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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
[Table view] |
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UNITED STATES OF AMERICA w ;., '
C-NUCLEAR REGULATORY COMMISSION <; I ,ce, # Ci r-AIE:
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'4cf.g{yg:7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,
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- In the Matter of )
, )
METROPOLITAN EDISON ) Docket No. 50-289 COMPANY, et al., )
1 )
(Three Mile Island )
Nuclear Station, Unit )
No. 1) )
)
DIRECT TESTIMONY OF ROBERT D. POLLARD ON BEHALF OF THE UNION OF CONCERNED SCIENTISTS REGARDING UCS CONTENTION NO. 3
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Septe aber 25, 1980 8'O 09300 Q20 i . ... ,
.e 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 scientists , engineers and other professionals supported by over 80,000 public sponsors.
Mr. Pollard's formal education in nuclear design began 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 training, 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 cum laude in Electrical Engi-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 oositions of Reactor Engineer (I ns trumenta tion ) and Project Manager with AEC/NRC.
As a Reactor Engineer, Mr. Pollard was primarily respon-sible for performing detailed technical reviews analyzing and evaluating'the adequacy of the design of reactor protec-tion . sys tems , control systems and emergency electrical power systems in proposed nuclear f acilities. In September 1974, he und promoted'to the posihion of Project Manager and became responsible for planning and coordinating all aspects of the design and safety reviews of applications for licensen to construct and operate several commercial.. nuclear power plants. .Heeserved as Pro je'c t Manager for t6e review of a
- number of nuclear power. plants includingi 14 dian Point, -
Unit 3, Comanche Peak, Units 1 and 2 g and Catawba, Units 1 and 2. While with NRC , Mr. Pollard.also served on the standards group, participating in developing standards and safety guides, and as a member of IEEE Committees.
t 9
1 OUTLINE - DIRECT TESTIMONY ON UCS CONTENTION NO. 3 This testimony describes why the ability to maintain natural circulation to remove decay heat is important to safety and how the pressurizer heaters are needed to assure natural circulation. It concludes that pressurizer heaters are com-ponents "important to safety" within the meaning of NRC reg-ulations. However, the TMI-l pressurizer heaters and associated controls do not meet the NRC's criteria applicable to the design and fabrication of components important to safety.
Therefore, they cannot be relied upon to function when needed.
This poses undue risk to puolic health and safety. TMI-l should not be permitted to restart unless and until the pressurizer heaters and associated controls are found to conform to all applicable safety-grade design criteria.
w
O UCS CONTENTION NO. 3 The staff recognizes that pressurizer heaters and associated controls are necessary to maintain natural cir-culation at hot stand-by conditions. Therefore, this equip-ment should be classified as " components important to safety" and required to meet all applicable safety-grade design criteria, including but not limited to diversity (GDC 22),
seismic and envircnmental qualification (GDC 2 and 4),
automatic initiation (GDC 20) , separation and independence (GDC 3 and 22) , quality assurance (GDC 1) , adequate, reliable on-site power supplies (GDC 17) and the single failure criterion.
The staff's proposal to connect these heaters to the present on-site emergency power supplies does not provide an equiv-alent or acceptable level of protection.
In order to maintain the TMI-1 reactor in a safe condition following a shutdown, it is necessary to remove the decay heat from the reactor. Assuming that the reactor core retains its coolable geometry and that the primary coolant pressure boundary remains intact, there is only one effective method of removing the decay heat at THI-1. Water must be
~
circulated through the reactor, the main coolant piping, and the steam generator tubes. The decay heat transferred from 9
Y
4 3-2 the fuel to the reactor coolant is then transferred to the secondary system through the steam generator tubes.
There are only two methods of providing circulation of the reactor cooling water available at TMI-1. These are forced circulation using one or more of the reactor coolant pumps or natural circulation. Either method of circulation requires that reactor coolant system pressure be maintained high enough to prevent boiling of the water. If a sufficiently high pressure is not maintained, the accumulation of steam will prevent operation of the reactor coolant pumps and will prevent natural circulation in the reactor coolant system.
At TMI-1, the pressurizer is used to control the pressure in the reactor coolant system. Turning on the electrical heaters submerged in the water at the bottom section of the pressurizer will increase pressure in the reactor coolant system. If one or more reactor coolant pumps are operating, opening the pressurizer spray valve results in spraying water water into the steam bubble in the top section of the pressurizer thereby decreasing reactor coolant system pressure. During normal operation, the pressurizer heaters and pressurizer
, spray valve are controlled automatically to maintain reactor coolant pressure in the desired range.
Prior to the TMI-2 accident, the design of TMI-l was such that, in the case of a reactor shutdown together with a
+
.I '-
0 3-3 loss of offsite electric power - a condition that must be designed for in accordance with GDC the reactor coolant pumps and pressurizer heaters would be inoperable. This is because they could not be powered from the onsite emergency diesel generators. After the TMI-2 accident, the staff's
" Lessons Learned" Task Force addressed this demonstrated inadequacy and TMI-l has since been modified to the extent that some of the pressurizer heaters can now be energized from the onsite emergency diesel generators.
The TMI-2 accident demonstrated that the inability to remove decay heat from a shutdown reactor can lead to severe fuel damage. Failure to maintain a sufficiently high pressure in the reactor coolant syster resulted in the formation of steam in that system. This in turn led to severe vibration of the reactor coolant pumps requiring the operator to stop those pumps. This terminated forced circulation in the reactor coolant system. Steam accumulation in the reactor coolant system also prevented the establishment of natural circulation.
As noted above, as a result of the TMI-2 accident, the NRC Staff and Met Ed decided to upgrade the pressurizer heaters to the. extent that some heaters could be connected to the onsite emergency diesel generators. The apparent purpose of this modification was to provide reasonable assurance that the pressure in the reactor coolant system could be maintained
3-4 high enough to permit decay heat removal by natural circulation.
Although I do not believe that an accident such as the TMI-2 accident should have been necessary to cause recognition of the importance of the pressurizer heaters, the following quote from NUREG-0578, page A-2 draws the connection between the TMI-2 accident and the need to assure the operability of the pressurizer heaters:
Maintenance of safe plant conditions, including the ability to initiate and maintain natural circulation, depends on the maintenance of pressure control in the reactor coolant system. Pressure control is normally achieved through the use of pressurizer heaters. Experience at TMI-2 has indicated that the maintenance of natural circulation capability is important to safety, including the need to maintain satisfactory natural circulation during an extended loss of offtice power.
As a result sf tha TMI-2 accident, the Staff developed a list of short-term actions that, in the Staff's view "would provide substantial, additional protection required for the public health and safety." (NUREG-0578, page 3. ) The Commission subsequently ordered that "[t]he licensee shall comply with the Category A recommendations as specified in Table B-1 of NUREG-0578." -(Order, item 8). I agree that changes in the TMI-l design are needed "to increase the availability of the reactor ,
pressurizer for pressure control in the event of loss of offsite power, thus decreasing the frequency of challenges to [the]
3-5 emergency core cooling systems." (NUREG-0578, page 6) . I conclude that such changes will provide substantial, additional protection which is required for the public health and safety.
However, for the reasons discussed below, I conclude that the measures described in Section 2.1.1.3.1, "Pressurizar Heaters," of the Restart Report and on page C8-7 of the Staff's TMI-l Restart Evaluation, are not sufficient to ensure the availability of pressurizer heaters when needed and thus do not provide the protection required for public health and safety. Fur thermore, as discussed in my testimony on UCS Contention 4, I conclude that the present design of TMI-l poses an additional hazard to public health and safety that was not present prior to the TMI-2 accident. To correct both of these problems, I conclude that the pressurizer heaters must be classified as components important to safety and the design of THI-l must be modified and tested to demonstrate conformance with the Commission's regulations that apply to components important to safety. .
In order to assure that systems needed to prevent or mitigate accidents can be relied upon, the Commission has developed the requirements contained in Appendix A to 10 CFR Part 50. The General Design Criteria set forth the minimum requirements for those structures, systems, and components i
I
3-6 that provide reasonable assurance that a nuclear power plant can be operated without undue risk to the health and safety of the public, i.e., those structures, systems, and components important to safety. The requirements of the General Design Criteria establish minimum necessary design, fabrication, construction, testir', and performance requirements for struc-tures systems, and components important to safety. The specific requirements address subjects such as the redundancy and independence of safety systems, the ability of safety systems to remain functional during and following events such as fire, earthquakes and loss-of-coolant accidents, the need for automatic operation, the ability to detect failures by periodic tests, and the ability to provide necessary emer-gency electric power. In short, the General Design Criteria set forth the Commission's definition of what is required to assure that a structure, system, or component can be relied upon to protect the public. The Commission's policy is that, in assessing the adequacy of a plant design, only those systems that meet the GDC can be assumed to function. Therefore, if a system is needed to prevent or mitigate an accident, conformance with the General Design Criteria is mandatory. Systems that meet the General Design Criteria are commonly called safety-grade.
F e
3-7 Prior to the TMI-2 accident, the pressurizer heaters were not classified as components important to safety and, therefore, were not required to comply with the General Design Criteria. The TMI-2 accident demonstrated the importance of pressure control and the Staff concluded that availability of the pressurizer heaters is important to pressure control.
I concur. In my opinion, the proper application of Commission policy upon this situation compels classification of the pressurizer heaters as components important to safety and the consequent requirement that the pressurizer heaters conform to the General Design Criteria prior to restart of TMI-1.
Neither the Staff nor Met Ed classify the pressurizer heaters as components important to safety. However, the Staff believes that requiring the provision for connecting the heaters to the onsite power supply "in effect constitutes reclassification of the pressurizer heaters as ' components important to safety' in the context of the discussion in GDC-17." (Staff Response to UCS Interrogatories 26 & 31, Met Ed Response to UCS Interrogatory 31). Both the Staff and Met Ed apparently conclude that the TMI-l design complies with the " position" on pressurizer heaters in Section 3.1 ,
of Appendix A to NUREG-0578 as modified by the Staff's seven
" clarification" items on page CS-6 of the Staff's TMI-l Restart l
l
3-8 Evaluation (NUREG-0 68 0) . Basically, the modification that has been made to THI-1, in accordance with that position and its " clarification", now permits the pressurizer heaters to be connected to the emergency power supplies by operator action.
This is apparently an attempt to meet that oortion of GDC-17 requiring that the onsite electric power system
" permit functioning of structures, systems, and components important to safety," assuming that the offsite electric 1
power system is not functioning. Neither the Staff nor Met Ed proposes to apply any other requirements in the GDC applicable to functioning of the pressurizer heaters as components important to safety, apparently not even GDC 15 and 20, which are among the requirements the Position in NUREG-0578 is supposed to satisfy. (NUREG-057 8, page A-4) . I find the Staff and Met Ed's position to be totally inconsistent with Commission policy and the TMI-l design to be incapable of providing d
reasonable assurance that the health an'-safety of the public l
will be protected. Providing a means of connecting the pressurizer heaters to the onsite electric power system, but not providing independence between the two groups of pressurizer heaters, not demonstrating that the heaters can function following .
a safe shutdown earthquake, steamline break, a loss of coolant O
s
3-9 accident, not providing automatic load shedding and connection of the heaters and not meeting any of the other Commission regulations applicable to functioning of the heaters can have two dangerous results. At best, heaters that are not operable may be connected to the onsite emergency power supply. At worst, connecting non-safety grade heaters may result in failure of the onsite emergency power supply.
In neither case would the objective of assuring reactor coolant pressure control be achieved.
The logical inconsistency of the Staff and Met Ed's position can be illustrated in several ways.
Neither the Staff nor Met Ed propose that the heaters should be designed to remain functional following an earth-quake, as required by GDC-2 for components important to safety. A short discussion will illustrate the illogic of their position. TMI is required to withstand the occurrence of a safe shutdown earthquake without endangering the public.
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The occurrence of a safe shutdown earthquake could, and in r
my opinion most,likely would, result in.a loss of offsite power. Without offsite power, reactor cooling will be adequate only if natural circulation is established. Maintaining the .
reacto
r coolant pressure is necessary to achieve natural circulation This aspect is discussed in my testimony on UCS Contention 4.
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3-10 and the pressurizer heaters are important to maintaining the pressure. However, since the heaters are not seismically qualified as required by GDC-2, they must be assumed to be inoperable following the earthquake.
The Staff and Met Ed's position regarding GDC-2 is also inconsistent with the Staff's previous position in Regulatory Guide 1.139, " Guidance for Residual Heat Removal." The following information was provided in Regulatory Guide 1.139:
- 1. The Reactor Safety Study found that " systems or equipment failures that led to the inability to remove decay heat resulted in a higher probability of a core melt than that predicted for a large
[ loss-of-coolant accident] for both [ pressurized water reactors and boiling water reactors.]"
- 2. " [A] significant safety benefit will be gained by upgrading those systems and equipment needed to maintain the [ reactor coolant system] at the hot-standby condition for extended periods or those needed to cool and depressurize the [ reactor coolant system] so that the [ residual heat removal]
system can be operated."
- 3. "Furthermore, . . . experience shows that there have been events that required eventual cooldown and long-term cooling until the [ reactor coolant system] was cold enough to perform inspection and repairs."
- 4. "It is therefore obvious that the ability to transfer heat from the reactor to the environment af ter a shutdown is an important safety function
... (emphasis added.)
- 5. "These accident conditions [in which it is essential to remove decay heat] can, conceivably -
include a safe shutdown earthquake (SSE) and 5
e l
4 3-11 an extended loss of offsite power that may have resulted from that SSE."
- 6. "In that case, all components and equipment that are not seismic Category I...would be assumed inoperable."
- 7. "Under these circumstances, a plant shutdown (including cooldown) within a reasonable time requires systems designed to safety grade standards and operable from the control room. However, limited operator actions outside the control room may be permitted if suitably justified."
- 8. "Without offsite power, reactor cooling depends solely on natural convection circulation..."
In my opinion, there should be no question that the pressuri=er heaters must meet GDC-2.
Another example of the illogical position adopted by the Staff and Met Ed is the failure to require conformance with GDC-4 by demonstrating that the pressurizer heaters will remain operable following a small loss-of-coolant accident. It is certainly ironic as well as illogical that a " lesson learned"
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by the Staff and Met Ed from the TMI-2 accident, which.was a small loss-of-coolant accident, is that th.e pressurizer heaters must be upgraded, but that such upgrading need not include a demonstration that the heaters are capable of functioning in the environment created by a loss-of-coolant accident. In 4
GDC-4 requires, in part, that structures, systems, and components important to safety be designed to operate under ,
normal and accident env.ironmental conditions, including loss '
of coolant accidents.
c.
1
3-12 addition, the Staff's position is inconsistent with its position prior to the TMI-2 accident as expressed in Regulatory Guide 1.139 "The design should be r;uch that the reactor can be taken from normal operating ',anditions to cold shutdown using only safety-grade systems that satisfy General Design Criteria 1 through 5."
One final example of the illogic of the Staff's position involves GDC-20, " Protection System Functions." The Staff claims that the measures recommended in NUREG-0578 are "[c]on-sistent with satisfying the requirements of General Design Criteria.. 20...." (Page A-4) . GDC-20 states: "The protection system shall be designed L1) to initiate automatically the operation of appropriate systems...to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences...." (emphasis added) i l
In contrast, the Staff's position in NUREG-0578 specifically )
calls for operator action to connect the pressurizer heaters !"
to the emergency power supply and to shed loads from the ,
emergency power supply to provide sufficient capacity for connection of the heaters. Thus, although the Staff claims otherwise, it is clear that a system which is initiated manually does not satisfy a criterion requiring automatic l
initiation.
I will now address those portions of the Staff's and Met Ed's positions which are apparently put forward to justify l
l
3-13 failing to require the pressurizer heaters to be classified as safety-grade.
Both the Staff and Met Ed refer to a " bleed and feed" l mode of reactor cooling using the emergency core cooling system and the power operated relief valve which can, they say, be used if natural circulation can not be established. However, I note that in response to UCS interrogatory 32, the Staff acknowledged'that it has not attempted to determine whether .
the combination of the " bleed and feed" mode and pressurizer heaters needed for natural circulation is safety-grade. For example, the Staff did not attempt to determine whether the
" bleed and feed" mode or the combination of the pressurizer heater and " bleed and feed" meets GDC-3, " Fire Protection,"
GDC-22, " Protection System Independence" and the single failure criterion. It is clear that neither system alone conforms t safety-grade criteria. Two non-safety grade systems do not add up to one safety grade system. This is not a matter-of the exercise of engineering judgment; i.t is the clear purport of NRC regulatory policy.
I also believe that even if the " bleed and feed" mode were demonstrated to be an affective heat removal method and were designed to meet the requirements applicable to systems important to safety (neither of these conditions is now met in my opinion) it would not be an acceptable substitute for
3-14 classifying the pressurizer heaters as safety grade. My reasoning is as follows:
- 1. One principal lesson of the TMI-2 accident is that the pressurizer heaters should be upgraded to reduce the challenges to the ECCS as a result of relatively frequent anticipated operational occurrences such as loss of offsite power. To suggest that an inadequate upgrading of the heaters can be compensated for by challenging the ECCS during an anticipated operational occurrence is completely contrary to the lesson supposedly learned.
- 2. Another principal lesson learned from the TMI-2
~
accident is that the frequency of events that lead to opening the PORV should be reduced and that the :
methods of assuring that a stuck open PORV can be isolated should be improved. To suggest that an anticipated operational occurrence should be handled by deliberately opening the PORV and turning a routine event such as loss of offsite power into a loss-of-coolant accident is contrary to the lesson supposedly learned.
In summary, I have described why the ability to maintain -
natural circulation to remove decay heat is important to safety 4
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3-15 and how the pressurizer heaters are needed to assure natural circulation. This leads me to conclude that the pressurizer heaters are "important to safety" within the meaning of NRC regulations. I have also described the Commission's regulatory policy with regard to equipment important to safety and shown how the Staff's position in this proceeding contravenes that policy. In my opinion, the reason why the Staff's position produces untenable and illogical results is that although the Staff recognizes the vital importance of pressurizer heaters in providing reasonable assurance that operation of TMI-1 will not pose undue risk to public health and safety, they fail to understand that non-conformance with the General Design Criteria precludes a finding that the pressurizer heaters will be available when needed.
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