Direct Testimony Re Ucs Contention 14.Explains Significance of Distinction Between Safety & nonsafety-grade Sys & Components.Prof Qualifications & Certificate of Svc Encl. Related CorrespondenceML19338E966 |
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Three Mile Island |
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10/02/1980 |
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Pollard R UNION OF CONCERNED SCIENTISTS |
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ISSUANCES-SP, NUDOCS 8010070015 |
Download: ML19338E966 (15) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] Category:TRANSCRIPTS
MONTHYEARML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20235N2161989-02-17017 February 1989 Follow-up Testimony Clarifying Position on Question of Disposition of Over 2 Million Gallons of Accident Generated Water.Related Documentation & Certificate of Svc Encl ML20235S9911989-02-16016 February 1989 Transcript of 890216 Public Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-119. Supporting Documentation Encl ML20206C9391988-11-0707 November 1988 Transcript of 881107 Hearing in Lancaster,Pa.Pp 1,122- 1,417.Witnesses:JA Auxier,Ji Fabrikant,Skolnik & Mather ML20235M7601988-11-0303 November 1988 Transcript of 881103 Public Hearing in Lancaster,Pa for Presentation of Limited Appearance Statements.Pp 998-1,121 ML20206C2801988-11-0303 November 1988 Transcript of 881103 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 859-997.Witnesses:JA Martin, SS Yaniv,F Skolnik,S Lewis & a Bhattacharyya ML20205Q6581988-11-0202 November 1988 Transcript of 881102 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 573-858.Supporting Documentation Encl.Witnesses:Gg Baker,Wj Cooper & L Munson ML20205Q6441988-11-0101 November 1988 Transcript of 881101 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 288-572.Supporting Info Encl. Witnesses:K Hofstetter,Kl Harner,L Thomas & M Masnik ML20205N5791988-10-31031 October 1988 Transcript of ASLB 881031 Meeting in Lancaster,Pa Re License Amend Application.Pp 87-287 ML20205P0451988-10-25025 October 1988 Transcript of 881025 Periodic Briefing by TMI-2 Advisory Panel in Rockville,Md.Pp 1-30 ML20205G1851988-10-25025 October 1988 Licensee Testimony of GG Baker & Wj Cooper on Dose Assessments & Microorganisms (Contentions 2,3 & 5d).* Supporting Documentation Encl.Related Correspondence ML20205E5021988-10-24024 October 1988 Licensee Rebuttal Testimony of Ji Fabrikant on Health Effects of Tritium (Contention 5d).* Related Correspondence ML20155H1751988-10-11011 October 1988 Licensee Testimony of GG Baker & Wj Cooper on Dose Assessments & Microorganisms (Contentions 2,3 & 5d).* Related Correspondence ML20155H1531988-10-11011 October 1988 Licensee Testimony of Ww Weaver on Accident Risks (Contention 2).* Related Correspondence ML20155H1901988-10-11011 October 1988 Licensee Testimony of Ja Auxier & Ji Fabrikant on Effects of Tritium (Contentions 3 & 5d).* Supporting Info Encl.Related Correpondence ML20155H1661988-10-11011 October 1988 Licensee Testimony of Kl Harner & Kj Hofstetter on Sampling & Analysis of accident-generated Water (Contentions 3 & 4b).* Related Correspondence ML20155H1401988-10-11011 October 1988 Licensee Testimony of Je Tarpinian on Occupational Dose Assessments (Contention 2).* Related Correspondence ML20155H1281988-10-11011 October 1988 Licensee Testimony of Dr Buchanan on Evaporation Proposal & Joint Intervenors Alternative (Contentions 2 & 3).* Related Correspondence ML20155H4751988-10-10010 October 1988 Testimony.* Discusses Environ Impact of Force Evaporation of 2.3 Million Gallons of accident-generated Water by Licensee. W/Certificate of Svc.Related Correspondence ML20155H4711988-10-10010 October 1988 Affidavit of Cw Huver (Contention 5):further Considerations of Biological Effects & Health Hazards of Tritium.* Copyrighted Matl Encl.Related Correspondence ML20154D5201988-09-0707 September 1988 Transcript of Advisory Panel for Decontamination of TMI-2 880907 Meeting in Harrisburg,Pa.Pp 1-109.Supporting Documentation Encl ML20151G6951988-07-14014 July 1988 Transcript of Advisory Panel for Decontamination of TMI-2 880714 Meeting in Harrisburg,Pa.Pp 1-140.Related Documentation Encl ML20196B6041988-05-26026 May 1988 Transcript of 880526 Advisory Panel Meeting in Harrisburg, PA to Discuss Decontamination of TMI-2.Pp 1-117.Supporting Documentation Encl ML20154N4101988-04-14014 April 1988 Transcript of 880414 Advisory Panel for Decontamination of TMI-2 Public Meeting in Lancaster,Pa.Related Info Encl. Pp 1-100 ML20148F2351988-03-17017 March 1988 Transcript of 880317 Briefing in Washington,Dc Re Status of TMI-2.Pp 1-51.Supporting Documentation Encl ML20236Y1061987-12-0808 December 1987 Transcript of Special Prehearing Conference on 871208 in Harrisburg,Pa Re Disposal of accident-generated Water. Pp 1-86 ML20238C6981987-10-0505 October 1987 Deposition of a Beach.* Transcript of 871005 Deposition in Washington,Dc Re R Parks Allegations.Pp 1-244.Supporting Documentation Encl ML20235J7071987-09-30030 September 1987 Transcript of 870930 Prehearing Conference in Bethesda,Md. Pp 225-343 ML20238D4641987-09-0909 September 1987 Transcript of 870909 Oral Argument in Bethesda,Md.Pp 1-57 ML20238C7531987-08-20020 August 1987 Vol II to Transcript of Hl Hofmann 870820 Deposition in San Francisco,Ca Re Civil Penalty.Pp 208-471 & 489-494. Supporting Documentation Encl ML20238C7891987-08-18018 August 1987 Deposition of Rd Parks.* Vol IV to Transcript of 870818 Deposition in San Francisco,Ca Re Civil Penalty.Pp 551-818. Supporting Documentation Encl ML20238C7651987-06-25025 June 1987 Deposition of Hl Hofmann.* Transcript of 870625 Deposition in San Francisco,Ca Re Civil Penalty.Pp 1-206 ML20238C8041987-06-24024 June 1987 Deposition of Rd Parks.* Vol III to Transcript of 870624 Deposition in Newport Beach,Ca Re Civil Penalty.Pp III-1 - III-89 ML20235J1271987-06-24024 June 1987 Deposition of Rd Parks.* Vols II & III of Transcript of Rd Parks 870624 Deposition.Related Correspondence ML20238C7981987-06-23023 June 1987 Deposition of Rd Parks.* Vol II to Transcript of 870623 Deposition in Newport Beach,Ca Re Civil Penalty.Pp II-1 - II-263.Supporting Documentation Encl ML20238C7941987-06-22022 June 1987 Deposition of Rd Parks.* Vol I to Transcript of 870622 Deposition in Newport Beach,Ca Re Civil Penalty.Pp 1-199. Supporting Documentation Encl ML20238C5921987-06-16016 June 1987 Deposition of R Meeks.* Transcript of 870616 Deposition in Washington,Dc Re Allegations of Harassment Against R Parks. Pp 1-198.Supporting Documentation Encl ML20238C6171987-06-16016 June 1987 Deposition of R Meeks.* Corrected Title Page of 870616 Deposition ML20215L2731987-05-0808 May 1987 Transcript of 870508 Prehearing Conference in Bethesda,Md.Pp 19-224.In Camera Session (Pp 101-138) Bound Separately ML20238C7331987-04-24024 April 1987 Deposition of Rc Arnold.* Transcript of 870424 Deposition in Washington,Dc Re Civil Penalty.Pp 1-224.Supporting Documentation Encl ML20212Q9801987-04-16016 April 1987 Transcript of 870416 Periodic Meeting W/Advisory Panel for Decontamination of TMI-2 in Washington,Dc.Pp 1-50.Supporting Documentation Encl ML20212Q8021987-04-15015 April 1987 Transcript of 870415 Briefing by DOE in Washington,Dc Re TMI-2 Core Exam Program.Pp 1-64.Viewgraphs Encl ML20238C6521987-04-10010 April 1987 Deposition of Bk Kanga.* Transcript of 870410 Deposition in Gaithersburg,Md Re R Parks.Pp 1-151.Supporting Documentation Encl 1998-09-17
[Table view] Category:DEPOSITIONS
MONTHYEARML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20235N2161989-02-17017 February 1989 Follow-up Testimony Clarifying Position on Question of Disposition of Over 2 Million Gallons of Accident Generated Water.Related Documentation & Certificate of Svc Encl ML20235S9911989-02-16016 February 1989 Transcript of 890216 Public Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-119. Supporting Documentation Encl ML20206C9391988-11-0707 November 1988 Transcript of 881107 Hearing in Lancaster,Pa.Pp 1,122- 1,417.Witnesses:JA Auxier,Ji Fabrikant,Skolnik & Mather ML20235M7601988-11-0303 November 1988 Transcript of 881103 Public Hearing in Lancaster,Pa for Presentation of Limited Appearance Statements.Pp 998-1,121 ML20206C2801988-11-0303 November 1988 Transcript of 881103 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 859-997.Witnesses:JA Martin, SS Yaniv,F Skolnik,S Lewis & a Bhattacharyya ML20205Q6581988-11-0202 November 1988 Transcript of 881102 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 573-858.Supporting Documentation Encl.Witnesses:Gg Baker,Wj Cooper & L Munson ML20205Q6441988-11-0101 November 1988 Transcript of 881101 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 288-572.Supporting Info Encl. Witnesses:K Hofstetter,Kl Harner,L Thomas & M Masnik ML20205N5791988-10-31031 October 1988 Transcript of ASLB 881031 Meeting in Lancaster,Pa Re License Amend Application.Pp 87-287 ML20205P0451988-10-25025 October 1988 Transcript of 881025 Periodic Briefing by TMI-2 Advisory Panel in Rockville,Md.Pp 1-30 ML20205G1851988-10-25025 October 1988 Licensee Testimony of GG Baker & Wj Cooper on Dose Assessments & Microorganisms (Contentions 2,3 & 5d).* Supporting Documentation Encl.Related Correspondence ML20205E5021988-10-24024 October 1988 Licensee Rebuttal Testimony of Ji Fabrikant on Health Effects of Tritium (Contention 5d).* Related Correspondence ML20155H1751988-10-11011 October 1988 Licensee Testimony of GG Baker & Wj Cooper on Dose Assessments & Microorganisms (Contentions 2,3 & 5d).* Related Correspondence ML20155H1531988-10-11011 October 1988 Licensee Testimony of Ww Weaver on Accident Risks (Contention 2).* Related Correspondence ML20155H1901988-10-11011 October 1988 Licensee Testimony of Ja Auxier & Ji Fabrikant on Effects of Tritium (Contentions 3 & 5d).* Supporting Info Encl.Related Correpondence ML20155H1661988-10-11011 October 1988 Licensee Testimony of Kl Harner & Kj Hofstetter on Sampling & Analysis of accident-generated Water (Contentions 3 & 4b).* Related Correspondence ML20155H1401988-10-11011 October 1988 Licensee Testimony of Je Tarpinian on Occupational Dose Assessments (Contention 2).* Related Correspondence ML20155H1281988-10-11011 October 1988 Licensee Testimony of Dr Buchanan on Evaporation Proposal & Joint Intervenors Alternative (Contentions 2 & 3).* Related Correspondence ML20155H4751988-10-10010 October 1988 Testimony.* Discusses Environ Impact of Force Evaporation of 2.3 Million Gallons of accident-generated Water by Licensee. W/Certificate of Svc.Related Correspondence ML20155H4711988-10-10010 October 1988 Affidavit of Cw Huver (Contention 5):further Considerations of Biological Effects & Health Hazards of Tritium.* Copyrighted Matl Encl.Related Correspondence ML20154D5201988-09-0707 September 1988 Transcript of Advisory Panel for Decontamination of TMI-2 880907 Meeting in Harrisburg,Pa.Pp 1-109.Supporting Documentation Encl ML20151G6951988-07-14014 July 1988 Transcript of Advisory Panel for Decontamination of TMI-2 880714 Meeting in Harrisburg,Pa.Pp 1-140.Related Documentation Encl ML20196B6041988-05-26026 May 1988 Transcript of 880526 Advisory Panel Meeting in Harrisburg, PA to Discuss Decontamination of TMI-2.Pp 1-117.Supporting Documentation Encl ML20154N4101988-04-14014 April 1988 Transcript of 880414 Advisory Panel for Decontamination of TMI-2 Public Meeting in Lancaster,Pa.Related Info Encl. Pp 1-100 ML20148F2351988-03-17017 March 1988 Transcript of 880317 Briefing in Washington,Dc Re Status of TMI-2.Pp 1-51.Supporting Documentation Encl ML20236Y1061987-12-0808 December 1987 Transcript of Special Prehearing Conference on 871208 in Harrisburg,Pa Re Disposal of accident-generated Water. Pp 1-86 ML20238C6981987-10-0505 October 1987 Deposition of a Beach.* Transcript of 871005 Deposition in Washington,Dc Re R Parks Allegations.Pp 1-244.Supporting Documentation Encl ML20235J7071987-09-30030 September 1987 Transcript of 870930 Prehearing Conference in Bethesda,Md. Pp 225-343 ML20238D4641987-09-0909 September 1987 Transcript of 870909 Oral Argument in Bethesda,Md.Pp 1-57 ML20238C7531987-08-20020 August 1987 Vol II to Transcript of Hl Hofmann 870820 Deposition in San Francisco,Ca Re Civil Penalty.Pp 208-471 & 489-494. Supporting Documentation Encl ML20238C7891987-08-18018 August 1987 Deposition of Rd Parks.* Vol IV to Transcript of 870818 Deposition in San Francisco,Ca Re Civil Penalty.Pp 551-818. Supporting Documentation Encl ML20238C7651987-06-25025 June 1987 Deposition of Hl Hofmann.* Transcript of 870625 Deposition in San Francisco,Ca Re Civil Penalty.Pp 1-206 ML20238C8041987-06-24024 June 1987 Deposition of Rd Parks.* Vol III to Transcript of 870624 Deposition in Newport Beach,Ca Re Civil Penalty.Pp III-1 - III-89 ML20235J1271987-06-24024 June 1987 Deposition of Rd Parks.* Vols II & III of Transcript of Rd Parks 870624 Deposition.Related Correspondence ML20238C7981987-06-23023 June 1987 Deposition of Rd Parks.* Vol II to Transcript of 870623 Deposition in Newport Beach,Ca Re Civil Penalty.Pp II-1 - II-263.Supporting Documentation Encl ML20238C7941987-06-22022 June 1987 Deposition of Rd Parks.* Vol I to Transcript of 870622 Deposition in Newport Beach,Ca Re Civil Penalty.Pp 1-199. Supporting Documentation Encl ML20238C5921987-06-16016 June 1987 Deposition of R Meeks.* Transcript of 870616 Deposition in Washington,Dc Re Allegations of Harassment Against R Parks. Pp 1-198.Supporting Documentation Encl ML20238C6171987-06-16016 June 1987 Deposition of R Meeks.* Corrected Title Page of 870616 Deposition ML20215L2731987-05-0808 May 1987 Transcript of 870508 Prehearing Conference in Bethesda,Md.Pp 19-224.In Camera Session (Pp 101-138) Bound Separately ML20238C7331987-04-24024 April 1987 Deposition of Rc Arnold.* Transcript of 870424 Deposition in Washington,Dc Re Civil Penalty.Pp 1-224.Supporting Documentation Encl ML20212Q9801987-04-16016 April 1987 Transcript of 870416 Periodic Meeting W/Advisory Panel for Decontamination of TMI-2 in Washington,Dc.Pp 1-50.Supporting Documentation Encl ML20212Q8021987-04-15015 April 1987 Transcript of 870415 Briefing by DOE in Washington,Dc Re TMI-2 Core Exam Program.Pp 1-64.Viewgraphs Encl ML20238C6521987-04-10010 April 1987 Deposition of Bk Kanga.* Transcript of 870410 Deposition in Gaithersburg,Md Re R Parks.Pp 1-151.Supporting Documentation Encl 1998-09-17
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20235N2161989-02-17017 February 1989 Follow-up Testimony Clarifying Position on Question of Disposition of Over 2 Million Gallons of Accident Generated Water.Related Documentation & Certificate of Svc Encl ML20235S9911989-02-16016 February 1989 Transcript of 890216 Public Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-119. Supporting Documentation Encl ML20206C9391988-11-0707 November 1988 Transcript of 881107 Hearing in Lancaster,Pa.Pp 1,122- 1,417.Witnesses:JA Auxier,Ji Fabrikant,Skolnik & Mather ML20235M7601988-11-0303 November 1988 Transcript of 881103 Public Hearing in Lancaster,Pa for Presentation of Limited Appearance Statements.Pp 998-1,121 ML20206C2801988-11-0303 November 1988 Transcript of 881103 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 859-997.Witnesses:JA Martin, SS Yaniv,F Skolnik,S Lewis & a Bhattacharyya ML20205Q6581988-11-0202 November 1988 Transcript of 881102 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 573-858.Supporting Documentation Encl.Witnesses:Gg Baker,Wj Cooper & L Munson ML20205Q6441988-11-0101 November 1988 Transcript of 881101 Hearing in Lancaster,Pa Re TMI-2 License Amend Application.Pp 288-572.Supporting Info Encl. Witnesses:K Hofstetter,Kl Harner,L Thomas & M Masnik ML20205N5791988-10-31031 October 1988 Transcript of ASLB 881031 Meeting in Lancaster,Pa Re License Amend Application.Pp 87-287 ML20205P0451988-10-25025 October 1988 Transcript of 881025 Periodic Briefing by TMI-2 Advisory Panel in Rockville,Md.Pp 1-30 ML20205G1851988-10-25025 October 1988 Licensee Testimony of GG Baker & Wj Cooper on Dose Assessments & Microorganisms (Contentions 2,3 & 5d).* Supporting Documentation Encl.Related Correspondence ML20205E5021988-10-24024 October 1988 Licensee Rebuttal Testimony of Ji Fabrikant on Health Effects of Tritium (Contention 5d).* Related Correspondence ML20155H1751988-10-11011 October 1988 Licensee Testimony of GG Baker & Wj Cooper on Dose Assessments & Microorganisms (Contentions 2,3 & 5d).* Related Correspondence ML20155H1531988-10-11011 October 1988 Licensee Testimony of Ww Weaver on Accident Risks (Contention 2).* Related Correspondence ML20155H1901988-10-11011 October 1988 Licensee Testimony of Ja Auxier & Ji Fabrikant on Effects of Tritium (Contentions 3 & 5d).* Supporting Info Encl.Related Correpondence ML20155H1661988-10-11011 October 1988 Licensee Testimony of Kl Harner & Kj Hofstetter on Sampling & Analysis of accident-generated Water (Contentions 3 & 4b).* Related Correspondence ML20155H1401988-10-11011 October 1988 Licensee Testimony of Je Tarpinian on Occupational Dose Assessments (Contention 2).* Related Correspondence ML20155H1281988-10-11011 October 1988 Licensee Testimony of Dr Buchanan on Evaporation Proposal & Joint Intervenors Alternative (Contentions 2 & 3).* Related Correspondence ML20155H4751988-10-10010 October 1988 Testimony.* Discusses Environ Impact of Force Evaporation of 2.3 Million Gallons of accident-generated Water by Licensee. W/Certificate of Svc.Related Correspondence ML20155H4711988-10-10010 October 1988 Affidavit of Cw Huver (Contention 5):further Considerations of Biological Effects & Health Hazards of Tritium.* Copyrighted Matl Encl.Related Correspondence ML20154D5201988-09-0707 September 1988 Transcript of Advisory Panel for Decontamination of TMI-2 880907 Meeting in Harrisburg,Pa.Pp 1-109.Supporting Documentation Encl ML20151G6951988-07-14014 July 1988 Transcript of Advisory Panel for Decontamination of TMI-2 880714 Meeting in Harrisburg,Pa.Pp 1-140.Related Documentation Encl ML20196B6041988-05-26026 May 1988 Transcript of 880526 Advisory Panel Meeting in Harrisburg, PA to Discuss Decontamination of TMI-2.Pp 1-117.Supporting Documentation Encl ML20154N4101988-04-14014 April 1988 Transcript of 880414 Advisory Panel for Decontamination of TMI-2 Public Meeting in Lancaster,Pa.Related Info Encl. Pp 1-100 ML20148F2351988-03-17017 March 1988 Transcript of 880317 Briefing in Washington,Dc Re Status of TMI-2.Pp 1-51.Supporting Documentation Encl ML20236Y1061987-12-0808 December 1987 Transcript of Special Prehearing Conference on 871208 in Harrisburg,Pa Re Disposal of accident-generated Water. Pp 1-86 ML20238C6981987-10-0505 October 1987 Deposition of a Beach.* Transcript of 871005 Deposition in Washington,Dc Re R Parks Allegations.Pp 1-244.Supporting Documentation Encl ML20235J7071987-09-30030 September 1987 Transcript of 870930 Prehearing Conference in Bethesda,Md. Pp 225-343 ML20238D4641987-09-0909 September 1987 Transcript of 870909 Oral Argument in Bethesda,Md.Pp 1-57 ML20238C7531987-08-20020 August 1987 Vol II to Transcript of Hl Hofmann 870820 Deposition in San Francisco,Ca Re Civil Penalty.Pp 208-471 & 489-494. Supporting Documentation Encl ML20238C7891987-08-18018 August 1987 Deposition of Rd Parks.* Vol IV to Transcript of 870818 Deposition in San Francisco,Ca Re Civil Penalty.Pp 551-818. Supporting Documentation Encl ML20238C7651987-06-25025 June 1987 Deposition of Hl Hofmann.* Transcript of 870625 Deposition in San Francisco,Ca Re Civil Penalty.Pp 1-206 ML20238C8041987-06-24024 June 1987 Deposition of Rd Parks.* Vol III to Transcript of 870624 Deposition in Newport Beach,Ca Re Civil Penalty.Pp III-1 - III-89 ML20235J1271987-06-24024 June 1987 Deposition of Rd Parks.* Vols II & III of Transcript of Rd Parks 870624 Deposition.Related Correspondence ML20238C7981987-06-23023 June 1987 Deposition of Rd Parks.* Vol II to Transcript of 870623 Deposition in Newport Beach,Ca Re Civil Penalty.Pp II-1 - II-263.Supporting Documentation Encl ML20238C7941987-06-22022 June 1987 Deposition of Rd Parks.* Vol I to Transcript of 870622 Deposition in Newport Beach,Ca Re Civil Penalty.Pp 1-199. Supporting Documentation Encl ML20238C5921987-06-16016 June 1987 Deposition of R Meeks.* Transcript of 870616 Deposition in Washington,Dc Re Allegations of Harassment Against R Parks. Pp 1-198.Supporting Documentation Encl ML20238C6171987-06-16016 June 1987 Deposition of R Meeks.* Corrected Title Page of 870616 Deposition ML20215L2731987-05-0808 May 1987 Transcript of 870508 Prehearing Conference in Bethesda,Md.Pp 19-224.In Camera Session (Pp 101-138) Bound Separately ML20238C7331987-04-24024 April 1987 Deposition of Rc Arnold.* Transcript of 870424 Deposition in Washington,Dc Re Civil Penalty.Pp 1-224.Supporting Documentation Encl ML20212Q9801987-04-16016 April 1987 Transcript of 870416 Periodic Meeting W/Advisory Panel for Decontamination of TMI-2 in Washington,Dc.Pp 1-50.Supporting Documentation Encl ML20212Q8021987-04-15015 April 1987 Transcript of 870415 Briefing by DOE in Washington,Dc Re TMI-2 Core Exam Program.Pp 1-64.Viewgraphs Encl ML20238C6521987-04-10010 April 1987 Deposition of Bk Kanga.* Transcript of 870410 Deposition in Gaithersburg,Md Re R Parks.Pp 1-151.Supporting Documentation Encl 1998-09-17
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UNITED STATES OF AMERICA ;;7 ," M A .77 NUCLEAR REGULATORY COMMISSION -
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD C, E' 10 '
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In the Matter of )
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METROPOLITAN EDISON ) Docket No. 50-289 COMPANY, et al., )
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j (Three Mile Island )
Nuclear Station, Unit )
No. 1) )
)
DIRECT TESTIMONY OF j ROBERT D. POLLARD ON BEHALF OF THE UNION OF CONCERNED SCIENTISTS REGARDING UCS CONTENTION NO. 14 4
October 2, 1980 i
80.100700/6-
ROBERT D. POLLARD OUALIFICATIONS Mr. Pollard is presently employed as a nuclear safety expert with the Union of Concerned Scientists , a non-profit coalition of scientis ts , engineers and other orofessionals supported by over 80,000 public sponsors.
Mr. Pollard's formal education in nuclear design bega..
in May , 1959, when he was selected to serve as an electronics technician in the nuclear power program of the U.S. Navy.
After completing the required trair,ing, he became an instruc-tor responsible for teaching naval personnel both the theore-tical and practical aspects of operation, maintenance and repair for nuclear propulsion plants. From February, 1964 to April, 1965, he served as senior reactor operator, supervis-ing the reactor control division of the U.S.S. Sargo, a nuclear-powered submarine.
! After his honorable discharge in 1965, Mr. Pollard attended Syracuse University, where he received the degree of Bachelor of Science magna cu m laude in Electrical Engt-neering in June, 1969.
In July, 1969, Mr. Pollard was hired by the Atomic Energy Commission (AEC), and continued as a technical exoert with the AEC and its successor the United States Nuclear Regulatory Commission (NRC) until February, 1976. After joining the AEC, he studied advanced electrical and nuclear engineering at the Graduate School of the University of New Mexico in Albuquerque. He subsequently advanced to the cositions of Reactor Engineer (Ins trumen ta ti on ) and Project Manager with AEC/NRC.
As a Reactor Eng i nee r , Mr. Pollard was primarily respon-sible for performing detailed technical reviews analyzing and evaluating the adequacy of the design of reactor protec-tion systems, control systems and emergency electrical power systems in proposed nuclear facilities. In September 19 74, he was promoted to the position of Project Manager and became responsible for planning and coordinating all aspects of the design and safety reviews of applications for licenses to construct and operate several commercial nuclear power -
plants. He served as Project Manager for the review of a number of nuclear power plants including: Indian Point, .
Unit 3, Comanche Peak, Units 1 and 2, and Catawba, Units i 1 and 2. While with NRC, Mr. Pollard also served on the '
standards group, participating in developing standards and safety guides, and as a menber of IEEE Committees.
i
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OUTLINE - DIRECT TESTIMONY ON UCS CONTENTION NO. 14 The testimony explains the fundamental significance in nuclear safety regulation of the distinction between safety and non-safety grade systems and components. It then demonstrates how the TMI-2 accident showed three shortcomings in past practice: 1) certain systems previously classified as non-safety are, in fact, impcrtant to safety; 2) some systems known to be safety-related do not meet all of the requirements applicable to such systems; 3) the design basis for judging the capability of safety systems has not been properly specified. The Staff has acknowledged, in fact, that despite an NRC requirement that failure of non-safety grade equipment should not initiate or aggravate an accident, there is no comprehensive and systematic demon-stration that this has been accomplished. In other words, the elaborate structure for ensuring diverse and redundant safety systems remains vulnerable to unforeseen failures of non-safety equipment, just as during the TMI-2 accident.
No systematic or comprehensive review has been made of TMI-l in the aftermath of the accident; the staff proposes a long-term study to address the problem. The promise of a study, .
l i
l
l while it may offer hope for future improvement, does nothing to solve the safety hazards demonstrated by the TMI-2 accident.
1 Before the plant is permitted to resume operation, all systems currently classified as non-safety which can in fact either cause or aggravate an accident or can be called upon to mitigate an accident must be identified and required to meet safety-grade criteria.
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UCS CONTENTION NO. 14 f
The accident demonstrated that there are systems and components presently classified as non-safety-related which can have an adverse effect on the integrity of the core because they can directly or indirectly affect temperature, pressure, flow and/or reactivity. This issue is discussed at length in Section 3.2, " System Design Requirements," of NUREG-0578, the TMI-2 Lessons Learned Task Force Report (Short Term). The following quote from page 18 of the report describes the problem:
There is another perspective on this question provided by the the TMI-2 accident. At TMI-2, operational problems with the condensate purification system led to a loss.of feedwater and initiated the sequence of events that even-tually resulted in damage to the core. Several nonsafety systems were used at various times in the mitigation of the accident in ways not considered in the safety analysis; for example, long-term maintenance of core flow and cooling with the steam generators and the reactor coolant pumps.
The present classification system does not adequately recognize either of these kinds of effects that nonsafety system can have on the safety of the plant. Thus, require-ments for nonsufety systems may be needed to reduce the frequency of occurrence of events that initiate or adversly affect transients and accidents, and other requirements may be needed to improve the current capability for use ,
of nonsafety systems during transient or accident sit-uations. In its work in this area, the Task Force will include a more realistic assessment of the interaction between operators and systems.
The Staff proposes to study the problem further. This is ,
not a sufficient answer. All systems and components which can either cause or aggravate an accident or can be called 1
14-2 upon to mitigate an accident must be identified and classified as components important to safety and required to meet all safety-grade design criteria.
My testimony on UCS Contention 14 addresses the following subjects: 1) the commission's scheme for classifying plant structures, systems, and components as either safety or non-
! safety equipment; 2) the types of errors made in applying the Commission's classification scheme which contributed to the TMI-2 accident; and 3) the relationship between the long-term study to develop requirements for non-safety systems (See NUREG-0578, Section 3.2 and NUREG-0585, Section 3.2) and the Commission's present classification scheme. In my opinion, this testimony demonstrates that the present TMI-l design poses undue risk to public health and safety'because: a)the non-safety system demonstrated to be important to safety by
- the TMI-2 accident have not been fully upgraded to safety grade;
- b) the safety systems demonstrated by the'TMI-2 accident to be in violation of certain safety grade requirements have not been upgraded to meet all safety grade requirements; and c) the j adverse interactions between non-safety and safety systems have not been identified and corrected. ..
14-3 Classification Scheme The Commission's licensing process involves assessing whether the plant's structures, system, and components can be relied upon to protect public health and safety in the event of occurrence of any of the selected design basis events, i.e., accidents or anticipated operational occurrences.
The commission has developed regulations that define the minimum requirements for design, fabrication, construction, testing and performance which must be met if a structure, system or component is rolied upon to protect the public. These require-ments are set forth in the General Design Criteria of Appendix A to 10 CFR Part 50, industry standards such as IEEE Std 279 which are incorporated in 10 CFR 50.55a, and other sections of 10 CFR Part 50.
Commission policy and practice has been to apply these requirements to those structures, systems, and components that provide the requisite reasonable assurance that the nuclear plant can be operated without undu'e risk to public health and safety. This equipment is variously referred to The inadequacies of the Commission's method of choosing des;gn basis events will be discussed in connection with 4 UCS Contention 13. .
s
14-4 as safety-related, safety grade or important to safety. The method of applying these requirements is to assume that only safety grade systems function during a design basis event.
Non-safety grade systems are assumed to be unavailable and, therefore, their functioning is not credited in evaluating the protection available to mitigate the consequences of a design' basis event.
TMI-2 Errors in Applying the Classification Scheme The TMI-2 accident demonstrated three types of errors that were made in applying the Commission's classification scheme. First, the accident showed that some systems that
' had been classified as non-safety should have been classified as systems important to safety. Second, some systems that had been classified as important to safety did not meet all the requirements' appl'icable to safety grade systems. Third, the design basis events for systems classified as important to safety had been incorrectly specified. I will now explain each of these errors.
- 1. Improper Classification of Systems During the course of the TMI-2 accident, several systems that had been classified as non-safety systems were used to mitigate the accident. For example, the reactor coolant pumps In an Advance Notice of Proposed Rulemaking, " Consideration of Degraded or Melted Cores in Safety Regulation," September 26, 1980, the Commission described current practice as follows: "Further-more, in reviewing reactor plant designs using the ' design basis accident' approach, the NRC does not review all structures, sys-tems, and components but rather reviews, in varying levels of detail, only those considered ' safety grade' by the applicant submitting a Safety Analysis Report. Items considered by the applicant to be outslae the scope of design basis accident analyses
[ Footnote continued on following page]
14-5
,' wero used at various timas to accomplish coro cooling. Had the accident included the loss of offsite power, the reactor coolant pumps would have been unavailable. The loss of offsite power during an accident is an event that must be considered in accordance with the provisions of GDC-17. However, since the reactor coolant pumps were classified as non-safety components, the lack of an onsite emergency power supply to operate the pumps was not required. The TMI-l design remains unchanged. Despite the need for the reactor coolant pumps to mitigate the TMI-2 accident, the Staff and Met Ed take the position that the pumps are not important to safety.
Other examples of systems classified as non-safety which affected the course of the TMI-2 accident are the pressurizer level instruments, the PORV and its associated block valve and the auxiliary feedwater system. The failure of the pressurizer level instruments required termination of reactor coolant pump operation. However, at TMI-l the class-ification remains unchanged. As a result, although provisions have been made to supply onsite power to the pressurizer level instruments, the design is such that a single failure will result in loss of power to all three pressurizer level instru-ments.
The inability to recognize an open PORV led to core damage. However, at TMI-l the ability to isolate an open
( Footnote continued from previous page) are generally not considered to be ' safety grade' and are not reviewed by the NRC to see whether they will perform as intended or meet various dependability criteria. This method of classification is based on the notion that things credited in the analysis of a design basis event or specified in the regulations are important to safety and thus are ' safety grade' while all else is 'non-safety grade.'
Non-safety grade items do not receive continuing regulatory super-vision or surveillance to see that they are properly maintained or I that their design is not changed in some way that might interact negatively with other systems. Instead, these items simply receive l
what attention may be dictated by routine industrial codes and by desires to enhance plant availability."
14-6 PORV apparently remains classified as not important to safety.
A single failure can result in the inability to close the single PORV block valve. Similarly, recognition of the vital importance of auxiliary feedwater to core cooling has not resulted in requiring that all safety grade requirements be met before TMI-l restarts. (See the Staff's TMI-l Restart Evaluation, page C8-37).
- 2. Systems Important to Safety Did Not Meet All Safety Grade Requirements The second type of error disclosed by the TMI-2 accident is the failure to require that systems classified as important to safety meet all the requirements applicable to safety grade equipment. For example, the emergency core cooling system was not designed to prevent operator interference with completion of its safety function. The protection system signals used to initiate ECCS operation were not derived from direct measurements of the desired variable-reactor vessel water level. -The contain-ment isolation system was not initiated bp diverse parameters.
Except for the last example, these deficiencies remain uncorrected at TMI-1.
- 3. The Design Basis for Safety Systems Was Inadequate The third type of error disclosed by the TMI-2 accident -
14-7 is the inadequate determination of the severity of the design basis event for which safety grade systems must provide pro-tection. For example, during the TMI-2 accident an attempt was made to use the decay heat removal (DHR) system for core cooling. This attempt was unsuccessful for two reasons.
First, the design basis did not require the DHR system to be operable up to the design pressure of the reactor coolant system. Second, the DHR system leak rate and radiation shielding was found acceptable on the basis that it would always be carrying water with a relatively low level of radioactive contamination. Because of the extensive core damage at TMI-2, the DHR system could not be used because its leak rate and radiation shielding were inadequate to prevent excessive radiation exposure and reactor coolant system pressure was higher than the DHR system design pressure.
These deficiencies remain uncorrected at TMI-1.
The above demonstrates that the licensing review of TMI-1, while based on a fundamental distinction between
" safety" and "non-safety" equipment, was not adequate to identify all equipment important to safety, to define the design bases for such equipment, or to identify and prevent adverse interactions between non-safety and safety equipment which can compromise the ability of safety systems to perform j
14-8 their necessary functions. There does not seem to be serious .
disagreement over this. In the TMI-2 Lessons Learned Final Report, the Staff acknowledged that there are myriad inter-actions between non-safety grade and safety grade equipment which have not been systematically evaluated.
"The interactions between non-safety grade and safety grade equipment are numerous, varied, and complex and have not been systematically ovaluated. Even though there is a general requirement that failure of non-safety grade equipment or structures shoqld not initiate or aggravate an accident, there is no comprehensive and systamatic demonstration that this has been accomplished." (NUREG- 05 8 5,
- p. 3-3) .
The Staff has also acknowledged that some non-safety grade systems have a direct effect on core cooling.
1 "The Staff agrees that some systems and components presently classified as non-safety related can have an effect on the core because they can directly or indirectly affect temperature, pressure, flow and/or reactivity."
(Response to UCS Interrogatory 156).
Long-Term Study of Non-Safety System Requirements Sections 3.2 of both NUREG-0578 and NUREG-0585 discuss a long-term study to address the problems I have discussed above. Met Ed will be required to " evaluate the interaction of non-safety and safety grade systems...to assure that any interaction will not result in axceeding the acceptance criteria for any design basis event." (NUREG-0585, page A-14). One question presented, then, is'how this Board can find reasonable 6
1 l
14-9 l
l l
assurance that public health and safety is protected until that long-term study identifying adverse interactions is completed and its results implemented. The period of time until the latter is accomplished appears to be open-ended.
The second question presented is perhaps a clearer one.
Where the accident showed clearly that particular equipment presently classified non-safety is, in fact , important to safety or where the accident showed that equipment important to safety does not meet all safety grade requirements, what is the basis for finding reasonable assurance that the plant is safe enough to permit resumption of operation?
~
In my opinion, the answer to both questions is that neither the Staff nor Met Ed have provided any evidence upon which one could find a reasonable basis for concluding that the plant is safe enough to operate in the face of the lessons learned from TMI-2.
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D j E In the Matter of ) 90l l -
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METROPOLITAN EDISON ) Docket No. 50-289 COMPANY, _et _al., )
)
(Three Mile Island )
Nuclear Station, Unit )
No. 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of the " Direct Testimony of Robert D. Pollard on Behalf of the Union of Concerned Scientists Regarding UCS Contention No. 9," and " Direct Testimony of Robert D. Pollard on Behalf of the Union of Concerned Scientists Regarding U S Contention No. 14" have been mailed postage pre paid this 2nd day of October, 1980 to the following parties:
Secretary of the Commission (3) Mr. Steven C. Sholly U.S. Nuclear Regulatory Commission 304 South Market Street Washington, D.C. 20555 Mechanicsburg, PA 17055 Attn: Chief, Docketing & Service Section James A. Tourtellotte, Esq. Jordan D. Cunningham, Esq.
Office of the Exec. Legal Director Fox, Farr & Cunningham U.S. Nuclear Regulatory Commission 2320 North Second Street Washington, D.C. 20555 Harrisburg, PA 17110 Karin W. Carter, Esquire Frieda Berryhill Assistant Attorney General Coalition for Nuclear Power 505 Exec'utive House Postponement P.O. Box 2357 2610 Grendon Drive Harrisbur,g, PA 17120 Wilmington, Delaware 19808 .
Daniel M. Pell Walter W. Cohen, Consumer Adv.
- ' 32 South Beaver Street Department of Justice York, Pennsylvania 17401 Strawberry Square, 14th Floor Harrisburg, PA 17127 i
?
Cert. of Service :
Docket No. 50-289 p..
Chauncey Kepford Robert L. Kaupp, Esquire Judith H. Johnsrud Assistant Solicitor Environmental Coalition on .
County of Dauphin Nuclear Power h P.O. Box P 433 Orlando Avenue State College, PA 16801 407 North Front 17108 Street Harrisburg, PA Levin, Esquire Robert O. Pollard John A. Chesapeake Energy Alliance Assistant Counsel 6.19 Montpelier Street Pennsylvania Public Utility Ealtimore, Maryland 21218 Commission Harrisburg, PA 17120 Marvin I. Lewis Theodore Adler 6504 Bradford Terrace Widoff, Reager, Selkowitz Philadelphia, PA 19149
& Adler 3552 Old Gettysburg Road Camp Hill, PA 17011 .
Ivan W. Smith, Chairman Ms. Marjorie Aamodt Atomic Safety & Licensing Board -
RD #5 U.S. Nuclear Regulatory Commission 20555 Coatesville, PA 19320 Washington, D.C. i Linda W.-Little Dr. ;
Dr. Walter H. Jordan 5000 Hermitage Drive 27612 881 W. Outer Drive Raleigh, North Carolina Oak Ridge, Tennessee 37830 Ms. Jane Lee George F. Trowbridge, Esquire R.D. #3, Box 3521 17319 Shaw, Pittman, Potts & Etters, Pennsylvania Trowbridge 1800 M Street, N.W.2't36 Wa shis . ; '- on , D.C.
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