ML20126B210
| ML20126B210 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/25/1980 |
| From: | Pollard R Chesapeake Energy Alliance |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML20126B213 | List: |
| References | |
| NUDOCS 8003100068 | |
| Download: ML20126B210 (8) | |
Text
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UNITED STATES OF AMERICA CE A: DIS: llc-80'.02.25'.
,P~~~~ W iI NUCLEAR REGULATORY COMMISSION
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Y BEFORE THE ATOMIC SAFETY AND' LICENSING BOARD
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In the Matter of
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FIRST SET OF CHESAPEAKE ENERGY ALLIANCE' lNTERROGATORIES TO LICENSEE Intervenor, Chesapeake Energy Alliance (CEA), hereby submits the falluwing first set of interrogatories to Licensee (LIC).
In light of CEA's lack of financial resources, and its distance from LIC's Discovery Rooms and NRC's Public Document Pacms, CEA requests that when LIC's answer makes reference to any decoment, or relevant portions of a document, that is not more than five (5) pages in length, a copy of that document be attached to LIC's answer. CEA also rcquests that whenever a dccument is referenced in an ans..er, the relevant page numbers and/or sections in that do'cument be identified.
Furthermere, CEA requests that when a document referred to in a LIC answer is one that has been served on CEA, that an asterisk (*) be placed besidesithe reference.
For definitions of the terms 'decument' and ' identify', CEA hereby o'dopts the definitions applied by LIC in its 'First Set of interrogatories to Intervenor Chesaceake Energy A llianc e, Inc.' (80.01.18). " Probability' is defined below, at 8.
N CEA requests that the attached interrogatriec ' e answer d fully, in writing, and under oath, by an y member's of LIC's staff who I as personal knowledge thercoi. The answer to each interrogatory should contain the name(s) and identification of the persan(s) scpplying the ansv.er, and whether or not he/she has verified the answer. Whe neve -
a full and complete answer can act be furnished at this time, provida as full a areft as is possible of LIC's answer, indicating those rpecific aspects of the answer ;hnt can not be provided, and give a brief explanation as to why the full anzver enn nct be provided at this time. Alm, indicate tha approximate time that a fo!! an ver can he a.pected.
f n:errerateries (Numbered according to the contentica) 5-1 Summarize and exalain LIC's pcsition on the contention.
Idantify eny and ail documents relied on by LIC in reaching that position.
5-2 Identify thos2 aspects of the contention tl at LIC considers to v. marters of controversy.
For each such aspect, summarize briefly the cccasing posidens an the controversy as perceived by LIC.
Identify and summarize any and all documents in suppert of either position.
5-3 Identify and briefly summarize any and all documents kncwn to LIC ther would tend to provide evidence and/or support for this contention.
5-4 Identify any and all persons that LIC intends to have testify en this contantion; state the qualifications of each person; and present cf the testimony a summary that person is expected to provide.
5-5 Identify any and all present or fermer membes cf LE staff ~.~,,i zent frem t' e r
overall llc position on this contantion, and for "ch such ;
m, ro M y a summary of hiseher,ii;sarina ensition on the r.ar.i c8003100Ofst
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e 5-6 Identify the critical or central parameters of this contention as it is perceived and understood by llc, and briefly summarize LIC's position on, and evaluation of the importance of, each such parameter.
5-7 Provide a complete and accurate description of the present storage of radioactive water from the TMI-2 cecident, specifying where all th at water is being stored, and providing on estimate of the radioactivity levels (by isotope) of the water.
5-8 Provide a detailed description of the proposed methods for decontaminating the radio-active water from TMI-2.
Identify and describe any and all documents, based on actual previous operating experience with those methods, th ! demonstrate that the proposed clean-up methods are both effective and free from risk.
5-9 Describe in detail any and all evidence that demonstrates that the EPICCP-Il system being used for decontaminating TMI-2 intermedicte level radicactive water has operated less effectively or safely than LIC had proje:ted,
Describe the present expected schedule for d2 contaminating the intermediate level water with EPICOR-il, and compare that schedule with the schedule initialiy projected by l
LIC. Provide full justification for any revisions that have been made in the schedule.
Identify any and all documents relied on in the an;<.er to this interrogatory.
5 -10 Describe the expected schedule for decontaminating the high level water presently in the TMI-2 containment building. Also provide on estimated overall schedule i
for the completion of all the major steps in the TMl-2 clean-up.
i I
5 -11 Identify and describe any or d all accident scenarios at TMi,-2 during the clean-up that could generate additione. quantities of radicad ive waste water; der.cribe the probabilities of eak such accident scenario, demonstrating the basis and justification for these probability estimates; for each such accident scenario, estimate the quantity of radioactive waste water generated and the levels cf rcdioactivity of the water, describing the mechanism by which the radioactive v.c:te water will be generated; and for each such accident, identify the available.wrag e space that would be used for the waste water.
during clean-t;p 5-12 Identify and describe any and all potential accidents at TMI-2 Mat might ircpact cn the operation of TMI-l, including but not limited to those accidents rFet v.oald require site evacuation of Three Mile island; for uch such aca !unt, decribe the probability of its occurrence, showing the basis and ju.tifico>ie > Ter the prcbcbility estimate; for each such accident, describe the impact it wouM e.ve on lhe operation of TMI-l; identify any and all documents and persons relieu iden:ifying the u
accident scenarios and estimating the priabiliti s of each ac 1
o-l Answer the interrogatories 5-1 through 5-6 as they epply to 1: t r ia r e.
lhru 6-c 6~
Identify the rate, in gallons per minute, at which radioacti. -
.c er o beino discharged, or is leaking, from the primary coolant system cf T! 41-7.
D:s:rie the source and lecation of each such leak or discharge in th: crimary cociant system; for each leak / discharge, describe in detail t' 2 r m aa ;u. : tbnr cce h aina planned or implemented to correct the leak / discharge lacm y a,q end a4 j
documents and per:ons relied on to answer this interrsgatory,
c-5 Identify and describe the probabilities of any further I As ' 3rc:.m TMi-2 primary coolant system, with cartict.lar r:4rene 2 9 ywAs -crce:bn of seals, and/or embrittlam ent of volves, and/or arrhs'k w
,r Mio J oi:2q provide justification and basi: for the e:ti"cres d siiii.
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ccrrocien and embrittlement, citirg cry anu.: i,
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,; abrittlement
3 in the primary coolant system of TMI-2, and identifying the author (s), and their professional qualifications, of the cited documents.
Identfy and describe the measures that are being taken or planned to reduce or eliminate the probability of such corrosion or embrittlement.
6-9 Identify,and estimate the probabilities of, any and all leaks from the TMI-2 containment building, with particular reference to any pessible corrosien and/or embrittlement caused by the radioactive water in the containment building.
Identify the basis and justification for the probability estimates, citing any and all documents relied on.
Identify and describe the measures that are being planned or implemented to prevent such corrosion or embrittlement.
c-10 identify any and all sequences of events at TMI-2 that could resuit in substantial loss of reactor coolant.
Distinguish betweenthose sequences that are predicated on operator error and those that are predicated on equipment and/or instrumentation error or malfunction. Estimate the probabilities of occh such sequence, showing the basis and justification for each such probability estimate.
6-ll Describe any and all presently unused storage tanks that are available to receive major additional quantities of radioactive water from TMI-2 if needed, giving the capacity of all such storage tanks.
If any storage tanks presently assigned to TMI-l could be required to hold such radioactive water, d escribe the mechanism by which the radicactive water could be transferred from TM!-2 to TMI-l in an emergency.
7-1 Answer the interrogatories 5-1 through 5-6 as they apply to contention 7.
thru 7-6 7-7 Specify and describe in detail anyaand all potential radicm:tive pathways for which the monitoring provisions described in the TMI-l Petart Report and reviewed in the NRC Status Report would be incapable of discriminating between TMI-i and TMI-2 effluents.
i 7-8 Specify and describe in detail any and all sequences of events at either TMI-l or TMI-2 that could lead to a breakdown of the ability to distinguish between the radioactive effluents of TMl-1 and TMI-2.
For each such sequence of events, describe the estimated probability of its occurren:c, and 'the basis and jurtification for deriving the probability estimate,,
5-1 Answer the interregateries 5-1 through 5-6 as they cpply to cantantion ^.
thru 8-6 2-7 ldentify, and provide a detailed summary of, any and all documents that have been prepared or commissioned by or for LIC concerning its n:onagemnt strength and capability.
For each such document, identify tha auther(s) ord their professional qualifications.
5-8 Identify any and all aspects of LIC 's management capability, in rescect of which L!C, NRC, or any other party has uncovered evidence of inmiequacy or deficiency.
For each such aspect, describe in detail whct measuras have been taken, or are planned, to remedy the in:dequacy or deficiency, poviding a fuli and ccmplete justification as to how LIC can demonstrate that the remedial action will indeed i
ccrrect the management inadequacy or deficiency.that has been identified,
3-?
Identify,and provide a detailed summary of, any ard all dccuments per%ining to any investigation of the perceptions and attitudes of L!C's co f';yeus (Fr2sont and
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former) of its management capability and practice, include beth documents that
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ore specifically concerned with LIC's management of the TMI-2 accident, as well as those concerned with LIC's overall management capability and practice. For i.
each such document, identify the author (s) and their qualificatiens.
8-10 Has LIC conducted, or caused to be conducted, any systematic investigation (s) into the attitudes towards, and perceptions of, LIC by persons who have left the employ-ment of llc since March 28, 19797 If so, provide a detailed summary of the conclu-i sions of such investigation (s), and identify and describe the professional qualifications of the persons conducting such an investigation, if no such investigation has been conducted by, or for, llc, provide a thorough justification as to why such investi-gation would not provide needed insight into LIC's management ability and practice.
j 8-11 Are the employees of Llc affiliated with any Labor Union (s)? If so, (a) identify the i
Union (s), describe the gfievance process, and provide a summary cf the grievances j
that have been filed since TMI-1 came on lina, along with a summary of the dis-i position of those grievances; (b) identify and provide minutes of any meetings between l_
union representatives and management ; (c) if LIC's employee s are not represented by l
Labor Union (s), describe in detail any formal or informal grievance procedure avail-L able to LIC employees to current management and/or safety problems; and provide i
a summary of the grievances that have been filed under this procedure, i
i 9-1 Answer the interrogateries 5-1 through 5-6 as they apply to contention 9.
through l
9-6 9-7 Identify, and provide a detailed summary of, any and all documents prepared er j
commissioned by or for LIC since March 28, 1979, concerning the adeauccy of LIC's i
financial resources. For each such document, identify the author (s) and describe l
their professional qualifications.
9-8 Provide a summary of LIC's present financial status, with projections of income and expenditure for the next 12 months. Identify the principal assuaprions incorporated in those projections, including the clean up costs for TMl-2, replacement pcwer costs for TMI-l and TMI-2, decisions of PAPUC and NJBPU concerning rates and l
rate base, and the estimated date of restart (if any) for TMI-1. Provide a deciled justification and basis for the assumptions.,
9-9 Describe in detail any and all action LIC has taken, er plans le ra%, to r 2medy a.;y financial weakness of LiC. In particular, describe in detail any proposed cercorate reorgani otion plans that are being considered in order to remedy LlC's financial status,cnd demonstrate how such reorganization would in fact remedy LiC's fincncial status.
9-10 Describe the financial impact on llc that would result if PAPUC were a) to revoke MET ED's standing as a public utility, b) to exclude TMI-l from its rate bes, until such time, if any, that TMI-l is permitted to ra: tart. Describa in detail the effect on LIC's financial ability to operate TMI-l that a; and b) abovo would have.
12-1 Answer the interrcgatories 5-1 thcough 5-6 as they apply t, cometion 12.
through -
12-o 12-7 Provide a detailed nplenation cf LIC's criteria fer da eminir ma the ralm
5 of possible accidents, which accidents fall within the design basis. If LIC's criteria is based on the assumption of single failure (of systems or components),
provide a full and complete justification for so limiting design basis accidents, and for excluding design basis consideration of multiple failure accidents. If any assump-tions are made concerning probabilities, provide full and complete documentation of the basis and justification for computing such prcbabilities. Identify all documents relied on, and for each such document, identify the principal authors, their profession-al qualifications, and relevant publications.
12-S identify any and all known documents that challenge LIC's justification for refusing to consider multiple failure accident: in develeping design basis criteria for nuclear power plant operation. For each such document, identify the principal author (s),
their professienal qualifications, and relevant publications. Provide a brief, but detailed summary of the arguments advocated in each such document.
12-9 Specify, in numberical probability terms per operating reacrer year, the probability of an accident below which probability the accident is net considered credible by LIC. Provide a full and complete justification for the LIC's selection of thut pro-bability level as the cutoff p'oint for accident credibility. Identify any and all docu-ments relied upon in this answer.
12-10 Describe in detail the process relied upon by LIC in ecmputing the prcbability of any given accident sequence. Provide detailed and thorough justification for this com-putational method, paying particular attention to the respective determination of the role of human (operator) error as compared to roles of equipment and instrumentation information malfunction. For each of the above-identified three components of error (operator, equipment, and instrumentation-information) demonstrate the extent to which the assumed probabilities are based on past experience or on other estimates.
Wnere past experience is used as a basis for probabiitty estimates, state whether the estimate is based on past experience with identical reactors and control room designs to TMI-1; if not, state what methods are relied upen to take into the account the specific reactor and control room-dependent characteristics of TMl-1, as well as tha quality and effectiveness of operator training and emergency prccedures at f Ml-l; if there is no such consideration of TMl-1 specific parameters of pro': ability in de-termining accident probability, provide a full and thercugh justification why such consideration is not needed, if estimates other than tho:e based on past experience are utilized in calculating prcbabilities, provide a dntailed justilication and basis fer those estimates.
12-11 Identify any and all experts who were relied upon in providing 'he answer to 12-10 above; for each expert provide name, address, phone number, and professional qualifications.
12-12 Identify and all documents that were relied upon in providing the answer to 12-10 above; for each document, provide author (s), and their professional auclifications.
12-13 In a document dated Jan 25, 1980 from Steven A. Varga te All Boerds, in reference to Turbine cracking, it is stated that "...the probability values used... may have been too low and may be revised upwards." Identify any ard oil other circumstantes known to LIC where the prcbability estimore of any equipment, instrumenterien, or operator error or malfunction has had to be revised upwards by WC or by any Licenm in the light of experience, research, or other new infermetien. Previde, fer com-parison, identification of any and all circumstonces in which c.ch prchability n ti-mates have been revised downward in the light of m:p-iencc, r carch, er other informa t ien. De these data provide any eviderce ci na ern H ' und 9;wneds
6 higher or lower overall probabilities of errors, malfunctions, or transients? Provide justification for your conclusions.
12-14 A meeting was held on October 23,1979 with representatives of the B&W owners' group, B&W, & Ook Ridge National Laboratory (ORNL) to discuss the " Integrated Control System Reliability Analysis" (B AW-1564) and questions rai:ed of this Analysis by ORNL. Question 12 and the response are quoted below:
" Question 12 " Multiple failures are not treated although it is acknowideged by B&W that many failures are not annunciated and therefere may exist until other failures occur, resulting in effective multiple
- failures, it appears that multiple failure situations may have significant probability of occurrence _.
Ilow is the emission of multiple failure considerations justified in the analysis?
Might Fault Tree Analysis have been a better technique for cdJressing the concerns and producing the result s requested?
Response
B&W has identified transients that have occurred, in the Operating History Section. Therefor 9 with respect to multiple failures the report has identified critical areas.
Although this is true, an event tree of ICS may highlight other important multiple follures. This type analysis was considered to be tco extensive for the time available.
(Summary of rreeting, at 7, emphasis addet a) Answer fully and completely the two questions pm J in Question 12 abave.
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7
'l (12-14) 1:) Provide full and complete description as to any FaultTree Analysis (FTA) that has been conducted or commissioned by or for LIC or B&W to remedy the omission of multiple failure considerations; provide a full justification for the scope of such FTA as has been conducted er commissioned, c) If no FTA has been conducted or commissioned pursuant to the above cited question, provide a full and complete justification as to why such FTA was not considered necessary, d) If the lack of available time is cited as one such justification, provide a full and complete ex-planation as to why the health and safety of the pb lic would not be more reasonably protected by delaying restart of TMI-l until there has been sufficient time to conduct such FTA as is required to eliminate or substantially reduce the probabilities of oc-currence of multiple failure situations.
13-1 Answer the interrogatories 5-1 through 5-6 as they apply to contentien 13.
through 13-6 13-7 Describe in detail any and all screening procedures, known to the LIC, to detect the development or existence of an operator 'mindset', wheroin an operator is so conditioned on the basis of his experience, in conjunction with prevailing management and operating attitudes, to substantially rule out on interpretation of a sequence of alarms, adverse signals, and indications of abncrmal transients, as indicative of c major accident with consequences of a partial or full core melt. If any psychebDcol tests are so used as screening procedures, identify such tests, identify the author of the tests, and his/her qualifications and professional background, and summarize any research that has investigated whether the tests provide on accurate indication of the existence of such an operator 'mindset'.
13-8 Describe in detail any screening procedures that will be used by Licensee to detect the development or existence of an operator 'mindset' (as defincd above). Summarize any research that has been conducted to evaluate the efficacy of such screening pro-cedures, identifying the principal investigator (s), and providing their professional qualifications.
13-9 identify any and all known research investigating the relationrhip between the develep-ment of operator 'mindset' and the frequency of alarms or indications of minor abner-mal transients, and/or the frequency of false alarms or other false indicatiens of cb-n:rmal transients. For each such research, identify the princi;ml investigator (s), das-cribe their professional qualifications, and summarine the findin3s of the resurch.
13-10 Identify and describe any and all studies that have been d2veloced, comminicned, er planned by liC into factors associated with the developmant of operator mindset. If no such studies have been prepared, commissioned, er planned by L!C, provide full and detailed justification why such studies are not considered to be necessary.
13-11 Describe in detail any and all communication and dialog that hos taken place between LIC and professionals with experience and research into opera:cr mindsat in situations analogous to nuclear power plant control rooms, fer cumplo, garsonnel in the NM A Aviation Psychology program, if no such communication er.d dialog has teken pl:ce, provide a therough justification as to why that has ror been cor idered necessary or i
valuable.
'13-12 a) Does LIC maintain full and comp!ste records of any and a:t ciarms thei have been displayed on the control rooms of TMl-1 and iMI-2? If :o, identify cny and all documents recording the eccurrence and frequency of o A mmm cnd whe:her such
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S clarms are false alarms. If not, provide a full justification as to why such docu-mentation is not maintained, b) Has LIC conducted or caused to be conducted any systematic analysis of the frequency and occurrence of alarms (including false alarms) that have been displayed on the TMl-1 and TMI-2 control panels? If so, identify, and provide a detailed summary of any and all documents de :ribing such analyses. If not, provide a full justification as to why Lic considers such analysis is not necessary, c) If LIC has conducted such analyses, has Ltc conducted, or caused to be conducted, any investigation into the relationship between tha frequency of clarms, false clarms, and the development of operator 'mindset'.
Definition (estimate) of an event
' Probability': whenever CEA request that LIC furnish any probability /as pcrt of its response to an interrogatory, that prcecbility shall mean the bait estimate of the probability of the occurrence of that event, and the following information describing that probability shall be' furnished by LIC:
a) The mean and standard deviation of the probability estimate, with the provision that if the distribution of the probability estimate is ossumed to be over a logarithmic transformation, that the mean to be provided shall be the harmonic mean, and the standard deviation to be provided shall be the tandard deviation of the logarithm of the probability estimates, and that this fact be noted.
b) The 5% and 1% confidence limits for the prcbability estimate.
c) A description of the assumed distribution of the prcbability estimate.
d) The component parts of the probability estimate (if the estimate multiple events, the probability esiimates of each of the concerns sub-events shall be furnished; if the estimate includes components of equipment malfunction, instrumentation-information errer, and operator error, those component probability enin ates shcIl be pievidad)e e) If the probability estimate is based en actual c::perience, a description of the sample over which the cstimor 3 was obtained, and this description shall include the following infermation:
i) The total real time over which obsm.atinn: were taSen.
ii) The context in whic: the observations mre taken (whether the observations were taken in a laboratery centext or in experimental or operating reactor (s)),
f) If a probability estimate is based on a rhearetical medel, a brief description of the theoretical basis fcr the probability estimcre.
shall be provided.
Respe,ctfully submitted
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Io ert Q. Pollard, for CHESAPE AKE ENERGY ALL%NCE, lilC,
Darec: February.i5,1950
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