ML20115G462
| ML20115G462 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/18/1985 |
| From: | Trowbridge G GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Asselstine J, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| CON-#285-606 OLA, NUDOCS 8504220208 | |
| Download: ML20115G462 (25) | |
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April 18, 1985 (202) 822-1026 Nunzio J. Palladino, Chairman
' Thomas M. Roberts, Commissioner James K. Asselstine, Commissioner Frederick J. Bernthal, Commissioner Lando W. Zech, Jr., Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Three Mile Island Nuclear Station Unit 1 Operating License No. DPR-50 Docket No. 50-2890/A Response to April 5, 1985 UCS letter to the Commission on TMI-1 Steam Generators Gentlemen:
By letter to the Commissioners dated April 5, 1985, the Union of Concerned Scientists (UCS) transmitted an eight-page document entitled " Safety Hazards of Degraded Steam Generators at TMI-1," and urged the Commission to defer operation of TMI-l unless.and until the safety questions raised by UCS are an-swered. The accompanying letter to the Commission from Philip R. Clark, President of GPU Nuclear Corporation, demonstrates that the safety concerns raised by.UCS are unfounded.
The purpose of this letter is to address the legal stan-
! dards applicable to the UCS " submission," which was not filed 8504220200 850418 PDR ADOCK 05000289 -
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, e SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNERSMep INCLUDING P4CFES$fCN AL CORPORAftONS
- Nuclear Regulatory Commission 1- April 18, 1985
- Page 2 l
- l as a pleading in either'the TMI-l Respprt or TMI-l Steam Gener-ator Repair adjudicatory proceedings.- The submission clear-ly constitutes a request that the CommiFsion suspend the TMI-l l operating license on grounds other thr.a those which formed the i
basis for the Commission's immediately effective suspension order of 1979. The UCS submission addresses exclusively the purported' risks of plant and operator responses to a steam gen-erator tube rupture event at TMI-l. The Commission has ruled explicitly that. steam generator tube rupture events do not have a reasonable nexus to the TMI-2 accident and, therefore, are outside the scope of the Restart proceeding. Metropolitan i Edison Company (Three Mile Island Nuclear Station, Unit No. 1),
- CLI-84-3, 19 N.R.C. 555 (1984).
Requests from members of the public to the NRC seeking the i suspension, modification or revocation of a license, or other
- enforcement action, may be filed pursuant to 10 C.F.R. 5 2.206.
- Communications from the public which request such actions arc i
treated as petitions under section 2.206 even if they are not 2
labeled as such. See letter from the Commission to UCS, April i 24, 1984 (attached). The UCS submission clearly constitutes such a petition. It seeks enforcement action with respect to a license, and sets forth asserted bases for that action areindependentofanypendingadjudicatoryproceeding.ypich T
Further, the UCS petition seeks temporarily effective, im-mediate interim relief in the form of license suspension while the UCS safety concerns are assessed by the agency. This re-quest, thinly disguised as a suggestion that TMI-l resumed op-eration be deferred, ignores the legal standards which govern j such proposed action.
The norm for administrative action modifying outstanding licenses embraces a prior opportunity to be heard. Consumers 1/ UCS is not a party to, and has not participated in, the TMI-l Steam Generator Repair proceeding.
4 2/ 'It may be that UCS has failed to label its submission ac-curately because UCS hopes to bypass the initial Staff review.
j- which is an inherent part of the section 2.206 process. In the past, UCS has asked the Commission to take jurisdiction of such petitions in the first instance. The Commission has declined
- to do so. See " Union of Concerned Scientists' Petition for
- Show Cause Concerning TMI-l Emergency Feedwater System," dated
't January 20, 1984; UCS letter to the Commission, February 13, 1984; Commission letter to UCS,' April 24, 1984; " Supplement to Union of Concerned Scientists' Petition for Show Cause Concern-
! ing TMI-l Emergency Feedwater System," dated May 9, 1984.
I ,
l
SHAw, PITTMAN, PoTTs & TROWBRIDGE A pamTNERSMip OF pmOFESSiONAL CompomatiONS Nuclear Regulatory Commission April 18, 1985 Page 3 Power Company (Midland Plant, Units 1 and 2), CLI-73-38, 6 A.E.C. 1082, 1083 (1973). The Administrative Procedure Act provides a licensee a right to notice and an opportunit'1 to achieve compliance prior to license suspension. See 5 U.S.C.
'S 558(c). The section 2.206 procedure embodies this statutory scheme. If the relevant office director determines that a sub-stantial health or safety issue exists, he issues a show cause order pursuant to 10 C.F.R. 5 2.202. The affected licensee would then have the opportunity to respond to the show cause order by written answer under oath or affirmation, and to re-quest a hearing. 10 C.F.R. 5 2.202(b). If a hearing were re-quested, any order to modify, suspend or revoke the license would issue adter, and be based upon the record of, that hear-ing.
An order to show cause may provide, however, for stated reasons, that the proposed actions be temporarily effective
'pending further order if the public health, safety or interest so requires. 5 U.S.C. 5 558(c); 10 C.F.R. 5 2.202 (f). The Commission has stressed that summary administrative _ action is a
" drastic procedure." Midland, supra, CLI-73-38, 6 A.E.C. at 1083. "Such action, unless warranted by compelling safety considerations, can have serious consequences." Id. (emphasis added).
This legal setting is unaffected by.the present suspension of the TMI-1 license on other grounds. The only legal bases for the current temporary suspension are those which arose from the TMI-2 accident and were articulated by the Commission in 1979. Any enforcement action taken by the Commission with re-spect to this UCS petition must be based on the merits of the petition itself. Neither is UCS entitled to expedition in the treatment of its petition simply because of the schedule of the Restart proceedings. GPU Nuclear has all the rights and privi-leges of its license, under the Administrative Procedure Act, to the extent they are outside the scope of the existing sus-l- pension orders and the basis upon which they were issued. The suspension may not be unilaterally extended on new grounds sim-ply because a carefully timed letter is lodged by UCS.
Res tfully sub tted, M .f
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- Attached Service List
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BRANCH Ellyn R. Weiss, Esq.
General Counsel Union of Concerned Scientists 1346 Connecticut Avenue, NW Suite 1101 Washington, DC 20036
Dear Ms. Weiss:
This responds to your letter of February 13, 1984 regarding the UCS petition for show cause concerning the Three Mile Island, Unit 1 (TMI-1) emergency feedwater system. In that.
letter you inquired by what means the UCS request that the Commission itself take jurisdiction over the UCS petition was denied, and requested reconsideration of that denial.
You also set forth three categories of information which you wished staff to provida.
Since the adoption of 10 CFR 2.206 in 1974 the Commission has regularly referred all correspondence requesting enforcement action -- whether or not denominated a 2.206 request and whether or not directed to the Commission -- to the Executive Director for Operations for further referral to the appropriate office director. See 39 Fed. Reg. 12353 (April 5, 1974).
Only in rare cases, such as where the petition has raised broadbased or comprehensive challenges which may be considered
'more akin to a request for rulemaking, has the Commission itself directly acted. E. ., Petition for Emergency and Remedial Action, CLI-78 , NRC 400 (1978) (fire protection requirements) ; Denial of Petition for Revoking Nuclear Plant Licenses, 46 Fed. Reg. 39573 (August 4, 1981) (health impacts of the nuclear fuel cycle) .
The Commission does not believe the plant specific challenges raised in the UCS pett' tion warrant direct Commission action in the first ins %ance. The NRC staff has both the resources and the relevant expertise to assess the UCS arguments, and will provide a reasoned assessment of whether further action is warranted. The Commission will then have the opportunity sua sponte to review that determination. 10 CFR 2.206 (c) .
l I
2 i
That the staff has previously taken the position that no
! additional actions are required prior to any restart does not mean that staff will be unable or unwilling to give the UCS petition a fair evaluation. See Porter County Chapter
- v. NRC, 606 F.2d 1363 (D.C. Cir. I379). If a member of the staTF said that he intended to " shoot down" the UCS petition, 4
that statement was wholly inappropriate and will not reflect the treatment given the UCS petition.
. The Commission has accordingly decided to continue to have staf f respond to the UCS petition under 10 CFR 2.206. The Commission is also directing' staff in.its 2.206 decision to respond to the three categories of information set forth in s your February 13 letter.
The Commission. had also directed the staff on February 3, 1984, to respond to the UCS petition within 60 days of that date. Subsequently, on March 22, 1984 and April 9, 1984 (letters attached) the staff advised the Commission that the 60 day time frame could not be met and the Commission directed the staff to complete the action not later than May 30, 1984. Further, the Commission has directed the staff to brief the Commission on the issues raised by the petition before restart-of TMI-1.
Attachments:
As Stated r Sincerely, I /
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./ Samuel . Ik peeretary of the Commission t l t
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SERVICE LIST
- Nunzio ..._Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission Gustave A. Linenberger, Jr.
Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Thomas M. Roberts, Commissioner Washington, D.C. 20555
, - U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge
- Gary J. Edles James K. Asselstine, Commissioner Chairman, Atomic Safety and
- - U.S. Nuclear Regulatory Commission Licensing Appeal Board-
> Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Frederick Bernthal, commissioner U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 John H. Buck Atomic Safety and Licensing j Lando W. Zeck, Jr. , Conimissioner Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Ivan W. Smith Christine N. Kohl Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555
- - Administrative Judge Docketing and Service Section (3)
! Sheldon J. Wolfe Office of the Secretary
~
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Mr. Henry D. Hukill 4 Board Panel Vice President
, U.S. Nuclear Regulatory Commission GPU Nuclear Corporation
! . ' Washington D.C. 20555
, P. O. Box 480 Middletown, PA. 17057 Atomic Safety and Licensing Appeal Board Panel Mr. and Mrs. Norman Aamodt i
U.S. Nuclear Regulatory Commission 200 North Church Street
, Washington, D.C. 20555 Parkesburg, PA. 19365 1
~
, Jack R. Goldberg, Esquire Mrs. Louise Bradford Office of Executive Legal Director TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street Washington, D.C. 20555 Harrisburg, PA. 17102 t
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a SERVICE LIST Page 2 Thomas Y. Au, Esquire Joanne Doroshow, Esquire Office of Chief Counsel The Christic Institute Department of Environmental 1324 North Capitol Street Resources Washington, D.C. 20002 505 Executive House l P. O. Box 2357 Lynne Bernabei, Esquire Harrisburg, PA. 17120 Government Accountability Project Michael F. McBride, Esquire 1555 Connecticut Avenue LeBoeuf, Lamb, Leiby & MacRae Washington, D.C. 20036 1333 New Hampshire Avenue, N.W.
Washington, D.C. 20036 Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan Michael W. Maupin, Esquire 2001 S Street, N.W., 6430 Hunton & Williams Washington, D.C. 20009 707 East Main Street P. O. Box 1535 William T. Russell Richmond, VA. 23212 Deputy Director, Division of Human Factors Safety Office of NRR Mail Stop AR 5200 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
l GPU Nuclear NMCIMr EE DITAETED USMC 100 interpace Parkway Parsippany. New Jersey 07054 201 263-6500 TELEX 136-482 Writer s Direct Dial Number April 18, 1985 0FFICE 0: SECRdTAPy 5211-85-2077 000XET!N3 & 3ERVID SRANCH Nunzio J. Palladino, Chairman Thomas M. Roberts, Commissioner James K. Asselstine, Commissioner Frederick J. Bernthal, Commissioner Lando W. Zech, Jr., Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Three Mile Island Nuclear Station Unit 1 Operating License No. DPR-50 Docket No. 50-289 Response to April 5, 1985.UCS letter to the Commission on TMI-1 Steam Generators Gentlemen:
By letter to the Commissioners dated April 5, 1985, the Union of Concerned Scientists (UCS) transmitted an eight-page document entitled " Safety Hazards of Degraded Steam Generators at TMI-1," and urged the Commission, faced with UCS' safety questions, to defer operation of TMI-l unless and until it has been demonstrated that such operation will not pose undue risks to the health and safety of the public.
UCS contends that operation of TMI-1 with " degraded" steam generators could pose serious risks that have not been evalu-ated or brought to the Commission's attention. These unique risks, according to UCS, "arise from the inability of the steam generators in their degraded condition to withstand the forces that may occur following a steam generator tube rupture acci-dent." UCS asserts that TMI-l emergency procedures for steam generator tube ruptures cannot be implemented without violating safety limits and precautions applicable to other plants, and that generically applicable safety margins have already been reduced.
The UCS paper, under the heading " Specific Safety Haz-ards," identifies the following four factors relevant to the plant's condition: (1) Limiting Steam Generator Tube Stresses; (2) Violation of Subcooling Margin Criteria; (3) Violation of GPU Nuclear is a part of the General Pubhc Utilities System
f i
y
-Nuclear-Regulatory Commission April 18, 1985 Page 2 Reactor Coolant Pump Operating Limits; and (4) Violation of Fuel-Pin-in-Compression Safety Limits. The fifth and final
" specific safety hazard" raised by UCS is entitled " Operator i
Training Deficiencies." Under this topic, UCS also challenges the TMI-1 emergency procedures as too complex and confusing for an operator to follow.
The balance of this letter and the attachment constitute the GPU Nuclear response to the UCS allegations. In the at-tachment, we first address the premise which underlies the UCS paper -- the so-called " degraded" condition of the steam gener-ator tubes at TMI-1. The remainder of the attachment is orga-nized to parallel the five topics identified by UCS as
" specific safety hazards."' In an accompanying letter, our counsel. discusses the legal standards which the Commission should employ in considering the UCS letter.
The attached response demonstrates that the allegations raised by UCS are unfounded, and reflect either. lack of under-standing of the technical facts, or. selective and inappropriate juxtaposition of unrelated technical issues. In our view, the UCS letter is a variant on the now well known practice of introducing-last minute allegations and should be recognized and treated as such.
The fundamental premise underlying those allegations --
the so-called " degraded" condition of the steam generator tubes
-- is demonstrably incorrect. This error alone is dispositive of the UCS contentions. Neither is the~ condition of the steam generators at TMI-1 " unique," as UCS repeatedly claims. The sceam generators meet applicable NRC criteria and requirements,
' including the original licensing basis, and these criteria and requirements are not unique when compared to those imposed by the NRC on other nuclear power plants.
What UCS describes as " safety limits" which will be vio-lated under TMI-1 procedures are not, in fact, safety limits either at TMI-1 or at other plants. Further, the features of the procedures discussed by UCS actually enhance the capability of . the plant to recover quickly from tube rupture events, and therefore contribute to the protection of the public health and safety.
The TMI-1 emergency procedures have been developed in accordance with the NRC'c generic long-term " Lessons Learned" program, and are'an expansion of the symptom-oriented proce-dures developed by Babcock & Wilcox for the B&W Owners Grovo.
The Staff has endorsed the application of these guidelines to the TMI-1 procedures, and this represents an enhancement of the facility's ability to protect the health and safety of the
I O
Nuclear Regulatory Commission April 18, 1985 Page 3 public in the event of a steam generator tube rupture accident.
The complexity of the procedures actually has been reduced through the use of'the Abnormal Transient Operating Guidelines symptom-oriented approach to procedures, endorsed by the NRC.
As to TMI-1 operator training UCS had the opportunity, which it pursued, to challenge the GPU Nuclear operator training program in the Restart proceeding. In addition to the fact that the UCS letter employs faulty factual bases to chal-lenge operator training, the Licensing Board has essentially ,
approved GPU Nuclear's program on the basis of a substantial evidentiary record. See Licensing Board Response to CLI-85-2, April 11, 1985. Finally, both the licensed operator initial and requalification training programs for TMI-1.have recently been accredited by the Institute of Nuclear Power Operations.
In summary, there is no basis for the UCS allegations that operation of TMI-l poses serious risks, unique to TMI-1, which have not been evaluated or brought to the Commission's atten-tion. Contrary to the UCS assertions, the TMI-l steam genera-tors are not degraded, emergency procedures have been-simplified, improved, and do not involve violations of applica-ble safety limits, and operator training has been. comprehensive and effective. In short, the very items questioned by UCS en-hance protection of the public health and safety.
Sincerely, J
P. R. Clark President Attachment cc: J. Stolz T. Murley R. Conte Attached Service List
a ATTACHMENT Condition of the Steam Generator Tubes The fundamental premise underlying UCS' comments is that the TMI-l steam generators, because of the condition of their tubes, are'" degraded." The premise is incorrect. Nearly all of the tube damage took place high inside the upper tubesheet.
These damaged portions of the tubes were removed from service, i.e., removed from the primary pressure boundary, by the kinet-ic expansion repair process. All tubes with ECT indications of defects equal to or in excess of the 40% throughwall criteria in their unrepaired spans have been removed from service by plugging.
UCS was not a party to, and did not seek participation in, the hearings on the acceptability of the tube repair process.
The evidence presented by both GPU Nuclear and the NRC Staff demonstrated that the repaired tubes are in conformance with their original licensing basis. TMIA, the intervenor in the TMI-l Steam Generator Repair proceeding, has not appealed the Licensing Board finding on the adequacy of the kinetic expan-sion repair process and the integrity of the repair joint.
Thus, the steam generators have been found to meet all applica-ble Commission criteria and requirements, including the origi-nal licensing basis, and are in no way " degraded."
Further, these criteria and requirements are typical of those imposed by the NRC on other operating reactors, and en-dorsed through NRC approval of Standard Technical Specifica-61ons. (Refs. 1 and 2.) These criteria typically specify that stean generator tubes with through wall indications greater than or equal to 40% are to be. removed from service. This limit has a margin of safety such that cracks of this depth or less (even assuming 360* circumferential extent) will not prop-agate and rupture as a result of the worst case design basis loads.
GPU Nuclear has performed extensive examination of the TMI-l steam generator tubes, using current state-of-the-art eddy current examination techniques, to ensure compliance with Technical Specification criteria. All tubes with indications found to be greater than or. equal to 40% through wall have been repaired or removed from service. Subsequently, the steam gen-erators have been subjected to leak rate testing to verify leak tightness.
Finally, it should be noted that through wall indications in steam generator tubes are not phenomena unique to TMI-1, as discussed in several NRC staff reports. (Refs. 3, 4 and 5.)
Thus, the steam generators at TMI-l cannot in any sense be characterized as unique or degraded. All of the UCS
/
allegations are based on a faulty premise. Nevertheless, each of the specific UCS contentions is addressed below.
UCS Item 1: Limiting Steam Generator Tube Stresses UCS maintains that the 70*F shell-to-tube temperature dif-forential limit at TMI-1, is lower than that at other B&W plants, reduces the rate of reactor coolant system cooldown, and therefore is undesirable. UCS also argues that controlling the shell-to-tube temperature difference is difficult and com-plicated.
I The allowable shell to tube temperature differential at TMI-l is not a technical specification limit. Rather, as dis-cussed by the Staff in NUREG-1019 (Ref. 6), this lowered limit simply reflects additional conservatism. It was not estab-lished out of concern for " degraded" tubes. (Ref. 7.) Experi-ence at TMI-l has shown that the 70*F shell to tube temperature differential is not normally encountered. (Ref. 8.)
t Further, reduction of the shell to tube differential tem-
! perature limit to 70*F does not extend the time needed to cooldown the plant provided the main feedwater system is used for steam generator feed, since the shell to tube differential temperature is expected to stay below the 70*F limit at the maximum allowable cooldown rate. If emergency feedwater has to be used instead of main feedwater, the maximum shell to tube differential temperature could exceed the allowable limit with a rapid cooldown rate. The operator could then increase steam generator level or reduce the cooldown rate. In any event, the i effect on the overall cooldown time would be small, and there
- would be no significant adverse safety consequences. (Refs. 8 and 9.)
Since the shell-to-tube differential temperature varies slowly over time, thereuis no need to have immediate and con-tinuous readout of this information. The operators normally can read the value from the plant computer, or from direct tem-perature readings if the plant computer is unavailable. (Ref.
10.) NRC requires, and GPU Nuclear has provided at TMI-1, safety-grade instrumentation to measure many primary and sec-ondary system parameters. However, assuring public health and safety does not require (nor do NRC regulations require) safety-grade instrumentation to measure shell to tube differen-tial temperature, as inferred by UCS. (Ref. 11.)
In the Fall of 1983, GPU Nuclear conducted a series of tests on the TMI-1 plant with the goal of establishing a large shell to tube temperature difference on the steam generator. A large temperature differential did not develop in two of three
- tests because the shell is effectively cooled under nearly all I
a plant conditions. A 100*F temperature differential finally was achieved by using emergency feedwater and by controlling at the low level setpoint. Even in this plant condition, the tempera-ture differential could have been reduced by raising the water level-in the steam generator (or letting it rise due to tube leakage). Therefore, while knowledge of shell temperature is useful, it is not necessary in limiting differential tempera-ture. (Ref. 8.) The results of these 1983 tests demonstrate that shell to tube differential temperature can be controlled by the operator, regardless of the source of feedwater avail-able.
UCS also maintains that additional hazards will be presented if offsite power is lost during a steam generator tube rupture event at TMI-1. In fact, the TMI-l emergency pro-cedures specifically address tube rupture with simultaneous loss of offsite power. They provide for natural circulation cooldown (i.e., reactor coolant pumps inoperative) during tube rupture events.
UCS continues with the loss of offsite power scenario, contending that the reactor cannot be depressurized using the pressurizer spray, and that the pilot operated relief valve would have to be used. In fact, TMI-1 procedures call for use of the safety-grade pressurizer vent to reduce pressurizer pressure. The PORV is available as a backup.
UCS Item 2: Violation of Subcooling Margin Criteria In 1979, prior to the steam generator leakage problem, GPU initiated studies of reduced subcooling margin. Then, in re-sponse to TMI Action Plan (NUREG-0737) Item II.K.3.5, requiring reevaluation of reactor coolant pump trip criteria, GPU Nuclear proposed in March, 1983, a reduction of the minimum indicated subcooling margin from 50*F to 25'F. The proposal was based upon new analyses demonstrating that a reduced subcooling mar-gin allows better plant control during recovery from events of interest, including small-break LOCAs, steam generator tube rupture events, and overcooling transients. (Ref. 12.)
Copies of this proposal were served upon the Appeal Board, which then had jurisdiction over the plant design / procedures issues in the Restart proceeding, and on the parties including UCS. In its decision, ALAB-729, 17 N.R.C. 814, 881 n.315 (1983), the Appeal Board took note of this submission and stat-ed as follows:
That information indicates that the reduc-tion in subcooling margin for TMI-l is sup-ported on the grounds that a specific check at TMI-1 shows an error band of approximately 1 20*F for the primary coolant instrumentation temperature abave 300 psig. The original 50 F subcooling margin had been accepted on the assumption of 45*F instrument error. Thus the new proposal ~ continues to allow the same 5*F margin as originally contemplated. The staff has accepted this change on the basis that the lower subcooling margin will allow better plant control during recovery opera-tions. See Board Notification BN-83-34A (April 28, 1983), Enclosure 1. No objec-tions have been received from the other parties. We agree to this change, provid-ing the 20*F error in the TMI-l instrumen-tation is not exceeded.
The Commission, in its review of plant design / procedures issues' in the Restart proceeding, did not disturb this finding.
Consequently, the Staff and the Appeal Board, without ob-jection by UCS, approved the 25*F subcooling margin. Subse-quently, GPU Nuclear itself raised doubt that the 20*F instru-ment error limit imposed by the Appeal Board would be met in view of new instrument string error analyses, although the 25*F margin was maintained. This was reported in a letter to the Staff, copies of which were served on the Commission and the Restart parties. (Ref. 13.) The Staff affirmed its approval of the 25*F limit, and the Commission distributed the Safety Evaluation to the Restart parties for comment. (Ref. 14.) It is at this point that UCS advanced its comments of August 24, 1984, which are cited in the UCS letter of April 5, 1985. Sub-sequently, however, a superseding GPU Nuclear analysis showed that the instrument error would comply with the Appeal Board condition. (Ref. 15.) Again, thi: analysis was served on the Restart parties, including UCS, by both Licensee and the Staff (BN-84-164, September 26, 1984). While the Staff is still re-viewing the instrument error analysis, the subcooling margin criterion was conclusively approved in the Restart proceeding and is not subject to renewed attack here. Likewise, contrary to the UCS assertion, the subcooling margin monitoring system at TMI-l is safety-grade.
i Nevertheless, we note here that UCS overstates when it de-scribes the 50*F subcooling margin as a " lessons learned requirement." IE Bulletin 79-05B is the source of the 50*F subcooling margin criterion. According to the NRC (Ref. 16):
I the 50*F subcooling margin was based on the need to provide rapid guidance to the in-dustry in this area. Because of a lack of plant specific information readily
i available to the staff, the 5+'F subcooling margin was selected to include sufficient margin to cover instrument measurement un-certainties and geometry effects on a ge-neric basis.for all B&W designed PWRs.
Licensees always had available the option of selecting an alternate subcooling margin less restrictive provided they provided the necessary justification which demonstrated the original objectives for requiring a subcooling margin had been met (i.e., pre-vention of boiling in the coolant loops).
Within this framework, the TMI-l licensee proposed to base its subcooling margin criteria upon a plant specific instrumen-tation string error analysis rather than upon the generic assumption.
The 50*F subcooling margin criterion had been found acceptable by NRC historically on the assumption of a 45*F instrument error and a 5*F physical configuration error. The 25*F criterion is based on a calculated instrument error of less than 20*F and the original 5*F physical configuration error. In fact, the physical configuration factor has been calculated to be 1.3*F, and for steam generator tube rupture events, the instrument error is less than 8 F, ensuring even additional margin to saturation. (Ref. 17.)
UCS also contends here that under loss of offsite power conditions, the operator would not be able to determine sub-cooling margin. However, whenever the reactor coolant pumps are not operating, and regardless of temperature or pressure conditions in the primary system, the operator uses the incore thermocouples and pressure transmitters to determine subcooling margin, as required by the emergency procedures. (Refs. 17 and 18.)
UCS Item 3: Violation of Reactor Coolant Pump Operating Limits UCS states that " proposed" limits on reactor coolant pump operation at TMI-1 violate limits applicable to every other similar plant, and that GPU Nuclear proposes to " relax" the
" normal" limits applicable to pump operation in order to re-spond to steam generation tube rupture events.
Contrary to these assertions, there is no proposed relax-ation of the administrative (not technical specification) lim-its on pump operation at TMI-1, and the GPU Nuclear limits are not unique. No NRC criteria or requirements are violated by the TMI-1 limits.
s The required pressure / temperature limits for reactor coolant pump (RCP) operation, i.e., the RCP net positive suc-tion head (NPSH) limits, are affected by a steam generator tube rupture. For this event, the emergency RCP NPSH limits are used. These limits allow operation of the RCPs with decreased subcooling margin in the primary system relative to the normal RCP NPSH limits. Use of the emergency RCP NPSH limits does not result in violation of any plant safety limits.
The emergency limits allow for operation of the reactor coolant pumps for a wider range of plant conditions while still providing NPSH protection for the pumps. As a result of the use of the emergency limits, continued pump operation is ex-pected for the design basis double-ended rupture of a single steam generator tube. Continued operation of the RCPs for tube rupture events has obvious safety benefits such as the avail-ability of normal pressurizer spray for RCS pressure control, decreased primary-to-secondary leakage for a given RCS sub-cooling margin, and symmetric plant cooldown.
Normal reactor coolant pump NPSH limits are intended to apply for long-term operation, and are adhered to at TMI-1 under normal operating conditions. However, since it is desir-able to maintain forced RCS flow during an emergency cooldown, use of emergency NPSH limits is not only appropriate, but rep-4 resents a prudent action which reduces the potential for ra-diological release by reducing tube leakage. The Staff agrees with GPU Nuclear's judgment on this matter. (Ref. 19.) The pump manufacturer also has agreed with GPU Nuclear's judgment that for such short periods of time as this limit would be re-laxed, no significant damage to the pumps would be expected.
UCS Item 4: Violation of Fuel-Pin-in Compression Safety Limits
- Fuel pin compression limits are not safety limits. The i fuel pin compression limits are imposed as a precautionary mea-sure to prevent a change in the zircalloy cladding, which could (if it were to occur) result in weakened cladding during a sub-sequent heatup. No cladding failure is expected to re1 ing.thecooldownanddepressurizationinwhichthelimbultdur- t is waived. For this reason, during emergency cooldowns waiver of the normal fuel pin compression limits is allowed and in cer-tain instances recommended by Babcock & Wilce.x. Most B&W plants, including TMI-1, have utilized these cases [n developing emergency procedures which waive normal tuel som-pression limits. If a transient occurs in the plant ancl the
- normal fuel pin compression limit is exceeded, a post-trinsient evaluation to determine the acceptability of the fuel for sub-sequent operation would be conducted prior to startup.
t
Secondly, the hazards postulated by UCS have no-physical bases. For example, there is no plausible mechanism which could induce ballooning during a cooldown event. Ballooning can only occur with.very high cladding temperatures, such as might occur during events such as a loss-of-coolant accident.
UCS Item 5: Operator Training Deficiencies UCS' criticisms concerning the adequacy of operator training on steam generator tube leak / rupture accidents are faulty and improperly raised in view of the reopened Restart proceeding on training.
UCS' concern about the ability of operator training to address the emergency procedures involved in steam generator tube leak / rupture accidents is based on UCS " doubts" about three reactor operators' mastery of these procedures. These doubts were never aired-by UCS during the reopened Restart pro-ceeding on training. Obviously, this is not because of a lack of opportunity to do so -- the information on which UCS relies is information elicited by UCS during the discovery period that preceded the reopened evidentiary hearings. Moreover, the ade-quacy of training on emergency procedures fell squarely within the scope of the proceeding. In fact, this issue was the very subject of one of the topics identified by UCS for litigation in the proceeding -- UCS issue (1) states, "Are the operators trained to safely operate the plant in.accordance with approved procedures, particularly in emergencies?". See Licensing Board Memorandum and Order on Lead Intervenors, July 13, 1984, at 2, as modified by Memorandum and Order on Licensee's July 31, 1984 Comments on Lead Intervenors and Motion to Partially Exclude UCS From Management. Phase, Aug. 30, 1984,-at 3. Furthermore, the special training given by Licensee to its operators on steam generator tube leak / rupture accidents -- the precise pro-cedures questioned here -- was discussed by Licensee's opera-tions and Training managers in their prefiled direct testimony and on cross-examination by UCS and other parties to the re-opened proceeding. See, e.g., Newton et al., ff. Tr. 32,409, at 20-21, 33; Tr. 32,855-56 (Ross); Tr. 33,415-19 (Leonard, Ross).
In short, UCS' alleged present " doubts" are based on its personal interpretation of information previously available to UCS which it had every opportunity to and chose not to liti-gate. Accordingly, UCS' assertions should be rejected out of hand -- they constitute an impermissible attempt to bypass the adjudicatory process fully available and, in fact, utilized by UCS.
Furthermore, there are several noteworthy facts about UCS' questioning of operators, on which UCS' " doubts" are based,
~
which UCS has failed to mention in its April 5 letter. In November, 1984, UCS hand-picked three TMI-l reactor operators and a TMI-l senior reactor operator, and gave each of these individuals a one-hour written exam and about a one-hour oral exam. The examinations were conducted by Mr. Pollard.
After reviewing the results of its tests, UCS decided not to call any of the four operators as witnesses, even though it previously had so designated these individuals. This reversal was not surprising to GPU Nuclear, which objectively evaluated the performance of the operators during the UCS written and oral tests, and concluded that the four operators had responded satisfactorily -- i.e., without any advance preparation, such as the intense studying and review which ordinarily might pre-cede comprehensive examinations, the operators had clearly passed UCS' tests. (Licensee estimated the SRO received a 97%
on UCS' written test. The other operators' written scores were 84%, 85% and 81%.)
Thus, it is particularly inappropriate and misleading for UCS to pluck out of these tests isolated answers in order to attempt to establish a point UCS had every opportunity to pur-sue during the adjudicatory proceeding. The fact is that these tests reflect very favorably on the individuals involved, as well as on the training program, which most assuredly is why UCS did not use this information in the adjudicatory setting.
Finally, UCS' position in its April 5 letter is based on a miniscule amount of the information available to UCS. Through discovery, UCS has available to it, among other documents, the schedules for the licensed operator requalification program for the period in question, the lesson plans used in the delivery of these program topics covering steam generator tube ruptures /
leaks and Abnormal Transient Operating Guidelines ("ATOG"), and the weekly examination grades for these topics. In short, the actual training materials and performance records on this sub-ject (as well as all other operaT.or training subjects) was pro-vided to UCS during the reopened proceeding. If UCS were seri-ous about its allegation, all of this information could have been the subject of litigation. The fact is that UCS now, as before, chooses to ignore this extensive record.
Turning to the substance of UCS' position, UCS' concerns regarding operator training fall into the following three categories:
(1) In UCS' view the alleged complexity of the emergency procedures and their so-called reliance on improvisa-tion during an accident make it "unlikely" that any amount of training will be adequate:
1
a (2) Because only.one of the four operators questioned knew from memory the correct offsite dose rates at which a steam generator with a tube rupture should be isolated, this indicates to UCS a deficiency in the training program "far greater in scope than simply the adequacy of training for steam generator tube rupture accidents"; and (3) In UCS' view, none of the four operators could ade-quately explain how they could determine whether the leakage through the steam generator tubes was greater or less than 50 gallons per minute.
Emergency Procedure Complexity. The ATOG procedures for
.TMI-1 were developed by GPU Nuclear personnel representing the operations and Training Departments and the Technical Functions Division. .The incorporation of these procedures into the pro-cedural structure at TMI-1 occurred only after the procedures had been evaluated on the B&W simulator by Operations and Tech-nical Functions personnel. See, e.g., Newton et al., ff. Tr.
32,409, at 33-34, as modified at Tr. 32,407-08 (Newton). The procedural training emphasized the following areas:
(i) technical bases for abnormal transient procedures (ATPs);
(ii) immediate actions and reasons for each; (iii) recognition of symptoms; (iv) entry and exit points for procedures; and (v) prioritization of actions. (Ref. 20.) The emphasis of the ATOG procedures on the recognition of symptoms and the use of the symptoms,.rather than events, to enter the procedures, has simplified.the process required by the operator to combat tran-sients. By analyzing the plant conditions and categorizing the symptoms the operator can readily determine what procedure to use.
Furthermore, TMI-1 procedures on steam generator tube rup-ture accidents do not rely upon improvisation. With respect to TDR-406, Rev. 3., a GPU Nuclear technical data report referred to by UCS, the additional steaming and isolation criteria for reduction of radiological releases contained in an appendix to TDR-406 have been incorporated, at the request of the Common-wealth of Pennsylvania, as an attachment to the OTSG Tube Leak /
Rupture procedure, ATP.1210-5. This was preceded by extensive discussions with the Commonwealth concerning the adequacy of the procedures to protect the public health and safety. These are titled " Steam Generator Isolation Considerations for the
[ Emergency Director] with concurrence by the [ Emergency Support Director]." These criter'ia are provided for information pur-poses only; they are'not part of the procedure relied on by the operators, nor do any steps in ATP 1210-5 refer the operator to these criteria. Rather they were added as technical.informa-tion, particularly for the benefit of emergency managers. UCS' interpretation, that these criteria overrule the procedural guidelines, is incorrect.
9
6 Steam Generator Isolation Criteria. Of the four operators given written exams by UCS, three individuals were reactor op-erators and one was a senior reactor operator. The decision to isolate a steam generator during a tube rupture incident is the responsibility of the SRO emergency director. The control room operator does not make this decision; he therefore is not re-sponsible for knowing these criteria. The SRO who was examined by UCS answered this question correctly, as expected. Thus, the UCS-perceived deficiency in the training program is based on UCS' own misunderstanding of SRO and RO requirements.
Additionally, the action for isolation of the steam gener-ator is a follow-up action in the procedure. Consequently, memorization of these steps is not necessary, as it is with re-spect to immediate actions. The SRO can and would reference the procedure during the incident. Thus, UCS' expectation, even with respect to the SRO, is inappropriate.
l Finally, UCS presents no evidence to support its allega-tion that this perceived recent deficiency in the training pro-gram is "far greater in scope than simply the adequacy of training for steam generator tube rupture accidents." UCS presents no facts to support this allegation, nor do any exist.
For example, the licensed operator initial and requalification training programs recently were accredited by the Institute of Nuclear Power Operations, a process endorsed by the Commission in its recent policy statement on training. In its most recent SALP Report, the NRC Staff also has made very favorable fit.d-ings with respect to training at TMI generally, and training in ATOG, in particular. (Ref. 21.) Finally, the Licensing Board has essentially approved GPU Nuclear's program on the basis of a substantial evidentiary record. See Licensing Board Response to CLI-85-2, April 11, 1985.
Leak Rate Calculation. UCS' conclusion that the four de-posed operators did not know how to calculate steam generator tube leak rates is based on UCS' misinterpretation of the oper-ators' statements during the oral exam given by UCS. UCS did not ask the operators how to calculate tube leak rates. Each of the operators was asked the general question: "On the indi-cation you have available in the control room, do you think it is sufficient to be able to determine, for example whether the leak rate is 49 gallons per minute as opposed to 51 gallons per minute." The question itself poses a concern as to whether the interviewer -- Mr. Pollard of UCS -- appreciates conspicuous evidence of the condition of the plant with a 50 gpm leakrate.
Moreover, the distinction between a 49 and 51 gpm leak rate is not one upon which operators need focus. The proximity of a 50 gpm leakrate would most likely cause the SRO to take the con-servative action of dealing with tube rupture rather than a tube leak. UCS requested no details of the operators on how to calculate leak rate or what calculation methods are available.
b.
In response to the ambiguous question, all operators gave an-swers which summarized information available in the control room, as should be expected when asked about control room indi-cations. Three of the four operators (including the SRO) cor-rectly identified the data needed to discern leak rate from the RCS. Thus, it is unreasonable for UCS to use the operators' answers as a basis for challenging operators' use of steam gen-erator leak rate information in implementing ATOG procedures.
Finally, as suggested by several of the deposed operators, the occurrence of a 50 gpm leak rate would be easily detected
-- a comparison of makeup and letdown flows and system volume changes would be made, and could later be verified using com-puterized leak rate calculations. In addition, secondary plant radiation readings could be used to calculate leak rates and verify initial findings. However, it is the SRO in charge of the plant who uses the 50 gpm threshold to determine whether or not to enter the tube rupture section of the procedure and whether or not to permissibly violate fuel in compression lim-its. This is not a decision made by an RO.
In summary, UCS' challenge to the adequacy of the TMI-1 operator training program, particularly the steam generator tube leak / rupture emergency procedures, is wholly inappropri-ate.. The Commission has provided an opportunity to UCS -- and
, UCS has availed itself of this opportunity -- to challenge GPU Nuclear's training program. UCS' arguments on ATOG training therefore should be summarily rejected by the Commission.
Moreover, UCS' arguments about steam generator tube rupture training are faulty.
References
- 1. NUREG-0103, " Standard Tech. Specs. for Babcock and Wilcox Pressurized Water Reactors".
- 2. NUREG-0452, " Standard Tech. Specs. for Westinghouse Pressurized Water Reactors".
- 3. NUREG-0523, " Summary of Operating Experience with Recirculating Steam Generators".
- 4. NUREG-0571, " Summary of Tube Integrity Operating Experience".
- 5. NUREG-0886, " Steam Generator Tube Experience".
- 6. NUREG-1019, " Safety Evaluation Report Related to Steam Generator Tube Repair and Return to Operation."
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l
- 9. Response to Interrogatory 94, NRC Staff's Answer to TMIA's First Set of Interrogatories and Request for Production of Documents, January 30, 1984 (TMI-1 l
Steam Generator Repair).
- 10. GPUN TDR 406, " Steam Generator Tube Rupture Guidelines," Rev. 3.
- 11. Response to Interrogatory 93, NRC Staff's Answer to TMIA's First Set of Interrogatories and Request for Production of Documents, January 30, 1984 (TMI-1 Steam Generator Repair).
- 12. GPUN Letter 5211-83-017, H.D. Hukill to J.F. Stolz, "RCP Trip on 25* Subcooling Margin," March 31, 1983.
- 13. GPUN Letter 5211-83-250, H.D. Hukill to J.F. Stolz, "25*F Subcooling Margin," September 7, 1983.
- 14. Memorandum for Parties to TMI-1 Restart Proceeding from Samuel J. Chilk, Secretary of the Commission, July 27, 1984, "NRC Staff's Safety Evaluation of Subcooling Criteria for Actuating or Throttling High Pressure Injection (SECY-84-237)."
- 15. GPUN Letter 5211-84-2221, H.D. Hukill to J.F. Stolz, "Subcooling Margin Monitor (SMM)," August 31, 1984.
- 16. NRC Memorandum, William J. Dircks to the Commissioners, "Three Mile Island Unit 1 Subcooling Criteria for Throttling er Actuating High Pressure Injection," August 30, 1984.
- 17. GPUN Letter 5211-85-2001, H.D. Hukill to'J.F. Stolz,
" Error Analysis--Subcooling Margin Indication,"
January 16, 1985.
- 18. GPUN Letter 5211-85-2045, H.K. Hukill to J.F. Stolz, "Subcooling Margin Indication," April 9, 1985.
- 19. Response to Interrogatory 92, NRC Staff's Answer to TMIA's First Set of Interrogatories and Request for Production of Documents, January 30, 1984 (TMI-1 Steam Generator Repair).
- 20. GPUN Letter 5211-84-2015, H. D. Hukill to John F.
Stolz, " Abnormal Transient Operating Guidelines (ATOG) Implementation (NUREG-0737, I.C.1),"
January 26, 1984.
- 21. NRC letter, Thomas E. Murley to H.D. Eukill, April 2, 1985, attached Systematic Assessment of Licensee Performance, Inspection Report 50-289/
85-99, at 7, 9.
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SERVICE LIST
! Nunzio J. Palladino, Chairman Administrative Judge 1
, U.S. Nuclear Regulatory Commission Gustave A. Linenberger, Jr.
- Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Thomas M. Roberts, Commissioner Washington, D.C. 20555 i
- U.S. Nuclear Regulatory Commission .
l l Washington, D.C. 20555 Administrative Judge !
, Gary J. Edles l j James K. Asselstine, Commissioner Chairman, Atomic Safety and 4
U.S. Nuclear Regulatory Commission Licensing Appeal Board i Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 John H. Buck Atomic Safety and Licensing Lando W. Zeck, Jr., Commissioner Appeal Board
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Ivan W. Smith Christine N. Kohl Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Appeal Board U.S. Nuclear. Regulatory Commission U.S. Nuclear Regulatory Commission 1
Washington, D.C. 20555 Washington, D.C. 20555
- Administrative Judge Docketing and Service Section (3)
Sheldon J. Wolfe Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Mr. Henry D. Hukill Board Panel Vice President
. U.S. Nuclear Regulatory Commission GPU Nuclear Corporation
! Washington, D.C. 20555 P. O. Box 480 Middletown, PA. 17057 Atomic Safety and Licensing Appeal Board Panel Mr. and Mrs. Norman Aamodt 1 U.S. Nuclear Regulatory Commission 200 North Church Street
- Washington, D.C. 20555 Parkesburg, PA. 19365 1
(! Jack R. Goldberg, Esquire Mrs. Louise Bradford
' Office of Executive Legal Director TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street i Washington, D.C. 20555 Harrisburg, PA. 17102 i
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SERVICE LIST Page 2 Thomas Y. Au, Esquire Joanne Doroshow, Esquire Office of Chief Counsel The'Christic Institute Department of Environmental 1324 North Capitol Street Resources Washington, D.C. 20002 505 Executive House P. O. Box 2357 Lynne Bernabei,' Esquire Harrisburg, PA. 17120 Government Accountability Project Michael F. McBride, Esquire 1555 Connecticut Avenue LeBoeuf, Lamb, Leiby & MacRae Washington, D.C. 20036 1333 New Hampshire Avenue, N.W.
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