ML19337A437

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Testimony in Response to Sholly Contention 5 & Environ Coalition on Nuclear Power Contention 1(d) Re Instrument Ranges.Lays Out Comparison Showing Adequacy of Instrument Ranges.Prof Qualifications Encl.Related Correspondence
ML19337A437
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/15/1980
From: Broughton T, Dubiel R, Williems V
METROPOLITAN EDISON CO.
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ML19332B231 List:
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ISSUANCES-SP, NUDOCS 8009260439
Download: ML19337A437 (20)
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O M3TED CORRESPONDDS LIC 9/15/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289 (Three Mile Island Nuclear

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^O (2 LICENSEE'S TESTIMONY OF T. GARY BROUGHTON, RICHARD W.

DUBIEL AND VICTOR H. WILLEMS IN RESPONSE TO SHOLLY CONTENTION NO. 5 AND ECNP CONTENTION NO. 1(d)

(INSTRUMENT RANGES (IN PLANT))

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OUTLINE I

The purposes and objectives of this testimony are to respond to Sholly Contention 5 and ECNP Contention 1(d), each of which challenge the range of specified plant radiation and process inatruments based upon TMI-2 experiences during the accirtent. Testimony is presented on plant modifications that have been incorporated into TMI-1 to increase the monitoring range of radiation and process instrumentation. Fur ther , a comparison, of as-modified instrumentation ranges to appropri-ate TMI-2 parameters is presented which demonstrates the adequacy of plant instrument ranges.

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I INTRODUCTION This testimony, by Mr. T. Gary Broughton, GPU Control and Safety Analysis Manager, Mr. Richard W. Dubiel, Supervisor, TMI-l Radiation Engineering, GPU, and Mr. Victor H. Willems, Project Instrumentation and Control Engineer, Gilbert i Associates, Inc., is addressed to the following contentions:

SHOLLY CONTENTION NO. 5 It is contended that Licensee has not provided radiation monitoring instruments in effluent discharge pathways which are capable of remaining on-scale during anticipated opera-tional occurrences, postulated accidents, and Class 9 accidents as specified in Contention il7.

It is further contended that the insuf-ficiency in range of these instruments prevents the Licensee from making sufficiently accurate predictions of the quantities of radiation which are being released from TMI-1, and that this places the public health and safety at signifi-cant risk because such information is required by public officials and plant operators to provide the basis for decisions on the need for protective actions. i l

It is further contended that protection of public health and rafety requires that the high-range effluent monitoring system be installed prior to Restart of TMI-1, and that the high-range effluent monitoring system be capable of remaining on-scale under conditions specified in this contention.

ECNP CONTENTION NO. 1(d)

The TMI-2 accident showed that many monitoring instruments were of insufficient indicating range to properly warn control room operators of ambient conditions. For example, the " hot-leg" thermocouples went off-scale at 620*F and stayed off-scale for over 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for reactor coolant loop A and i

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about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> for reactor coolant loop B.

A higher temperature limit would have provided important information to the reactor operators. This situation is unchanged at TMI-1. All monitoring instruments for TMI-l must be calibrated to provide full and accurate readings of the complete range of possible conditions under both normal and worst-case conditions.

In addition, it is reported that the radiation monitors went off-scale during the TMI-2 accidenc. It should be noted here that this eventuality was predicted in 1974 by the TMI-2 Intervenors, but dutifully denied by the NRC Staff and the Applicant during the TMI-2 licensing hearings. Needless to say, the TMI-2 Licensing Board accepted the assurances of adequate monitoring offered by the Staff and Applicant. Yet a similar situation still exists at TMI-1. All radiation monitoring equipment must be capable of recording the maximum possible releases of radiation in the event of a worst-possible accident (Class 9) in excess of Design Basis Accidents.

The Board limited the first paragraph of ECNP Contention 1(d) to " core cooling and containment isolation systems." The Board also stated that "the references in both paragraphs to the worst case and worst possible accidents are not accepted."

(See Board First Special Prehearing Conference Order, December 18, 1979, at 38.)

_ RESPONSE TO SHOLLY CONTENTION NO. 5 BY WITNESSES BROUGHTCN, DUBIEL AND WILLEMS:

TMI Unit I has sufficient radiation monitoring capacity to monitor radioactivity which may be released due to anticipated

operational occurrences and due to postulated accidents. This  !

monitoring capacity enables accurate estimates of radioactivity from Unit 1 under conditions of anticipated operational occur-ences and postulated accidents. These estimates of radiation i

releases can be provided as information in decision-making related to emergency actions.

Modifications to the Radiation Monitoring System, required by NUREG-0578 and described in the TMI-l Restart Report, will provide additional radiation monitors and extend the monitoring range of the Radiation Monitoring System. These modifications will be completed prior to restart. The following is a description of the existing Radiation Monitoring System and associated modifications for TMI-1.

The effluent discharge paths at TMI-l may be categorized as atmospheric discharge paths and liquid discharge paths. The atmospheric discharge paths are:

Reactor Building Ventilation Purge Exhaust Auxiliary and Fuel Handling Building Ventilation Exhaust Condenser Discharge Paths Main Steam Lines The first three discharge paths are monitored directly.

These monitors have sensitivities and dynamic ranges suitable for anticipated release rates from normal operations, an-ticipated transients and postulated accidents as analyzed in 9

l the Final Safety Analysis Report (FSAR). High radioactivity levels in the reactor building ventilation purge exhaust initiates automatic closure of the purge valves.

Modifications to the radiation monitoring system will provide additional gaseous and radiciodine monitoring capabil-ities over expanded ranges for the four atmospheric discharge paths which will overlap the previous existing monitoring ranges. These changes to the monitoring system meet the range and release rate requirements of NUREG-0578. These changes ,

described in Restart Report Section 2.1.2.7, will be completed prior to restart.

The following table summarizes the maximum radiation levels detectable in the TMI-l atmospheric discharge paths prior to and following the modifications:

GASEOUS EFFLUENT MONITORS Approximate New Discharge Path Previous Range Extended Range Condenser Off-Gas -1 10 mci /cc 105 .uci/cc Aux. & PBS Exhaust ~1 3 10 uCi/cc 10 uCi/cc Containment Exhaust -1 10 aci/cc 105 pCi/cc Main Steam Lines None 10 2

pCi/cc The liquid discharge path from the plant is through the plant discharge line to the river. This discharge line is monitored by a continuous liquid monitor. The principal source of radioactive effluent is the waste disposal system which

leads to the plant discharge line and is separately monitored.

Liquid radioactive waste discharge is automatically terminated by interlocks initiated by the radiation detection system whenever pre-established limits are exceeded.

These radiation monitors are designed to provide adequate sensitivity and range for releases associated with normal operation and anticipated operational occurrences. As noted in Licensee's Testimony of Messrs. Fuhrer and McGoey on the Physical Separation of TMI Units 1 and 2, the TMI-2 experience has demonstrated that gases and liquids can be maintained in containment and storage facilities until such time as pro-cessing can proceed. All of the above monitors used for effluent monitoring have control room readout indication and recording.

Licensee's testimony on Emergency Planning will discuss the use of radiation monitoring. system information in dose and release rate estimates and communication of this information to appropriate personnel.

The TMI Unit 1 Radiation Monitoring System, with the modifications outlined above and described in the TMI-l Restart Report, will be able to provide accurate estimates of offsite radiation releases for anticipated operational occurrences and postulated accidents significantly beyond those analyzed in the FSAR.

The monitoring ranges have been expand 6d sufficiently to measure noble gas release rates approximately 103 times greater than occurred during the TMI-2 accident, and sampling l

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capabilities have also been extended to enable measuring I-131 release rates at least 106 times greater than occurred during the TMI-2 accident.

RESPONSE TO ECNP CONTENTION NO. 1(d)

BY WITNESSES BROUGHTON, DUBIEL AND WILLEMS:

This testimony will address the contention, as limited by _

the Board, in three parts:

1. That because certain important safety related monitoring instruments related to core cooling and containment isolation systems went off-scale during f

the TMI-2 accident the operators were denied impor-tant information.

2. All important safety related monitoring instruments related to core cooling and containment isolation systems must provide full and accurate readings under i

anticipated conditions.

3.

All important safety related radiation monitoring equipment must be capable of recording the maximum possible releases of radiation during anticipated conditions.

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BY WITNESS BROUGHTON:

1. Adequacy of Information during TMI-2 Accident Reviews of the TMI-2 accident data conclude that suffi-cient information was available during the accident to indicate deteriorated heat transfer conditions, core voiding and inadequate RCS water inventory. Sufficient information was available to assess core cooling and containment isolation systems performance.

One indicator of inadequate core cooling is the existence of superheated steam in the reactor coolant system. At RCS pressures below 1000 psig (the stabilized pressure following the early sequence of events at TMI-2), temperatures above 550'F indicate the presence of superheated steam. Therefore, the hot leg temperature indicator, with a range of 620 *F, provided adequate indication of superheated steam in the reactor coolant system. Expected operator actions do not change based on the degree of superheat as determined by the hot leg tempercture instrument. Therefore, operators were not i

denied important ir4 formation when the hot leg temperature  !

indicator went off-scale high. i l

2. Core Cooling and Containment Isolation Systems Instrument Ranges Guidelines for identification and mitigation of approach to Indequate Core Cooling (ICC) are discussed in Licensee's testimony in response to UCS Contention 7, ANGRY Contention V  :

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d (B) and Sholly Contention 6(b)(Detection of Inadequate Core Cooling). These guidelines define the instruments used to prevent ICC situations and the actions required in response to specific instrument readings. The guidelines are not based on specific scenarios such as the TMI-2 accident, but are appli-cable to prevent conditions of ICC regardless of cause.

TMI-l will have sufficient instrumentation, with adequate range and accuracy to provide information necessary to detect and mitigate potential inadequate core cooling per the ICC guidelines. As described in the TMI-l Restart Report (Section 2.1.16), the hot leg temperature instruments will be modified to indicate temperatures from 120 to 920*F, core exit ther-mocouples will be connected to the plant computer and a saturation margin meter will be provided. These modifications will be completed prior to restart.

There are no postulated conditions identified as a result of the TMI-2 accident which would require changes in ranges of existing instrumentation or new instrumentation related to containment isolation systems.

BY WITNESSES BROUGHTCP, DUBIEL AND WILLEMS:

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3. Radiation Monitorina_

Radiation monitoring of discharge patns is discussed above I i

in our response to Sholly Contention No. 5.

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A. Monitoring of Reactor Containment Atmosphere '

Presently the reactor building atmosphere is monitored for normal operation, anticipated occurrences and accident condi-tions by the following radiation monitors as indicated in the FSAR Section 11.4:

Area Gamma Detector located near the personnel access door Area Gamma Detector located on the Fuel Handling Bridge No. 1 Area Gamma Detector located on the Fuel Handling Bridge No. 2 These monitors are providing Area Gamma Monitoring information during normal operation and operational occurrences. A wide range Area Gamma Monitor, located in the reactor building, provides information on post-accident ,

cond itions .

In addition, during normal operations and operational occurrences, the reactor building atmosphere is sampled and monitored for radioactive particulate, iodine and noble gases.

This monitor isolated in case of an accident. i Modifications to the radiation monitoring system will l orovide for two additional high-range, post-accident, area  !

t Gamma Detectors located in the reactor building, with readout 1 and recording in the control room. These monitors extend the i

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range of gamma monitoring within the containment to 107 R/HR.

These monitors are described in the Restart Report, Section 2.1.2.1, and will be operable prior to restart.

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B. Monitoring of Spaces, Outside the Reactor Building, Containing Components for Recirculation of Loss of i Coolant Accidents Fluids l Components for recirculation of loss of coolant accident fluids are located in concrete shielded room / spaces to which access is controlled. These components are normally not operating during plant operation, their function being called l

upon only during plant shutdown and accident conditions.

These concrete, shielded room / spaces are monitored for normal operation, anticipated occurrences and accident condi-tions by monitoring the radioactivity concentration in the ventilation air serving these rooms / spaces. The ventilation j

air for these rooms / spaces is supplied and exhausted by the auxiliary building ventilation system which is monitored for radioactive particulate, iodine and noble gas by radia' tion monitors. High radioactivity levels from the monitors result in appropriate automatic isolation of the ruxiliary building supply ventilation system or the waste gas disposal system.

The radiation field in the vicinity of but external to these rooms / spaces is also monitored by an area gamma monitor.

In addition to the detection of radioactivity present in the ventilation system, several area radiation monitors are selectively located in the Auxiliary Building to provide

{ coverage of abnormal event: in the waste tank area, radioactive waste packaging area, waste evaporator area, heat exchanger vault area and entrance areas. Excessive levels indicated in these areas will initiate investigational surveillance by operators accompanied with portable survey instrumentation.

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As deceribed above in our response to Sholly Contention No. 5, the TMI-1 Radiation Monitoring System will be able to provide accurate estimates of off-site radiation releases and doses for anticipated operational occurrences and postulated accidents significantly beyond those analyzed in the FSAR.

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l T. GARY BROUGHTON Business Address: GPU Service Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 Education: B. A. , Mathematics, Dar tmouth College, 1966.

Experience: Control and Safety Analysis Manager, GPU Service Corporation, 1978 to present. Responsible for nuclear safety analysis and integrated '

thermal, hydraulic and control system analysis of nuclear and fossil plants.

Supervised on-site technical support groups at Three Mile Island, Unit 2 ,

during the post-accident period. '

Safety and Licensing ngineer; Safety and Licensing Manager, GPU Service Corporation, 1976 to 1978. Performed and supervised nuclear licensing, environmental licensing and safety analysis for Oyster Creek, Three Mile Island and Forked River plants.-

Served as Technical Secretary to Oyster Creek and Three Mile Island General Office Review Boards.

Officer, U.S. Navy, 1966 to 1976. i Trained at Naval Nuclear Power School, '

Prototype and Submarine School.

Positions held include Nuclear 1 Propulsion Plant Watch Supervisor,  !

Instructor at D1G prototype plant and Engineering Officer aboard a fast-attack nuclear submarine.

Publications: EPRI CCM-5, RETRAN - A Program for One-Dimensional Transient Thermal-Hy-draulic Analyses of Ccmplex Fluid Flow Systems, Volur' 4: Applications, December, 197 . Mction 6.1, " Analysis of Rapid Cools s fransient - Three Mile Island Unit 2", with N.G.

Trikouros and J. F. Harrison.

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"The Use of RETRAN to Evaluate Alternate Accident Scenarios at TMI-2", with N. G. Trikouros.

Proceedings of the ANS/ ENS Topical Meeting on Thermal Reactor Safety, April 1990, CONF-800403.

"A Real-Time Method for Analyzing Nuclear Power Plant Transients", with P.S. Walsh. ANS Transactions, Volume 34 TANSAD 34 1-899 (1980).

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RICHARD W. DUBIEL Business Address: Metropolitan Edison Company Three Mile Island Nuclear Station l

P.O. Box 480 Middletown, Pennsylvania 17057 Education: B.S., Physics, Fairfield University, 1970.

M.S., Nuclear Engineering, Georgia Institute of Technology, 1971.

Experience:

Supervisor, Radiological Engineering, TMI-1, Metropolitan Edison Company, 1979 to present. Responsibilities include design reviews for proposed facilities, systems, and equipment that potentially affect radiation exposures; accomplishing ALARA through periodic review of work conditions, review of procedures, and developing and maintaining standard work practice and procedures; calibration and maintenance of survey and laboratory instruments used in TMI-1; preparation of radiological control program implementing procedures to meet current regulatory requirements; maintenance of required survey and exposure records; respiratory protection; dosimetry and bioassay; and, review and approval of radioactive releases.

Supervisor of Radiation Protection and Chemistry, Three Mile Island, Metropolitan Edison Company, 1977 to 1979. Duties included responsibilities for development and implementation of the Radiation Protection Program, Chemistry Program, Radwaste Processing and Shipping.

Radiation Protection Supervisor, Three Mile Island, Metropolitan Edison Company, 1976 to 1977. Supervision of Radiation Protection Foreman for both TMI-1 (opera-tional) and TMI-2 (start-up and testing) in all areas of Radiation Protection, includ-ing field operations, dosimetry, bioassay, respiratory protection, effluent sampling and analysis, training, emergency planning,

l and instrumentation calibration.

Radiological Engineer, Three Mile Island, Metropolitan Edison Company, 1974 to 1976.

Duties included effluent release eval- '

uations; radiological control procedure preparation; bioassay evaluations; Emergency Planning; radiation monitoring system performance evaluation; HEPA and charcoal filter testing; review of design considerations for TMI-2.

Radiation Health Officer, Nuclear Submarine Tender, U.S. Navy, 1972 to 1973.

Responsible for dosimetry program; training of radiation workers; auditing of submarine radiation control programs.

Radiation Physicist, Naval Regional Medical Center, U.S. Navy, 1973-1974. Duties included radiation surveys of x-ray facility; licensing of Nuclear Medicine Lab; establishment of Health Physics program at the Nuclear Medicine Lab; Emergency Planning at NRMC to support the Naval Shipyard.

Professional Affiliations: Health Physics Society.

Company representative to the Edison Electrical Institute's Health Physics Task Force.

Presentation, " Health Physics Problems t at TMI," American Nuclear Society, June 1980 meeting. 1 I

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VICTOR H. WILLEMS Business Address: Gilbert Associates, Inc.

525 Lancaster Avenue Reading, Pennsylvania 19603 Education: A2 Electrical Engineer , Ecole Technique Saint George, Brussels, Belgium, 1957.

Al Electronic, InRaci, Brussels, Belgium, 1960.

Microcomputers in Control Systems, The George Washington University, 1979.

Seismic Qualification Seminar and Demonstration, Wyle Laboratory, 1977.

Ex per ience :

Nuclear Instrumentation and Control Consultant, Gilbert Associates, Inc., 1975 to present. Technical supervision, consultations and design reviews of nuclear instrumentation and control designs relating to reactor trip systems, safety features actuation systems, equipment qualification, electrical separation, radiation monitoring and solid state-controls for all nuclear projects. j Project Instrumentation and Control Engi-neer, Gilbert Associates, Inc., 1979 to 1980. Responsible for supervision of the instrumentation and control design for the restart modifications required for Metropolitan Edison Company's Three Mile Island Nuclear Station, Unit 1.

Project Instrumentation and Control Engi-neer, Gilbert Associates, Inc., 1975 to 1979. Responsible for and supervision of the development of the instrumentation and control design of Gilbert Associates' Reference Nuclear Plant including portion of the Standard Safety Analysis Report (GAISSAR). Task Force Leader for the preparation and submittal of the " Fire l Hazard Analysis Report" supporting GAISSAR docket. Participated in the preparation of the Fire Analysis Report (required by the NRC) for the Metropolitan Edison Company's Three Mile Island, Unit 1.

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Project Instrumentation and Control Engi-neer, Gilbert Associates, Inc., 1972 to 1975. Responsible for and supervision of all phases of the design of the instru-mentation and controls for Metropolitan Edison Comppany's Three Mile Island Unit 1.

Work included control room boards design, computer applications, safety feature actuation system, radiation monitoring system, secondary plant instrumentation control system and licensing.

Instrument and Control Engineer, Gilbert Associates, Inc., 1967 to 1972. Design and supervision of engineered safety features actuation system and radiation monitoring system for Metropolitan Edison Company's Three Mile Island Unit 1, and Florida Power Corporation's Crystal River Unit 3.

Preparation and review of PSAR-FSAR and participation in licensing for Metropolitan Edison Company's Three Mile Island.

Establish design criteria for the radiation monitoring system for Korea Electric Company's Ko-Ri, Unit 1 Inventor of a detection principle for battery ground detectors and designer of a solid state battery ground detector based on the principle.

Eurochemic, Belgium, 1962 to 1967.

Research and development of in-line plutonium and uranium analyzers for PUREX Fuel Reprocessing. Preparation of spe-cifications and technical reception tests; installation of ambient gamma and dust activity monitoring systems, activity release monitoring system, and nuclear burst detectors; inventor of a noiseless continous air sampler for rad Eation monitoring r.pplication.

Superior Technician, Research Center for Natural Substance, Belgium, 1963 to 1961.

Development of electronic instruments for measuring chemical parameters.

Professional Affiliations: Institute of Electrical and Electronics Engineers; Member , Working Group, Stan-dard 381 - Type Test of Modules and Nuclear Power Station Protection Systems. Member, Working Group 2.12 Radiation Cualification of Class lE Equipment.

Registered Professional Engineer, Pennsylvania.

Publications: Representative publications include:

" Operating Experience - The Designer Point I of View." International Atomic Energy Agency - International Symposium on Nuclear Power Plant Control and Instrumentation, Cannes, France, April, 1978.

" Role of the Architect - Engineer ,"

(Lecturer), International Atomic Energy 4

I Agency's Nuclear Power Project Construction and Operation Management Course, Paris, France, March, 1977.

" Equipment Consideration," (Instructor),

Instrument Society of America's Plant Protection System and Radiation Monitoring Systems Course, 1977.

" Modern Nuclear Generating Plant Controls -

An Integrated Approach," Institute of Electrical and Electronics Engineer Symposium , New Yo r k , 1980.

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