up to and including a break equivalent. ments, and proposals from The Babcock and deseloped in the corytext of the defense-in atze to the double. ended rupture or the wilcos Co. and Combustion Engineering. hdepth concept, with the primary as, largest pipe of the reactor cootar.t system. Inc., are under review by the AEC. FICIRAL RtGilitt, Vol. 34, NO.125-TUISDAY, ENE 29,1971 I f w.. 1 - h,.::.anl3M. w.M W i.~.o. d.n. Q

?.-_

L

4 NOTICES 1221'J whefe their :pplicati n is nit prtetic;ble a 20 percent allomance for uncertainty. euming tha -udetng and channet boa emis-. l cr for other good cause. sheutd be sued. ne fret:on of elecar haat snt:y as equ ! to o o. (b) 'Une Commission may also author. generated in the hot rod should be constd.

4. It should be assumed that channel set-12e variances from these criteria for a ered to be too percent of this nlue uSess a ting dw n,ng,,1, ot rectar untt! so seconds following limited period of time to allow comple-amaiie,,alue is 3ustif,ed.

13e time cai,ulated usin, tne

e. Time to departure from nucleate bot 2-ti:nof testingprograms.

Ing-use any calculated option in the code. Tamanouchi analysis.

s. A range of conservatively calculated W (~

n (c) The application of these criteria

7. Heat transfer after departure from nu-l f\\ )is expected to permit normal electrical peating factora should be studied and the c2eate botung-m programed transition

- x

.- power output of all, or almost all, power botI:ng correlation option. combination selected which results in the.,..6g, reactors. However,if a 11mitation should ~ veld correlation (equation s.7 of AECT 3281,8. mn b tung heat trar y - apectrum and combmstions W aystems.&.I result, and if an urgent short-term need r ~ f;r additional power occurs because of December 1969). analyzed.

s. The decay ' heat ' urve described in 'theMT J'

'~

s. Afeta! worker reaction rate-.use the c

f unusual or peak demand. outage of other Baker-Just equation, with a coemenent of 1. N, proposed ANs Standard, with a 20 percentmitowance equipment, or other similar reasons the now at the junction which as entering core.to. Core flow-use o.8 a RELAP smoothed r Commission may authorize full power operation of the reactor for a limited If 8 ws are opposed. use zero dow. hot rod should'be considered to be too per-

t ('*

11. Enthalpy and pressure-use entering cent of this value unless a smauer value is., p*;i q.

. pe justiSedJne effect of volds on reactivity,'h. ] k plenum conditions, (d) Any variance authorized here-

12. Accumulator Bypass-Ibr cold leg account

' "". t i(hf5 ks during the, blowdown may be taken into w i under shall be based upon s'determina-breaks, all of the water injected by the me-3 tion of Teasonable assurance that the cumulators prior to end-of-bloadown shal) pmposed action will not adversely affecg be assumed to be lost. In this context the Faar s-wESTrNGuoUsE EvaLUarION HoDEL.a;.. -."* ,g, i Analyses should be performed for the en'..** tire break spectrum, up to and including ' d;./- the health and safety of the public. end-of-blowdown sha!! be spee! Sed as the ) time at which APrgwnta A-Accrrrasts Evattario,x Sfoorts, cornputed.

zero bre&R Sow, la Srst the double-ended severance of the largest $'Z' s"

4 INCLUDING THsIn CoNsEsVarrvs AssenEP pipe of the reactor coolant pressure.<

13. RaSood-a calculation for the reSood*

TsoNs axo Paocznvass ing heat transfer abould be performed. The boundary. The combination of systems usedikM

'3, " pas? 8-4EC EvaltarloN stoDEL Foa Pats-contaminant back pressure assumed for the for analyses abould be derived from a fatture a L.5 ' smtrmwarra aracreas analys!s should not be higher than the initial mode and effecta analysis, using'the atngle=D. Analyses sh)uh3 e performed for the entire pre-break pressure plus 80 percent of the failure criterion.

t W:

.. var W,7.. f-ne analytical techn!' ques'to be Sed 'are increase in pressure calculated for the acci-described in the topical report, " Westing' M9 *,f 1 .brest spectrum..som 0.5 ft? up to and in. dent. The fo!!osing stems should be con-house PWR Core Behavior Following a less dr*.E b 1' glu3ng the doubie-ended severance of the straints on the calculation: Jan **[. h 'b T largest pipe of the reactor coolant pressure

a. No steam Sow should be permitted in of-Coolant

'70 (Proprietary), and a supplemen: r,N(.i ', Accident" WCAP-742bL boundary. The combination of systems used for analysts abould be derived from a failure intact loops during the time period that ac-usry cumulators are injecting. ta'I rmrtetarI Westinghouse report. * @r % f' snode and effecta analysis, using the single

b. Core exit quality should be calculated failure criterion.

from entering mass flow rate and nominal e, June 1971 n in an ppro ritte ne following snalytical techniques should FLECHT heat transfer. "O"[g# P ~ ! had b 1 be used:

c. Pump resistance. K, should be calcu-

, ng o e a th t e f Ilo Ing e eptions 1. Thermchydraulle calculation during M* blowdown-IN-1321.RELAP 3-A Computer lated on the basis of a locked rotor" For breaksIrester than 0'5 ft.8-Program for Reactor Blowdown Analysis,"

d. De effects of the nitrc' gen gas in the

1. The break discharge coemcient. (Ca).

.',,, g ( June 1970. accumulator, which is discharged following used with the hfoody disc ,b accumulator water d?scharge, should be should be equal to 1 for all break sizes.

2. A suitable re811 and reSood calculation taken into account in calculating steam flow

2. The decay heat curve described in the - *..

g)20m the end of blowdown onward. as a function of time. proposed ANS Standard, with a 20 percent g

3. Fuel element heatup calculation-IN-

e. The pressure drop in the steam genera, allowance for uncertelaty, should be used.

C 445, " THETA 2.B. A Computer Code for tor s!.suld be calculated with the exist. The fraction of decay Seat generated in the ,.. h,' Nuclear Reactor Core Thermal Analysis /* ing fluid conditions and associsted loss hot rod may be considered to be 95 percent, February 1971. Inputs from 1 and 2 w111 be coef5ctents. 1 used for this calculstion. of this value. , 4.,p *' t f he user of these codes should assure him.

f. AJ1 effects of cold injection water. In

3. For large breaks in the range 0 6 to 1 self that he has rettewed available " updated either a hot or cold leg. on steam flow (and times the total area of the ouble-ended <M..

?- memos" and is using the correct versions and A P) should be included in the calculation. break of the largest cold. leg pl, two break '. 4 ;

chitee of options within the code.

g. ne hast transfer coef5clent during re.

models should be 'used. The first model * -4 a The fo!!owing assumptions and procedures Aood should be derived from FLECHT data. should be the double-ended severance (Outt. t lotine), which assumes that there is break M.Y T ~ ~ are to be used. Any assumptions not spectfled Faa? 3-CENEmat ELECTA 1C EVaLUaT!oN MoDEL should be fully just1 Sed. flow from both ends of the broken pipe, but. J., ' ;C Anal aes should be performed for the en. no communication between the broken ends.

3. Core and System Noding-f

.;Q G. RELAP--at least 3 core nodes, at least 7 tire treak spectrum, up to and including a ne second model should assume discharge i .g "; L . nodes in the primary side of each steam gen. double. ended severance of the largest pipe from a alngle node (sp!!t). erattr model, and one containment node. of the resctor ecllant pressure boundary. The

4. The time after the break for the onset of b, THETA ~at least 4 radN fuel nodes and combinations of systems used for analysts departure from nucleate boiling at the hot k

on) radial c: adding node; at least 7 metal should be dertved from a ft!1ure mode and

2. Pump Model-7he pump resistance. K*

terton as indicated in Table 2-1 of the toptcal

5. Fbr cold leg breaks all of the aster in." 'N' h spot should be equal to 0.1 second.

2nd nodes. e!lec*a analysts, ustng the single fa!!ure cit. l' used for analygis should be fully justlSed. report " Loss-of. Coolant Aceldent and Emer. jected by the accumulators prior tc end.of. p du n h "' gency Core Coo ing Models for General Elec. blowdown shall be assumed to be lost. In this dere1. r , atre of t rte Bolling Water Reacters." NEDO-10329. context the end-of-bloadown shall be spect. - g fled as the time at which zero break flow is ne analytical techntques described in a sumptions (locked or runningt should be d or the purr.p during the blowdown NEDO-10329 and its supplement should be first computed. The containment back pres. p* sure assumed for the blowdoan analysts used with the folloaing exceptions:

3. Break ' Characteristics-For large ' breaks

1. During the period of flow coastdown should not be higher than the in!tta) pre.

in the range 0.6 to y tinies the total area of after the minimum critical heat flus ratto at break pressure plus 90 percent of the increase in pressure calculated for the, accident under "N y y,, the double-ended break of the largest cold. the hot spot is less than one and untti the consideration. i leg pipe, two break models should be used. top of the jet pumps uncover, the heat trans.

6. The pump resistance, K, used for analy. ' p g.*!

Th) first model should be the double. ended fer coemetent should be calculated using the neterance (guillotlne), which assumes that D. C. Groenereld correlation ( AECle3261 mis should be fully justified. ne effect of .a., ; t - pump speed upon K should be considered. there Is break flow from both ends of the equation S.7). The more conservative of two assumptions , {* brokIn pipe, but no communication between

2. During the period oflower plenum flash. (locked or runntog) should be used for the

,y g the broken ends. *fte second model should ing untA1 the core becomes uncovered, the pump during The blowdown calculation. svume discharge from a sing!e node (sp!!t). beat transfer coemclent should be calculated A break discharge coemclent (Cs) of 1 using Groeneveld's correlation as in 1 above. 't. A calculation for the reflooding heat 4 ahruid be used for all break stres.

8. The heat transfer coemetents masociated transfer abould be performed. The contain.

ment back pressure assumed for the anaJyals . ' [.

4. Decay heat-The decay heat curve de. srith rated core spray flow should correspond should not be higher than the Initial pre. ;i '

scribed in the proposed ANS Standard, with to those derhed from experimental data, as. break pressure plus 80 percent of the increase i<^3 'J V> 1 a a.* L s-d [ fl0 ERAT REGl$ tit, Vot. '36, NO.125-fut$0AY, JUNE 29,19y1 s . s! /. :. /* .., c 2. r. '.:g;.: n;yy g. 7"*a m e. ,s r e s T- .v.- A -1

y 8-Ir

. Ms.*q, a }s.- o c. . ?. .'. J. .....-..:=-- .s,.y.mw r _'_-_, v 1 A - ~ & L

h 122*>0 NOTICES in pressu a caldstes far the no&!r.a c.dw the p9tisiens of a re.soluthn of ti.c ur. urnM ex;,ect that such issues include the

. consideranon-The ru:fonr.g nems should be constrcts rier me r.bers of the Air TrafLa Confer-following: v hether the unanimous toting ence of Amtrica (ATCP relating to the proredures currently employed by ATV $ should be permttted in establishment of comtr.ission rates for should be maintained and if not, whether a. o te intact loops dt.rtng the time period that ac. trate! c::ent sales of dornestic air trans-a representative determination of the eumuisters are injeeung. portat;cn and providing for certain conftrence membership can and should Ta core east gua:Aty shotJd be c:.:cutated haundments to the ATC process for the be effected by different voting proce. entering mass now rue and nominal selection and retention of trate! ogents? dures; whether a carrier which seeks to CHT best transfer. j

e. Pump resistance should be cateulated Dunng the course that proceeding issues take action independent of that which were raised with respect to whether the the whole conference has decided upon NeNseet. sit e [tregen gss in the procedures employed by ATCin adopting should be allowed to do so pursuant to si 8

accumulator, which ta discharged rollowtng the resoluuon. i.e., ATC's ur.arunfous requirements more flexible than th(cur-I f ecumulater water dis-ha ge,should be taken voting requirement, were contrary to the rent ones; whether it is in the public in. Into account in caJeulating steam now as a pubIlc interest because such had resulted terest to require membership in ATA as tunetton of time. in an inherently unfair compromise a condition to full membership in ATC; 4'

c. The pressure drop in the steam gen-which was reflected by the inadequate and related thereto whether it is in the 4

ert, tor should be caJeutated with the exist. ,,ing fluid conditions and associated loss oo-level of agent compensation provided for public interest for ATC to functiort as '4 in the resolution.'. part of ATA.* e ' i; f I afects of cold inpetion water, in In response to thew ategations we Acco@ngh if is ordered. That: ' citber a hot or cold leg, on steam flow (and concluded that the substantial issues

1. An investigr, tion to be known as - %

A F) should be included in the calculation. raised by the unanimous features of the "ATC Bylaws Investigation" be ini.

4

g. The heat transfer cce 'ictent durtr.: re. ATC's bylaws warranted a general in-t!ated for the purpose of determining a

! ficod abould be dertred from F't.ECHT data. Quiry indeMndent of our concern with whether such bylaws or any provisions In view of the public health and safety the commission resolutions there before thereof are adverse to the public interest considerations discussed above the Com. us. Consequently, we stated that we,and whether they should be approved -m. 2nission has found that the in'terim ac-would address ourselves to the initiation under section 412 of the Act: 3. ceptance criteria contained herein should of an inquiry relative to the unanimity

2. Said investigation be and it hereby be promulgated without delay, that no-voting procedures at a subsequent date, is set for hearing before an' examiner of tice of proposed issuance and pub!!c pro-Order 70-12-165. supra pages l4-15.

the Board at a place and time to be ' cedure thereon are impracticable, and Accordingly, we are herein instituting hereaf ter designated; and - ~ th:t good cause exists for making the a general investigation of all the ATC

3. ATA, ATC, all carrier members #of

'9' i tatement of policy effective upon publi. bylaws--not only those which encompass.A"IV, each travel agent and travel agent <~ cation in the Frer AL Rrcistra. The the unanimous voting procedures. We atsociation participating in the commis. ~ :* Commission invites a!! interested persons have concluded that the most appropri. sion proceeding in Docket 21305, and the _ 3" Ch3 desire to submit uritten comments ate avenue of exploring those issues Departments of Justice and Transpor. raised by the unanimous voting proce. tation be served with copies of this order. feet dures would be in the context of a thor. and made parties to the proceeding. s th s ate ent po Ic t srnd them to the Secretary of the Com. ough and complete investigation into the 2ninion, U.S. Atomic Energy Commission, framework of the conference in whish This order will be published in 'the FrotraL Rectsrza, eya e,c 1 ded that a fo2 mal evi.' By the Civil Aeronautics Board. W;shington, D C. 20545, Attention: ,i a'y af rp 1e on of t s' no Ice d' hen g e rn st sa fa o AL] HARa7. E If,e mea og p ,ed the FrorPAL RrcisTrn. Copies of com. ents received may be examined at the by the ATC bylaws and would be in the public interest. Our limited experience vn M141ea n!ed e-2M1m am] Commission s Public Document Room. with the unanimity provisions of the by. 1717 H Street, NW., Washington, D.C. L The Commission wi!! consider all such laws during the course of the proceedin s ! Docket No. 22118) - 7 in Doc 3 comments and suggestions with the view that it w be e t cme y di e if n p t dit na o s!o a essentially irnpossible to fully explore all ' consider holding an inforTnal pub!!c rule f the issues raised by each provision of Notice of Postponement of Prehearing Conference rnaking hearing on this Interim policy

* '"I' men a alo e Notice is hereby 'given that the pre.

(Sec.161,68 5%L 948. 80 Stat 383. F1 Stat. The basic !ssue to be resolved in the hearing conference in the above. entitled 84; 42 tLs c. 2201, 5 tr s c. 552, 553) proceeding will be %hether the ATC by. 1;vestigation is postponed until August 3, laws should be arproved or disapproved 1971, at 10 a.m., e.d.s t., in Room 503, Dated it Washington, D.C., this 25th under section 412 of the Act. Of course' Universal Building, 1825 Connecticut day if June 1971. the subsidiary issues are subject to delin. Avenue NW., Washington, DC, before the For the Atomic Energy Commission, eation at the prehearing conference. We si ea e W. B. !LicCoot., mation and evidence, proposed atate. Sepetary of the Comm!ssion. j,^y,,1'y'jj,u nQ,s ments of issues, and procedural dates by eo Int Doc.71-9285 n:ed 6-2s-71:8:52 am] domestle scheduled air carrier industry trade c un W hau d M @nahns association. The other conferences are: The is accordingly postponed until July 12, Atritne nnance and Accounting conference: 1971, and the date for similar filings by the Personnel Relations Conference; and the Aloha and Hawa!!an Airlines, and by any 51 AB0MMM MW

i>>ine o erations conrerenee. *w desis tri-other parties. is postponed untii Juiy 26 v

4 [ Docket No. 23542; Order 714127] martly in trafBc and sales matter and has a 1971, stated purpose of increasing the use and AIR TRAFFIC CONFERENCE OF ""I" **' ManspoMahon a nd fuMhn. AMERICA Ing the Interest of the member carriers to

We do not (Itend in this proctedtog to g desa with their mutual trame, sales, and ad. reenamin, our approva: of ans prior reaolu.

Crder Inllilul.mg Investigation vertising problems. tion adopted by AM and approved by the s Agreements CAD So44-A144, Docket 21305. Board since the status of such resolutions Adoptad by the Civil Aeronauti:s Board ame attersuon was rataed initially by under section 412 has already been esamtned it its oftce in Washington. D C.* on the DF ^ "I^ "hh **

I' 3*' "'d Ih'" DT

""# d''*' "'d T* 'D ' ' ' "' 'h * " '***

24th day of June 1971-the Department of Justice which argued that of the investigation afects any estan"t reso.

the Board consider the unantmous voting fution, we shan consider such matters sub. Cy Opinion and Order 70-12-165, De. procedures either in the commission proceed. sequent to the conclusion of the {nter 31,1970, the Boart! passed upon sng orin a subsequent proceeding. Investigation. U f t:f rat RfCilf!R, VOL, 36, NO,123-fU!$0AY, JUNE 29,1978 4 Q d W .~ MWJ,~.id$,M,65D.2 $;$ p. ; e.

- o

~ 1 g , 21082 N311CES opplication for license dakd Novem. and by Combustion ~ Endneesing.1nc., Stoltr.wd: con 'Resood Analysts"-.yers ber 25.1970. and amendments thereto have been reviewed by the Commission, BAw-loc 71 october 1971. dated December 30,1970. March 26,1971, together with the conservathe assump-3. mHA 1-B. A Computer Code for Nay 20,1971, September 30,1971 Octo. tions and precedures eppropriate to each "r "**N ***'C'"*'"'I ^"'T*38 *

.2 ber 22,1971, and November 16,1971: (2) model. The amendn:ents to the Interim Copatim Report IN-1445, y

ayy the preposed facility license with Techn1 Acceptance Criteria which follow add e, -aruitinoise Analysis of B&W's 2548 M c 1 Specifications, and (3) a related these acceptable new evaluation models hfWt Nuclear Planta Durtng A Imas-of. Cool. ,( ' Safety Evaluation prepared by the Di. as Parts 4 and 5 of Appendix A. Con. ant Accadent"--Report BAW-loo 34. October veion of Reactor Licensing, all of which forming amendments have been made 1871 4 } cre atsuab!e for public inspection at the in the body of the Interim Acceptance er ce nn.:.uion's Putlic Document Room at criteria. slowdoua period 4' f lill H Street NW., Washington, DC. A - 1. The third and fourth paragraphs of 1.1 Core and system Noding. )

j copy of each of items (2) and (3) above section III are amended to read as shibe be d7and t$e ourEm mty be ob'ained upon request sent to the follows

^. M. Atom.e Energy Commission. Wash-erator nodes (primary side) should be used. ington, D C. 20545, Attention: Director, Izt. EVALUAr1oM or EMEaceNCY cone Coot. A containment node abould be used. 20 systru psaroaxacs 1.1.2 '11rrrA 1-B-At least ela tedlal fuel D. vision of Reactor Licensing. modes and two radial cInd nodes. In conjune. i. . Dated at Bethesda, Md., this 8th day mon with at least to axial fuel nodes, abould 3 *.,, of Daember 1971. Detailed technleal reviews have been bo used. .,s - performed by the AEC of the computer 1.2 rump Model. Tor the Atomic Energy Commission. codes currently available for predicting erect oUpu aDire e a u'14 be l'* to DcNnn J. Exovnoty emergency core cooling system perform

b'.-

Assistant Dircefor for Reactor ance. The AEC has developed sets of tully justined. The more conservattee of two I. assumptions (locked or running) abould be Operoffons, Die 4fon o/ Re-suitably conservative assumptions and used for the pump during the blowdown g acto @ensing. procedures which together with the com. calculation. puter codes comprise five appropriately 1J srest charsetertatics. j IrR Doc.71-1852o F11ed 12-17-71;8:47 am) conservative evaluation models to use For large breake In the range of c.s-10 for evaluation. The codes used in one umes the total ans of the double ended f" [ Docket No. 50-113] of these evaluation models (described in break of the largest cold. leg pipe, two break Part 1 of Appendix A) are available from snodels should be used.no arst model should j UNIVERSITY OF ARIZONA the AEC. Codes used in the other four be the double. ended severance (gulliotine) which assumes that there is break now troen ^ evaluation models (described in Parts both ends of the broken pipe, but no com. .t, Extension of Compferion Date of 2-5 of Appendix A) contain proprietary munication between the broken ends. The A Construction Permit material, for which summaries are or second model should assume discharge from De UnS ersity of Arizona. having filed soon will be publicly available. Other * *jn,g n e sp o request dated November 29,1971, for evaluation models are under review by A break discharge coeractent cs = 1.0 should exten' ion of the latest completion date the AEC. be used for au break anes. l spectied in Construction Permit No. The five acceptable evaluation models is Decay nest. ^I CPRR-111 which authorizes modifica-presently included in Appendix A are The decar beat curve described in the ilin of the existing reactor facility lo-different in many respects, and the sets proposed ANS standard,* incrossed by a 4 20 g cated on the University's campus at of conservative assumptions and proce. percent a!!owance for uncertainty abould be ii dures also differ from one another. Rese used. The fraction of decay beat senerated h. pDeson, Am andVexUs on**"r'lld Eti, Ur7uNE s'5 **ifferences d arise from two principal 1" 'h' "'t **8 "' T D' ****8d'"8 ** D' "8 d ,'%"L,s.,,,m ya,,,,,,,,,. a'15:,tiynf,"n'A"g* $ *,P','1*!e'"n u ) d h ,), 'tlin 185 of the Atomic Energy Act of analyses, leading to di!!erent areas where 1954. as amended, and 10 CFR I 50.55 of The time to DNB abould be calculated using 4 g the Commission's regulations: imperfect knowledge or analysis require any one of the programmed options of the conservative treatments, and (2) differ. TRWA 1-B code, A ft is hereby ordered, That the latest g ences in hardware among the various re. 1.7 rum mostmp Rest Trenifer. P completion date for Construction Permit NA CPRR-111 is extended from actor designs, such as spray vs. flood **fne oroeneveld e rrelation (equation s.7 cooling and hot leg vs cold leg vs. direct "' al December 31,1971 to September 1,1972. vesse! injection. boutng heat transfer ngtme. used o - o or l~ Date of issuance: December 8, 1971. ~ ~2. New Parts 4 and 5 are added to Ap-1.s werer. Water Resetion Asie. For the Atomic Energy Commission. pendix A to read as follows: ne meta!. water reaction rates should be 6 i t Baker.Just equatson J PzTrn A.Monats, twesenueo Tuus Consuurry: A ssc"F* ,1

Director, stons awn Pnoctorata 1.s Core riow Aere.

DMsfon of Reactor Licensing, ne smootbed core now rate at the hot e o e e e spot location, derived frtan the CRAFT code [T'R Doc.71-1sS21 rtled 32-17-71.0:47 am] Paaf 4-ssBCoCE anD Witcos EVsLrATIoM and mult! Plied by o.s. abould be used as k. MoctL e input to the THPTA 3-B, fuel rod bestup calculauon.

CRITERIA FOR EMERGENCY CORE Analyses should be performed for the en*

1 to Entha?py and Presture ti,e bnas spectrum, from o e it.', up to an.2 The core pressure and the entert'on ptenum COOLING SYSTEMS FOR LIGHT. Includirig the double ended severance of the enthaspy. derseed from the CRAPr code, WATER POWER REACTOR $ 8 8 "' P '.P'

' th ' "'*' ***! ' "' P""'e should be used as :nput to the TurTA 1-B boundary ne combination of systems used calcultuona.

Interim Acteplante for analyses should be derived from a failure 3.11 Core riooding rank,ypass. mode and effecta analysis, using the single ydr a>ld leg breaks, an of t.be water in. On June 29,1971, the Atomic Energy fauure ertterton. + jocted by the core needing te prior to the Commission published its Interim Policy 'The analytical techniques to be used, with Statement, Interim Acceptance Criteria eymptio o pr e es dgert d in for Emergency Core Cooling Systems for Light. Water Poser Reactors." (36 F.R. tog topica:g, Description down of cransum ruel Thermal Reactors." rsa *, - 3,,c33 of Model for subcommittee ANS-8. American Nuclear 12247.) The Statement included, as Ap* pendix A, Parts 1-3, acceptable evalua* Equilibrium thCA Analysts Program"-Re. Society. October 1971. Copfee may be obtained port B Aw-too30, october 1971. from Dr. M. E. Remley, Chairman. Subcom.

tien models, including conservative as.

s. -atrLooD--Description of Model for snittee ANS-a, Atomics International. Post Omce Bos 309. Canoga Park. CA 9130s. Ooples sumptions and procedures. Since that

. are avaliable for pub!Ie inspection at the time, proposals for evaluation models en.ts en2uation modet app!!es to resetors commisston's Public Document Roorn,1717 a Made by The Babcock and Wilcox Co. contatatng in ternai veni valves. street Nw washington. DC. U FIDIRAt RfCllitt, V0t. 34, NO. 244-SAIJt0AY, DICIM8tB 18,1971 .. Y,. >!. ~. ' ~ ? '.- M ht' ? i .,.~. gghr$}.,4. '. s.,,. q.. i g

e NLTICES 24083 pg.of. blowdown should be escumed to be last In this contert the end-of tdowdown lost. In this centert the end.of.tlowdown abould be considered to be the time at which abould be considered to be the time at which Dated at Germantown, Md, this 16th I sero break now la niet computed-zero break Bow is Srst computed. day of December 197L 1.5 Pomp Modet.. 'rhe pump charactertatica, including the Fcr the Atomic Energy Commission. Rejtood PeNod 2.1 ne core reSood performance should be egees or pump speed. for analyses abou14 be . F. T. Rosas., j

- 3culated using the ItIncoD eode fully justined. ne more conservatste or two Acting Secretary of the Corrasmissfors.

,mitbed in RAW-loo 31. assumptions (locked or running) abould bo ~ 2J An adsabsue bestup of the com should used for the pump during the blowdown.{FR Doeff1-19645 F*)od 13-17-71;10:28 mm] be assumed from the ame of end.ot blow-calculation. down unut the emergency core couting Auld Rehod PeNod ] resches the bottom of the core. 2.3 ytr the M8ood emiculation. the con. 2.1 ne reSood sequence of events should Sainment pressure should not escoed the be calculated using the analitical methods n Initta2 prebreak pressure plus 80 percent of described in CENPD-26 and its supplements. the gnerenae In pressure calcu!sted by th ne containment back pressure assumed for snethods used for containment desagn for the the analysis abould not be higher than the INTERNATIONAL AIR accident under consideration-initial prebrent pressure plus so pereens or TRANSPORT A550CIAT ON 2 4 ne steam So'w rste from the core. as the increase in pressure calculated by th* . Regard #ng Possengelr For gt asects the NeSood pressurwdrop calcula" metboos used for containment design for the O tions, should be calculated on the basis of accident under consideration-b ns a equal SJ All efects of cold injection water, in Issued under delegsted authority De. eember 7,1971. A either a hot or cold leg on steam Sow (and,TrafDc Conferene.greement adopted by eccienta.The laternals vent valves abou3d be 8 4 ln 1 of the Internations ir Transport Association relating to the only now path from the upper plenum. gy in ! et ps transtents are injecting abould be calculated as do. time period that the safety injection 2.5 The fuel rod temperature should be calculated on the basis of heat ment CAB 22824. tranarer coescients derived from flecht. scribed in Supplement 2,of CENPD-Se. no An agreement has been filed with the nar a-contacstron rwenerzme steam now rate from the core as at asects amoarrow asonzz. the pressure-drop enleulations should be cas. Board pursuant to section 412(a) of the Ana!rses should be perforrned for the en-culated on the basis of core heat transfer Federal Aviation Act of 1958 (the Act) e emetents that are equal to or greater than and Part 261 of the Board's economic aste break spectrum, from 0.5 ft.', up to and FLECHT heat transfer coemetents. regulations, between various air carriers, Nsfp!pe o t$ El foreign air carriers and other carriers 35

d e

r s embodied in the rhuhns of Trad boundary. ne combinatson or erstems used 2.4 no erecte at the nitrogen gas in the Conference 1 of the International Air for ana:Tses should be dertved from a failure safety injection tank which is discharged fbl. Transport Association (IA mode and efects analyns, using the singte towing water discharge, shou)d be taken into adopted by ms!! vot tauun criterton, account in calculatJng steam now as a funo. ne analytical teebniques to be used. with tson of time. been ass!gned the above-designated CAB the assumptions and procedures described in 3 31.1-2 e. are those described in the fo! lowing 2.5 The pressure drop in the steam genera

agreement number.

topical reports. Sultable nonproprietary re. tor should be calculated with the existing The agreement would amend an exist-ports are to be submitted. Suld conditions and associated less coefB-rMuWn gomning ecemy-class csonta. i

1. "Descr!ption of Loss of-Coolant Calcu*

fares within the Western Hemisphere by lational Procedures." CENFD-26. Proprietary 2.8 ne heat t.ansfer coemelent for the tuet the inclusion of a specified fare reflect-Combustion Engineering Report, August

rod temperature ca3eu!ations during rencod ing nN direct servloe betDreen Mazatlan 1971.

nhould be derived from FLECHT da*.a (

s. " Description of Loss-of-cociant Calcula-In view ' f the necessity, from the stand-and Denver. 'Ihe proposed fare is $

o one way* tional Procedures." Preprietary Combustion Engineering Report, Supplement I to CEN* point of public health and safety of pro-Pursuant to authority duly delegated . PD's. october.1971. Tiding interim ciiteria for emergency by the Board in the Board's regulations,

s. asteam venting Experiments and netr core cooling systems app!! cable to all H M MR h nd kW.on a Wa-App 11 cation to CE Evaluatson &fodel." Pro-nuclear power reactors, the Commission tive basis, that Resolution 100(Ma11884) prtetary Combustion Engineering Report

fo nd tht tM amendments con- 061, which ts incorporated in the above-supplement 2 to CENPD-26. November,1971. tained herein should be promu} gated designated agreement, is adverse to the

4. "Efotsture Carry over During PWR Post-1,0CA Core Rer.n." informal proprietary Com. without delay, that nottoe of proposed 1s-p c WM M b Mh M W M tustion Engineering submittal November. suance and pr!Or pubilC procedure are, Accordingly,if (# ordered, That; 1971.

tmpracticable, and that good cause exista Act!on on Agreement CAB 22824 be h ~d88"#'d*d for making the amendments effective and hereby is deferred with a Tiew to-1.1 Dfscherpe Coeff efenf. upon publication in the FEDERAf. Rtets-ward eventual approval. ne brent discharge corsetent, (en) used Tsa. The Commission has issued a notice with the Afoody d!scharge Sow model abould scheduling a public rule making hearing Persons entitled to petition the Board U ' on the Interim Acceptance Criteria for for review of this order, pursuant to the Duergency Core Cooling Systems for Board's regulations,le CFR 385.50 may* 1 D ear I The d$ car beat'eurre described in the pro. L!ght Water Cooled Nuclear Power Re-within 10 days after the date of s'ervice posed ANs standard.* Incressed by a + 20 per-actors (38 F R. 22774). The amendments of this order, file such petitions in sup-cent enorance for uncertatott, abould be herein M11 be considered at that hearing. port of or in opposition to our proposed ,med. rte fraetton of decay heat generated Interested persons desiring to participate action herein. in the hot rod may be considered to be 0.94 Emes this tarve unless a arna!!er value se in that hearing should refer to that This order Mll be published in the Just1 Sed-notice for the procedures available. In. FrnrRAI, Ercistra. terested persons who desire to submit (stal.1 ~ PuntIs T. KATLoa~ r la breats t e' range 0.6 to 1.0 written comments or suggestions for con-times the total area of the double-ended sideration in connection with the Actinp Secret 4ry, brent of the largest cold.seg ptpe, two brear amendments should send them to the [rR Doc.71-18547 Filed 12-17-73;s:40'aml modets should be used. The nrst anodel Secrvtary of the Commission, U.S. abould be the double. ended severance (guu* totine), which assumee that there is breat Atomic Energy Commission, Washingten. IDockat No.18257) D.C. 20545, Attention Chief. Public Pro 50UTHERN TIER COM now from beth ends of the broken ptpe. tut eeedings Branch, within 30 days after no communscauon tatween the broken and' pubucation of this nouce in the FrotaAr. ne a cond modet abound assume discharge mm CW W ments received STOP INVESTIGATION IHOUSTON. trom atngie mode teput). No anay be etamined at the Commission's -' MIAMI PHASE) aka, a th water in. Pubue Document Room,1717 H Street Notice of Preheoring Conference jected by the sarety injecuon tants prior to fad of. blowdown abould be sasumed to be NW., Washington, DC. Nouce is bereby given that a prehear. d asee footnote on page 240a2. (Sec. let, et Stats 948, 80 Stat. ss3,81 Stat. IDg conference ln the above entitled mat-64: 42 U.s c. 2201, a U.s c. 362, 653) teris assigned to be held on January 18, 780tRAt Rf CllitR, VOL 36, NO. 244-$ATUADAT, DIC8MOtt 18,1971 I 1* ~' ..&**e

o. n,; &

-.J h b$5 Y. ~

m ,A (cm i () L) SUPPLEMENT TO LICENSEE'S APPENDIX B List of Exhibits Identified at Admitted at Exhibit Number Description Transcript Page Transcript Page TMIA Mailgram Exh 20 TMIA Deposition of Julien 30,119 31,697 Abramovici (Oct. 15, 1984) as TMIA Exh. 32H .(Page 42 line 19 to page 50 line 13) TMIA Mailgram Exh 25 Memorandum from Roger A. 30,709 30,863 Fortuna to James Cummings (Nov. 6, 1980) (re IE admitted only Inspectors' Alleged Failure to Report Information Re March 28, 1979 Hydrogen Explosion at TMI-2) (marked up) TMIA Mailgram Exh 34 Testimony of David H. Gamble ( Nov. 1, 1984) 31,415 Rejected at 31,415 TMIA Mailgram Exh 41 Reactor Building Pressure 31,606 31,666 Strip Chart A (March 28, 1979) TMIA Mailgram Exh 42 Reactor Building Pressure 31,612 31,666 Strip Chart B (March 28, 1979) Reactor Building Licensee will keep custody and 31,627 31,628 Pressure Strip Chart be required to produce upon ap-(Original) peal or in any court review. Anamolies between original and duplicates have not been resolved.

i SUPPLEMENTAL APPENDIX C r-

\\me]

TMIA Adopts Licensee's Appendix C and supplements As Follows: BEEMAN,.LORRAINE Rad Chem Tech Jr., TMI-1. BENNER, RICHARD L. Rad Chem Tech Jr., 2nd, TMI-1. -BOYER, ROBERT E. Control Room Operator. - TMI-1. Reported to work at 2:30 p.m. on 3/29/79. CVIJIC, GEORGE L. Auxiliary Operator B, TMI-2. CONRAD, CURTIS A. Auxiliary Operator C, TMI-2 on 3/28/79. Reported to work about 7:00 a.m. DEMAN, JOSEPH H. Foreman Radiation Protection. Reported to work at Unit 1 about 6:00 or 6:30 a.m. on 3/28/79. Later went to Unit 2 early that morning. HAHN, EDWARD'D. Utility Construction and Maintenance, 2nd Class, 2nd Yr., TMI-1. 'HETRICK,' JAMES _L. Maintenance, TMI-2 JOYCE, MATTHEW Instrumentman 2nd Class, TMI-2. 'KEMBLE, DAVID A. Repairman 1st C1. (Certified Welder)~, TMI-1. LIONARONS, J. K. Auxiliary Operator A, TMI-2. NATALE,, RONALD D. Repairman 1st C1. (Certified Walder), TMI-l PELEN,. MARGARET A. Rad Chem Tech, TMI-2. Reported to work about 7:00 a.m., 3/28/79 and . monitored people, trains, and cars.- RETCH, DAVID E.- Instrumentman 1st Class, TMI-1.. RIGGENBACH, THOMAS Instrumentman 1st Class, TMI-1. O o.

PAGE TWO SUPPLEMENTAL APPENDIX C ROCHINO, A. P. Engineering Mechanics Manager, GPUSC, New Jersey. Provided technical assistance at Unit 2 on 3/30/79. SMITH, DONALD E. Control Room Operator, TMI-1. UMBERGER, RICHARD R. Maint. 2, Mechanical, TMI ZEITER, DAVID E.. Rad Chem Tech. Reported to work at Unit 1 about 11:00 p.m. on 3/27/79. Later went to Unit 2 about 7:00 or 8:00 a.m. on .i 3/28/79. i O

_g 00'nEirr UNITED STATES OF AMERICA ^h" NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board V < G :'yiEi nt, COCXE'f In.the Matter of. ) U p, ) . METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP ) (Three Mile Island Nuclear ) (Restart - Management Phase) ' Station, Unit No. 1) ) ) ) . I hereby. certify that a copy of the foregoing Three Mile j. Island Alert's Proposed Findings of Fact and Conclusions of Law on Dieckamp Mailgram Issue has been served this 8th day of February,21985, by mailing a copy first-class, postage prepaid to the following: Service List' -

Administrative Judge Docketing and Service Section (3)

'Ivan~'W. Smith, Chairman Office of the Secretary . Atomic Safety.& Licensing Board U.S. Nuclear Regulatory Commission !U.S.iNuclear Regulatory Commission Washington, D.C. 20555 ' Washington, D.C. 20555 Atomic Safety & Licensing-Board

Administrative Judge Panel Sheldon'J. Wolfe U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board Washington, D.C.

20555 U.S. NuclearcRegulatory' Commission

Washington,1D.C. 20555 Atomic Safety & Licensing Appeal Board Panel

Administrative Judge U.S. Nuclear Regulatory' Commission

.Gustave A. Linenberger, Jr. Washington,~D.C. 20555 Atomic Safety & Licensing. Board-U;S.. Nuclear Regulatory Commission

Jack.R. Goldberg, Esq.

Washington,' D.C. 20555 ' Office of the Executive Legal Director l' -,f U.S.' Nuclear Regulatory Commission Washington,-D.C. 20555 L .L. ~ ^ *

--n v . Thomas Au, Esq. Joanne Doroshow, Esq. Office of Chief Counsel The Christic Institute Department of Environmental 1324 North Capitol Street Resources Washington, D.C. 20002 505 Executive House P.O. Box 2357 Michael F. McBride, Esq. Harrisburg, PA 17120 LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue N.W.

Ernest L. Blake, Jr.

Suite 1100 Shaw, Pittman, Potts & Trowbridge Washington, D.C. 20036 1800 M Street, N.W. Washington, D.C. 20036 Michael W. Maupin, Esq. Hunton & Williams Mr. Henry D. Hukill 707 East Main Street Vice President Post Office Box 1535 GPU Nuclear Corporation Richmond, VA 23212 P.O. Box 480 Middletown, PA 17057 Ellyn R. Weiss, Esq. William S. Jordan, III, Esq. TMI Alert Harmon, Weiss & Jordan 315 Peffer Street 2001 S Street, N.W. Harrisburg, PA 17102 Suite 430 Washington, D.C. 20009 Mr. and Mrs. Norman Aamodt R.D. 5 TMI-PIRC Legal Fund Coatesville, PA 19320 1037 Maclay Harrisburg, PA 17103 ~Ms. Louise Bradford TMI Alert 1011 Green Street Harrisburg, PA 17102 / (')l ' ibd .L, v 2~ LyngeBernabei

Hand Delivered h

.}}

ML20106D126

Text

c. Conclusion

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