ML20004B450

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Joint Proposed Reply Procedural Findings by Usc & Sc Sholly. Certificate of Svc Encl
ML20004B450
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/18/1981
From: Sholly S, Weiss E
AFFILIATION NOT ASSIGNED, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:
Atomic Safety and Licensing Board Panel
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NUDOCS 8105280256
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UCS--SHOLLY, 5/18/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BCARD In the Matter of )

)

METROPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289

) (RESTART)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

UNION OF CONCERNED SCIENTISTS AND STEVEN.C. SHOLLY JOINT PROPOSED REPLY PROCEDURAL FINDINGS

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i llyn7. Weiss . Esquire Counsel for UCS l-

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INTRODUCTION AND BACKGROUND A. Commission Hearing Orders I

1. Metropolitan Edison Company (Licensee or Met Ed) is the holder of Facility Operating License No. DPR-50 which authorized the operation of the nuclear power reactor r

known as Three Mile Island Nuclear Station, Unit No. 2. (the facility or TMI-!.), at steady state power levels not in excess of 2535 megawatts thermal (rated power). The facility is a Babcock and Wilcox (B&W) designed pressurized water reactor (PWR) located at the Licensee's site ten miles southeast of Harrisburg, Pennsylvania.

2. The Licensee is also the holder of Facility Operating License No. DPR-73, which had authorized the operation of the Three Mile Island Nuclear Station, Unit No. 2 (TMI-2) at power levels up to-2772 megawatts thermal. TMI-2 is located at the same site as TMI-1, and is also a B&W designed PWR.
3. On March 28, 1979, TMI-2 experienced a severe feedwater transient that led to a series of events culminating in a partially mitigated loss-of-coolant accident (LOCA) with l

significant core damage. At the time of the accident, TMI-l j was in a power ascension mode after completing a refueling l

l- outage and was immediately shut down by the Licensee. At the i

( request of the NRC Project Manager, Licensee verbally committed j

l on March 28, 1979, to give the NRC "significant advance notice" I

j prior to taking TMI-l out of cold shutdown. This verbal I

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4 commitment was later confirmed in a letter to the NRC dated April 16, 1979. [ copy attached for reference]

4. On June 11, 1979, the NRC Staff and the Licensee
  1. met to discuss open items and proposed changes for TMI-l prior to restart. At this meeting, the Licensee indicated i that the facility would be ready for restart by about August 15, 1979. The NRC Staff made no commitments regarding any aspect of TMI-l restart, noting that the basis upon which restart would be permitted had not been established. [ copy

.of meeting summary and list of attendees attached for reference]

5. On June 28, 1979, the Licensee proposed a schedule of modifications and actions which would have led to a restart of TMI-l on about September 1,.1979, and requested NRC Staff approval of this schedule. The Licensee committed to make certain modificationc to the plant and take certain other actions prior to restart, and also committed to seek NRC Staff approval prior to restart of TMI-1. (copy of June 28, 1979, letter from Mr. Herbein to Mr. Denton attached for 1

reference]

6. On July 2, 1979, the Commission issued an Order directing the TMI-l be maintained in a shut down condition pending further order of the Commission. The Commission based this action on its conclusion that, "In view of the variety of issues raised by the accident at the Three Mile Island Unit No. 2 facility, the Commission presently lacks

the requisite reasonable assurance that the same licensee's Three Mile Island Unit No. 1 facility, a nuclear power reactor of similar design, can be operated without endangering the health and safety of the public." The Commission further determined that it was in the public interest that a hearing precede the restart of TMI-1.

7. In its Order and Notice of Hearing dated August 9, 1979, Metrocolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1) , CLI-79-8, 10 N.R.C. 141 (1979), the Commi.ssion specified the basis for its concerns about the operation of TMI-l and set forth the procedures to govern further proceedings which would determine "whether any further operation will be permitted and, if so, under what conditions."

In that Order, the Commission appointed this Atomic Safety and Licensing Board to rule on petitions to intervene and conduct the public hearing on the restart of TMI-1.

8. The A1 gust 9, 1979, Order noted that the NRC Staff's evaluation of the TMI-2 accident (both TMI units use a B&W-designed PWR) led the Staff to conclude "that B&W designed reactors appear to be unusually sensitive to certain off-normal transient conditions originacing in the secondary system."

10 N.R.C. 141 at 140. Because of certain design features, the Order noted that the Staff had concluded that B&W-designed reactors

" place more reoiance on the reliability and performance characteri2 tics of the auxiliary feedwater system, the integrated control system, and the emergency core cooling system (ECCS)

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1 performance to recover from frequent anticipated transients, such as loss of offsite power and loss of normal feedwater, than do other PWR designs. " The Order stated that the Staff concluded further that this, in turn, " places a large burden on the plant operators in the event of off-normal system behc.vior during such anticipated transients " 10 N . R. C . 141 at 143.

9. The August 9th order explained that after a preliminary review of the TMI-2 accident chronology, the NRC Staff had initially identified several human errors that occurred during the accident, contributing significantly to its severity. The NRC Staff began an immediate reevaluation of the design features of B&W reactors to determine if additional safety improvements were nccessary. As a result of the evaluation, all holders of operating licenses except Met Ed were instructed to take a number of immediate actions to avoid a repetition of-errors, in accordance with bulletins issued by the Commission's Cffice of Inspection and Enforcement (IE). In addition, ESW owners were issued an IE Bullb'i; c instructing them to take certain actions concerning B&W's unusual sensitivity to certain off-normal transient conditions j originating in the secondary system. Besides the items identified for other B&W reactors, the NRC Staff identified j

additional safety concerns for TMI-1 to be resolved prior l

to restart.1 1 These concerns resulted from (1) potential interaction be-tween Unit 1 and the damaged Unit 2, (2) questions about the management capabilities and technical resources of Met Ed, including the impact of the Unit 2 accident on these, (3) the potential effect of operations necessary to decontaminate the Unit 2 facility on Unit 1, and (4) recognized deficiencies in emergency plans and station operating procedures. 10 N.R.C.

141 at 143-44.

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10. Based on the concerns raised by the TMI-2 accident, the Director of Nuclear Reactor Regulation recommended certain "short-term" actions be required of the Licensee. The Commission 2 The "short-term" actions:
1. The Licensee shall take the fo] lowing actions:

(a) Upgrade the timeliness and reliability of the Emergency Feedwater (EFW) system by performing the items specified in Enclosure 1 of the Licensee's June 28m 1979 letter. Changes in design will be submitted to the NRC Staff for review.

(b) Develop and implement operating procedures for initiating and controlling EFW independent of Integrated Control System (ICS) control.

(c) Install a hard-wired control grade reactor trip on loss of main feedwater and/or turbine trip.

(d) Complete analyses for potential small breaks and develop and implement operating instructions to define operator action.

(e) Augment the retraining of all Reactor Operators and Senior Reactor Operators assigned to the control room including training in the areas of l natural circulation and small break loss of ,

coolant accidents including revised procedures l and the TMI-2 accident. All operators will also receive training at the B&W simulator on the TMI-2 accident and the Licensee will conduct a 100 percent reexamination of all operators in these areas.

l NRC will administer complete examinations to all licensed personnel in accordance with 10 C.F.R.

S50.20-23.

2. The Licensee shall provide for NRC review and approval of all applicable actions specified in IE Bulletins79-05A, 79-05B, and 79-05C.
3. The Licensee shall improve his energency preparedness in accordance with the following:

(a) Upgrade emergency plans to satisfy Regulatory Guide 1.101 with special attention to action level criteria based on plant parameters.

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itself had additional concerns, which, although the Commission (continued)

(b) Establish an Emergency Operations Center for Federal, State and Local Officials and designate a location and an alternate location and provide communications to the plant.

(c) Upgrade offsite monitoring capability, including additional thermoluminescent dosimeters or equivalent.

(d) Assess the relationship of State / Local plans to the Licensee plans se as to assure the capability to take emergency actions.

(e) Conduct a test exercise of its emergency plan.

4. The Licensee shall demonstrate that decontamination and/or restoration operations at TMI-2 will not affect safe operations at TMI-1. The Licensee shall provide separation and/or isolation of TMI-1/2 radioactive liquid transfer lines, fuel handling areas, ven-tilation systems, and sampling lines. Effluent monitoring instruments shall have the capability of discriminating between effluents resulting from Unit 1 or Unit 2 operations.
5. The Licensee shall demonstrate that the waste manage--

ment capability, including storage and processing, l for solid, liquid, and gaseous wastes is adequate

! to assure safe operations of TMI-1, and that TMI-l -

waste handling capability is not relied on by op-erations at TMI-2.

! 6. The Licensee shall demonstrate his managerial capability l and resources to operate Unit 1 while maintaining Unit 2 in a safe configuration and carrying out planned decon-l tamination and/or restoration activities. Issues to be addressed omc;ide tje adequacy of groups providing safety review and operational advice, the management and technical capability and training of operations staff, the adequacy of the operational Quality Assurance program and the facility procedures, and the capability of important support organizations such as Healtn Physics and Plant Maintenance.

7. The Licensee shall demonstrate his financial qualifi-cations to the extent relevant to his ability to operate TMI-1 safely.

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believed need not be resolved prior to resumption of TMI-l operation, must be addressed in a timely manner. The Director of Nuclear Reactor Regulation recommended that certain "long-term" actions be required of the Licensee to resolve these concerns and permit a finding of reasonable assurance of the safety of long-term operation.3 (continued)

8. The Licensee shall comply with the Category A recommendations as specified in Table B-1 of NUREG-0578. (NUREG-0578 is the TMI-2 Lessons Learned Task Force Status Report] 10 N.R.C. 141 at 143-44.

3 The 'long-term" actions:

1. Submit a failure mode and effects analysis of the ICS to the NRC Staff as soon as practicable.
2. Give continued attention to transient analysis and procedures for management of small breaks by a formal program set up to assure timely action of these matters.

l 3. Comply with the Category B recommendations as -

! specified in Table B-1 of NUREG-0578.

l 4. Improve emergency preparedness in accordance with l

the following:

( (a) Modify emergency plans to address changing capabilities of plant instrumentation.

(b) Extend the capability to take appropriate emergency j actions for the population around tha site to a

distance of ten miles.

10 N.R.C. 141 at 145.

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11. In its August 9, 1979, Order the Commission set forth the subjects to be considered at the hearing:

(A) Whether the "short-term actions" recommended by the Director of Nuclear Reactor Regulation are necessary and sufficient to provide reasonable assurance that the TMI-l facility can be operated without endangering the health and safety of the public, and should be required before resumption of operation should be permitted.

(B) Whether the "long-term actions" recommended by the Director of Nuclear Reactor regulation are necessary and sufficient to provide reasonable assurance that the facility can be operated for the long term without endangering the health and safety of the public, and should be required of the Licensee as soon as pract.".cabic. 10 N.R.C. 141 at 148.

12. The Commission's August 9th Order further guided the Board:

If the Board determines that operation can be resumed upon completion of certain specific short-term actions by the Licensee, it shall consider the extent to which the Licensee has demonstrated reasonable progress toward completion of the long-term actions described in this section. If it finds that the Licensee has demonstrated reasonable progress, it shall

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recommend resumption of operation upon completion of the short-term actions. If it cannot make such a finding, it shall recommend that operation be resumed at a date that it believes appropriately e

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reflects-the importance of the action involved, the time lost because such progress had not been made on the prescribed schedule'and the overriding need to provide adequate protection for the public health and safety. 10 N.R.C. 141 at 149.

13. The Order further provided that the hearing before this Board should be conducted in accordance with the provisions of the Commission's Rules of Practice governing adjudicatory licensing proceedings set forth in 10 C.F.R. Part 2. 10 N.R.C.

141 at 147.

14. On March 6, 1980, the Commission issued anothdr Order, CLI-90-5, providing further guidance to the Board regarding the managment competance issues by specifying 13 specific issues which the Board should examine. These issues are individually discussed in the management capability section of this recommended decision.
15. On March 14, 1980, the Commission a further Order to make clear that it was intended by the Commission that any party to the proceeding might raise as an issue whether one or more safety concerns, not specifically listed as "short-term" in the Commission's August 9, 1979, Order should be satisfactorily resolved prior to startup, so long as they satisfy the requirements (e.g., specificity and basis) applicable to contentions generally and there is a reasonable nexus between the issue and the TMI-2 accident. The Board's rulings on contentions had from the outset followed this approach and continued to do so throughout the proceeding.

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16. Finally, on March 23, 1981, the Commission issued I

a further Order (CLI-81-3) which modified its August 9, 1979, 2 Order by removing from the scope of this proceeding the matter of the Licensee's financial qualifications.

B. Interventions and Appearances d

17. Many entities filed petitions to intervene in August and September of 1979. The Board admitted the following p'atitioners as intervenors in this proceeding:

Union of Concerned Scientists (UCS,,Three Mile Islant Alert, Inc. (TMIA;, Mr. Marvin I. Lewis, Ms. Marjorie Aamodt, Mr. Steven C. Sholly, Anti-Nuclear Grcup Representing York (ANGRY), Environmental Coalition on Nuclear Power (ECNP),

Chesapeake Energy Alliance (CEA), Newberry Township TMI Steering Committee (Newberry Petitioners). The Commonwealth of Pennsylvania, the Pennsylvania Public Utilities Commission, l

4 The Board ruled that Mr., Lewis had not shown standing in the proceeding and therefore dismissed most of Mr. Lewis' contentions. However, as a matter of discretion, the Board did allow Mr. Lewis to intervene solely with respect to his contention on the adequacy of the TMI-1 filter system for radioactive effluents -- a contention not advanced by any other intervenor.

5 Regarding ECNP, in May of 1980 the Licensee moved for sanctions against ECNP based on this intervenor's default on a Board Order compelling discovery. We declined to dismiss ECNP as a party but did dismiss many of its contentions.

Metropolitan Edison Company, (Three Mile Island Nuclear Station, l Unit 1) LPB-80-17, 11 N.R.C. 893 (1980).

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The New Jersey Board of Public Utilities, the Pennsylvania Consumer Advocate and Dauphin County were admitted as special participants under 10 C.F.R. 52.715(c). The Commonwealth of Pennsylvania participated actively and helpfully in all phases of the hearing and presented direct testimony of the Commonwealth's emergency plan. The Pennsylvania Public Utilities Commission and the Pennsylvania Consumer Advocate participated in only limited phases of the hearing. Dauphin County and the New Jersey Board of Public Utilities elected not to attend any of the evidentiary hearing.

18. We deferred ruling on People Against Nuclear ' Energy-(PANE) status as intervenors until the Commission determined whether psychological stress issues (the only issues sought to be litigated by PANE) could be considered. The Board certified this question to the Commission in Metropolitan. Edison Company ~

(Three Mile Island Nuclear Station, Unit 1), LEP-80-8, 11 i

N.R.C. 297 (1980), where we concluded the Commission within its discretion may and should consider psychological stress un3er NEPA for the purpose of mitigating community fears about f:he operation of TMI-1. The Commission in a Memorandum and Order, CLI-80-39 of December 5, 1980, was evenly divided on the question. A vote of 2-2 on this question conctituted an effective denial of requests to admit the psychological. stress issue. We were told to consider this a denial of these contentions and tha t "there is no authorization for the Board

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to admit psychological stress contentions." The Commission noted it would reconsider the question upon. confirmation of a fifth Commissioner.

19. The Eoard denied petitions to intervene by Ms. Jane Lee, Ms. Frieda Berryhill, representing the Coalition of Nuclear. Power Plant Postp'nement, o and Victaulic Company, et al, either for lack of standing or failure to advance an acceptable contention, ,or both.
20. The Board received more than 1,000 written limited '

appearance statements directed either to the Board or to one or more Commissioners, which we considered and directed to be' placed in the public record. In addition, the Board held special sessions to hear oral limited appearances on November 15, 16 and 17, 1979, and again on March 5, 1981. Subsequently the Board permitted additional limited appearances by ,

appointment in the course of scheduled hearings. Over 200 individuals availed themselves of the opportunity to make statements.  :

21. The record of the hearing includes the written and oral testimony of witnesses presented by Licensee, the NRC Staff, the Commonwealth of Pennsylvania, the Union of Concerned Scientists, TMIA, ANGRY, ECNP, and Mrs. Aamodt. '

In the findings of fact below, citations to the direct written testimony received into evidence refer only to the last name of the witness (es) and to the transcript page immediately preceding the prepared testimony. For the convenience of the Board and the parties, we have also compiled an

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alphabetical listing by witness, Appendix A to this decision, which fully identifies each piece of testimony sponsored by each witness an'd which identifies the location in the transcript of all of the written testimony.

22. The record also includes exhibits which were offered and received into evidence or rejected by the Board. Appendix B to this decision i s a list of exhibits which were marked for _

identification and identifies those exhibits received or rejected by the Board.

C. Rulinas on Contentions

23. The contentions which were allowed by the Board are enumerated later in this decision and are not repeated here.

Nor does the Board attempt to recite the disposition of each of the many contentions which were challenged by Licensee or the l

1 Staff and which were either disallowed or revised by the Board.

l We do recite, however, some of the main principles which guided the Board in its rulings on contentions.

a. Scope of the Proceeding. . .

The Board addressed i

the question of the scope of the proceeding in its First Special Prehearing Conference Order, dated December 18, 1979. The Board rejected the Licensee's position that only contentions related

to the bases for suspending TMI-l's operating authority, as recited in the Commission's August 9, 1979, order, should be allowed.

In rejecting this position, the Board ruled, inter alia, l that the charge of the Commission to consider the " sufficiency" of the recommended short- and long-term actions clearly drew the scope of the proceeding beyond the limits urged by the

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The Board also rejected the approach urged by some intervenors that any contention be allowed which would be allowable in an initial operating license proceeding.

The Board ruled.instead, in agreement with the position put forward by the NRC Staff and several other intervenors, i that it would admit any otherwise allowable contention having a reasonable nexus to the TMI-2 accident. This principle guided the Board both in ruling on the admissibility of contentions and in its subsequent rulings on the admissibility 4

of direct testimony, the scope of cross-examination, and in rulings on motions to compel discovery.

  • b.

Class 9 accidents. The Union of Concerned Scientists proposed a contention alleging that the Staff's methodology for determining which among the realm of possible accident sequences are "credible " for the purposes of ~

determining the plant's-design basis, is fundamentally faulty (UCS Contention 13).

The contention was admitted by the Board subject to further specification, with the caveat '

that the showing of the Licensee and the Staff would depend upon the specificity provided by UCS. The Board noted in its First S pecial Prehearing Conference Order (December 19, 1979) that: "

1 (r)egardless of the final specificity of this contention, the Board itself expects the Staff to provide evidence addressing the general method by which the Staff has determined whether accidents within the scope of this proceeding fall within or outside the design basis." Other e* ,

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parties were permitted to adopt UCS Contention 13 .

Steven C. Sholly also filed a contention 'on Class 9 accidents, specifying several accident scenarios based on the TMI 2 accident. -

This contention was subsequently withdrawn by the intervenor.

UCS subsequently filed a timely motion for Summary Disposition with respect to UCS Cont ention 13, demonstrating, inter alia, that the NRC Staff had conceded under oath that it has not and cannot determine e probabilityth of any particular accident sequence.

UCS argued that it was entitled to judgment as a matter of law since its motion demonstrated that the Staff's methodology f or identifying'

" credible" accidents had no rational basis .

The Staff filed no response to the UCS motion.

The motion was denied by the Board not as a judgment on its merits but b ecause the Board considered the issue so important as to call for it on the evidentiary record s treatment i

(Tr. 2229-31). The Board accepted

\ the facts and arguments stated in the moti on as providing sufficient specificity to permit litigation of the contentio'n ,

while noting again that the nature of the Licensee's and Staff's

_ responses would of necessity be framed in response to the generality of the contention 22G8-12, and 2221). (Tr. 2337; See also Tr. 2198-9, During the hearing, Board that, UC3 informed the' '

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due to a lack of resources compounded by the length of the proceeding, i

it would be unable to participate directly in the litigation of UCS Contenti6n 13.

However, consistent with its earlier rulings, the Board required the Staff to come forward with avidenceson it methodology for

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classifying accidents as credible or incredible .

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c.

Basis and Soecificity.

The Board applied traditional tests in ruling on the based on basis and specificity admissibility of contentions admitted A number of contentions were on a conditional basis for the purpose of proceeding with discovery, with the di scovery process providing the means by which the contentions further specified. would be Contentions accepted on this basis were accepted with the caveat that they be further specified soon after the close of discovery .

In some instances, particularly in the case of ECNP and CEA ,

the Board subsequently dismissed contentions whe re the intervenor failed to respond to interrogato i bases and specifics of contentions n a dr es inquiring into the defaulted on Board Orders compelli where intervenors d.

ng them to respo'nd.

Withdrawn Contentions. During the course of the hearings a number of intervenors ,

withdrew contentions, citing a variety of reasons including to pursue the contentions and the f a lack of resources .

there were multiple contentions c act that on some issues It was the Board's practice to reviovering similar issues.

by intervenors to assess the import ew contentions dropped ance of the issues raised by the contentions and to ascert i raised by the contention were adequat l a n whether the issues e y covered by the contentions of other intervenors .

where the Board determined that the rIn a number of instances, inadequate or imco mplete, ecord would be otherwise the Board adopted contentions as e- #

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i Board questions and required the Licensee and the Staff to address the withdrawn contention in testimony. In some instances, the Board also permitted intervenors to adopt contentions which had been withdrawn by another intervenor.

24. In addition to rulings in accordance with the foregoing general principles, the Board made a number of special rulings on specific contentions which ara discussed later in this decision in connection with the specific contentions.
25. The Board and the parties accepted Licensee's 1

proposal to group contentions into the following major categories:

a. Plant design and procedures.
b. Separation of TMI-l and TMI-2.
c. Management qualifications of the Licensee.
d. Emergency Planning.

This grouping and sequence of contentions was followed generally in the presentation of evidence at the hearing, although a '

l number of pieces of supplemental testimony were generated i

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as a result of Board questions or intervenor cross-examination and were fitted into the proceeding as preparation time and hearing time permitted. A fifth category of contentions, -

those dealing with financial qualifications, was eliminated from the hearing as a result of the Commission's Order of March 23, 1981.

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26.

The Commission's August 9, 1979, Order instructed the Board to consolidate participstion c . parties pursuant 10 C.F.R. 52.715a to the maximum extent c pra ti cable consistent with the provisions of that regulation .

Tne intervenors in general objected to consolidatica

, but agreed to voluntarily consolidate and present joint cases and cond examination. uct joint cross-None of the parties favored involuntary consol-idation by Board Order.

The Board adopted the intervenor proposal and required the intervenors to desi gnate a lead intervenor for the presentation of eviden ce and the conduct of cross-examination on issues where re multipic, there we similar contentions.

This practice, in general, worked satisfactorily.

D.

Miscellaneous Rulings _

27. In the period between the August 9 ,

1979 Crder and commencement of the evidentiary hearing o n October 15, 1980, -

. the Board was called upon frequently not only t differences as o resolve to the allowability of contentions bu t to rule on discovery disputes, prehearing and h earing schedules and a wide variety of other procedural ma tt ers.

Prehearing con-ference orders dealing with these matt '

, ers were issued on December 18, 1980, January 11, 1980, January 25 29, 1980 and May 22, 1980.

1980, February The final prehearing conference was n - - - , , - , , - , , - , -,--u -p , ,

held on August 12 and 13, 1980 in Harrisburg p9rsuant to 10 C.F.R. S'2.752, and the final prehearing conference' order 'was issued August 20, 1980. In addition, the Board _ issued a-large number of rulings on motions and requestsJsubmitted in separate filings. The total number of prehearing documents filed with or issued by the Board, exclusive of prefiled testimony,'was well over 1,000.

29. The issuance of the Staff's safety evaluation report proved in this proceeding as in others to be a critical path item. Without attempting to assign blame or responsibility as between Licensee (who provided information required by the Staff to complete its evaluation) and the Staff (which generated detailed criteria for the short-term and long-term actionc specified in the Commission's August 9, 1979 Order and reviewed materials submitted by Licensee), delay in the issuance of the safety evaluation report largely accounted for -

the delay in the commencment of the evidentiary hearing _as '

compared to the target schedule attached to the Commission'.

l August 9, 1979 Order. This delay enabled the Board to extend the discovery periods contemplated in the August 9, 1979 Order

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without delaying the commencement of the hearing. The Board-l' also afforded intervenors an opportunity for supplemental l discovery following the issuance of the safety evaluation.

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report and major supplements and following several revisions s

i made by Licensee in its emergency plans in the course of the proceeding.

30. Some intervenors requested financial assistance from the Commission to support litigation of their cententiens.-

These requests were initially denied by the Board as outside the scope of its authority. On May 16, 1980, the Commission announced that it generally favored intervenor funding as a matter of policy, but it nevertheless denied a request to provide financial assistance to intervenors in this proceeding in light of Congressional disapproval of the use of appropriated funds for such purposes in Fiscal Year 1980. Metropolitan ,

Edison Company (Three Mile Island Nuclear Station, Unit No. 1) ,

CLI-80-19, 11 N.R.C. 700 (1980). On the same day, in response .

to a certification to the Commission from this Board, the Commission announced it would not provide financial assistance to intervenors in this proceeding to address the psychological stress issue. Metropolitan Edison Company (Three Mile Island l '

l I Nuclear Station, Unit No. 1) , CLI-80-20, 11 N.R.C. 705 (1980).

In another certification to the Commission dated August 8, 1980, the Board requested the Commission to extend its rule governing procedural assistance in adjudicatory licensing proceedings to this restart proceeding so as to allow the Board to l

! consider intervenor requests for free transcripts. Metropolitan

( Edison Company (Three Mile Island Nuclear Station, Unit No. 1),

LBP-80-23, 12 N.R.C. 227 (1980). As explained in its certifi-l

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cation, the board viewed such assistance is an important contribution to the efficiency of the hearing process. In a Memorandum and Order dated August 15, 1980, the Commission granted the Board authority to extend the prosrisions of the procedural assistance rule to the parties in this proceeding.

In a Memorandum dated December 4, 1980, however, the Chairman of the Commission cited a letter (dated December 3,1980) by the Comptroller General of the United States that the NRC

procedural assistance program may not lawfully use any Fiscal Year 1981 appropriation funds. The Commission directed the Board and the Staff to immediately cease such assistance.'
31. In response to numerous new documents, intervenors posed new contentions or revised existing contentions. The Board in general required such revisions to be submitted as.

l l

soon as possible, but in any case no later than 30 days following the issuance of the documents. The Board notes that as a result of the investigations into the TMI-2 accident and related ,

matters, there were issued during the course of this proceeding dozens of major reports which were related in varying degrees to the issues in this proceeding. . Among the reports issued during the course of this hearing have been, inter alia: .

a. The Report of the President's Commission on the Accident at Three Mile Island, together with numerous Technical Staff Reports.

l l

b. The Report of the NRC's Special Inquiry Group (the so-called "Rogovin" investigation).
c. The t o reports of the.TMI-2 Lessons Learned

! Task Force (NUREG-0578 and NUREG-0585).

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d. Generic Evaluation of Small Break Loss-of-Coolant Accident Behavior in Babcock & Wilcox Designed 177-FA Operating Plants (NUREG-0565).
e. Transient Response of Babcock & Wilcox Designed Reactors (NUREG-0667),
f. Major investigatio..s by the Commission's Office of Inspection and Enforcement (including NUREG-0600 and NUREG-0760).

In addition, revisions to Commission rules and regulations had a similar impact on intervenor contentiens, particularly in the area of emergency planning, where the Commission published two revisions of NUREG-0654 and a set of major revisions to the Commission's emergency planning regulations on August 19, 1980. ,

Such changes mandated a diligent effort on the part of all parties to keep abreast of changing circumstances throughout the proceeding, and also contributed, in some measure, to the delay in the proceeding compared to the suggested schedule set forth in the Commission's August 9, 1979, Order.

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.g r Metropolitan Edison Company g, q ' f ,;

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['- Post Office Box 480 Middletown, Pennsylvania 17057 717 944-4041 April 16,1979

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Office of t'uclear Rtactor Regulation 3 k Attn: Mr. Harold R. Centon, Director

  • U.S. Nuclear Regulatory Comission <b M Washington, DC 20555 , bi y, . h4 .

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Three Mile Island Nuclear Station Pnit I (TMI-1) .

Operating Licensrfro7~0Pb 5 s Docket N . 50-289 This is to confirm the comitment which we u orally on Thursday, March 28, at tne recuest of your project manager for Three Mile Island Unit 1 that

.4etresolitan Edison would provide significant advance notice to NRC prior to taking Uni' 1 out of its present cold shutdown condition. We do not plan any such rcve until we have evaluated the course of events at Unit 2 and any signi-fican; irr.olications they may have to the operation of Unit 1.

Sincerely, I \

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I . G. Herbein Vice President-Generation JGM: L',01: djh 3 cc: D. C. Dilanni pu PE O f \g 7905020214

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g Jf., s, NUCLEAR P.EOULATORY COMMISSION E _"j,','[ff, j .*: 3 i WASHINGTON. D. C. 20555

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'%m." <- ' f June 7, 1979 Co:ket No.: 50-289 . .

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HEM 0PMDUM FOR: Robert W. Reid, Chief, Operating Reactors Branch #4,.~00R : ~

FROM: D. Dilanni, Project Manager, ORBf4, D0R . . .

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SUBJECT:

FORTHCOMIt'G MEETING WITH METROPOLITAN EDISON COMPA!1I THREE MILE ISLAND, UNIT NO.1 (TMI-1) . . .

TIME & DATE: 10:30 a.m., Monday -

/,'.

June 11, 1979 ,- c: .

LOCATIO!i: P-500 Bethesda, Maryland RURPOSE: To discuss prerequisite open items '

for TMI-1 startup resulting from the .

TMI-2 event. .

PA?.TICIPANTS: NRC V. Stello, R. Vollmer, D. Ross .

R. Mattson, B. Grimes, R. Reid -

D. Dilanni, L. Chandler .

i ISE, REGION I I!

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Representatives  :

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l E. Wallace,' R. Arnold, D. Slear, R. Heward, R. Wilson l

MET ED l

j J. G. Herbein, J. Seelinger, L. Tsaggeris ,

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/[!: k' ominic Dilanni, Project Manager -

l Operating Reactors Branch !4 .

Division of Operating Reactors.

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gE NUCLEAR REGULATORY COMMISS!ON WASHINGTo!.* 0. c. 20555 g

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3 June 28, 1979

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Docket No. 50-289 /  % -

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, ciu .. se_ u LICENSEE: METROPOLITANEDISONC0hlPAtlY (Met Ed/GPUSC)

FACILITY: THREE MILE ISLAND UNIT NO. 1 (TMI-1)

SUBJECT:

MEETING

SUMMARY

ON THE JPEN ITEMS REGAR0IflG TMI-l RESTART On June 11, 1979 the TMI-l licensee et with the NRC staff to discuss open items and proposed changes for restart of TMI-1. g A list of attendees is enclosed.

The subject matter presented by the licensee is as follows: -

'(a) Retraining Program -; . ,.

i .-

(b) Procedure Changes (c) Plant Modifications P- .

(d) Emergency Plan ,

(e) Safet/ f aalysis & Stud'es .

A summary of these items is as follows and further details on the presentation

, concerning these topics are attached.

~

4. .

Retraining Procram The licensee committed to retraining aoproximately 40 reactor operators needed to cover the coerating shifts. Furthennore, the licensee committed to have a degreed engineer present during plant operation to assist the shift supervisor.

As cart of the retrainino programs ~, the operator.s will be taking college level technical courses in fluid flow, heat transfer and Ther.todynamics. The staff indicated the cualification of the instructors for these courses should be addressed. The licensee was also advised to contact the NRC Operating Licensing Branch regarding the content of the technical courses for de operators. A criterion fnr retraining ocerators .should be developed and be made part of the restart recort. The crocosad schedule for retraining shows the NRC examination oa0E0f 7 908150t7 e

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eriod starts Augrst 10, 1979 and to last for one week. NRC will considor

-his recuest with r esoect to other commitments for this period.

Procecures A total of 80 to 100 procedures are scheduled for review and revisfort as necessary to meet the critieria presented in the enclosure (Procedure Changes).

The procedure review is being completed at an approximate rate.of 3 per day and the licenses plans that the precedure reviews will' be csnpleted by the end of July 1979. The staff indicated that some of the crocedures will be reviewed by the NRC staff and that the training schedule should reflect possible changes to the procedures as a result of the NRC review.

Modifications The licensee proposad plant modifications some of which were comnitted to be c:mcietec prior to reactor restart and the remaining modifications to be c:moletec as soon as practicable (See Enclosure s ).

ine iicansee committed to study the feasibility of installing reactor vessel

( level indication as well as remote (from outside containment) reactor vessel The licensee also comnitted to resolvino the problem of containment gien-inc. ?resently the licensee has committed to a valve analysis instead of

urce.

limiting purging to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year. ,

Emercency Pla;n The licensee proposed to make changes to the emergency plan covering those items The existing emergency olan over which the licensee has direct control.

submitted to the staff appears to be inadequate as to the deoth of details existing in the plan. The licensee was requested to review Reg. Guide 1.101 in this regard. It was agreed that staff would discuss with the licensee the require-However, reapproval of the emergency plan would be. required cents in this area.

prior to restart.

iafety analvsis & Studies

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~The licensee dians to review certain of the existing safety analyses as outlined .

in Inclosure 8. This review is exoected to be completed prior to the restart of RiI-1. .

Staff C:mments & Future Plans It was agreed to have a meeting during the week of June 25th (actual date to be established) at the site to discuss the future efforts on the TMI-l restart.

Al-hougn an agenda was discussed it will be finalized before the meeting.

i

-as ncicated that it is likely tnat there will be a oublic The meetinq near question of the a

site we.are technical issues are discussed with the oublic. -

ublic 1 earing wil: be determined.

.ne nues:1on or EC-1/TMI-2 physical separation during all operating modes of The objective is that operating

ne T.vo units would need to be addressed.
ncitions of bc h units will not affect each otner due to croximity and/or
meona:ity of service facilities.

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f ccmplete response tof the bul~1etins ::ay not be necessary.. 'The staff' '

will give- ths. licenses guidanca as to thosa

  • specific items to be covered . . ' . . ,- - ' - C.

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,. ,in the bulletins..3 . .. .

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. . .. Conclusio.n .. . --

J The' licensee indicated that according.ta his schedule he wuld be ready ~

~1 for. restart about. August.15,1979.

a. - - .

- These discussions resulted in no agreecents or cc::: nit::'.ents by the staff" wuld - .'.

regartling any aspect of the TMI 1 restart.. The basis upon whichr THI-1c .

be allowed to restart, and the~asscciated schedule; have not yet been . , '

b.

estabi t shed. .

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. Originsi signed by,, .

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'. ' D..C. Dilanni, Pr'oject Manager

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- Operating. Reactors Branch.f4 ~5 Division of Operating Reactors' - "

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Enclosures:

' . s .

l.. List of. Attendees '

- 2.. Agenda

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3. Retrair.# gran ~ .
i. Pmced ,.2nges
5. Control redificaticns' Studies Required Prior to Restart - ~. .
6. -

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7. energency p3an
8. , Safety Analysis .

. cc w/ enclosures: See attached list . .

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TMI-1 Restart Meeting P00R ORIGINAL Enclosure 1 June 11, 1479 Attendees

' lace Orcanization NRC D. C. Di! anni Harley Silver R. H. Vollmer H. R. Genton Darrell Eisenhut srien Grimes 30s Capra 3ob Reid T. M. Novak Lawrence Chandler b G. R. Klinger H. 3. Xister John R. Sears .

?e:er Tam .

H. Diec~< amp GPU R. C. Arnold R. W. Heward, Jr.

I. G. Wallace D. S. 51 ear R. .:. Wilson MET ED J. 3. Herbein J. L. Seelinger A. Tsaggaris SHAW, PITTMAN George .:. Trow'o ridge

b. (Counsel) .

FA DER W. ?. Cornsife O

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. j., Metropolitan Edison Company

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.-4 e I' f J Post Office Box 542 Reading Pennsylvania 19640 215 929 3601

- writer's 0. rect Dias Number

. June 28, 1979 -

Mr. Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 [

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Dear Sir:

\

T Three Mile Island Nuclea St OperatingLicensebo.ation, DPRISOUnit 1 Docket No. ' ~0-289 Y

By letter dated April 16, 1979 (GQL 0576), .itted to providing .

-l 5-tit >Jffcant . advance notice prior to taking TMI-l out of cold shutdown.

We haveiTe~iitified a number of modifications / actions to be completed prior to the THI-l restart. We expect to be e.ble to complete these changes en or about September 1, 1979 and it is our hope that we would ,

be able to receive the necessary approvals from the NRC to support that schedule. However, the reactor will not be restarted until, items 1(a) through 1(h) below are completed and we have received your approval.

1, Modi)1 cations /ActionstobecompletedpriortoTMI-1Startup (short-term):

(a) Upgrade of the timeliness and the reliability of the Auxiliary Feedwater System as described in Enclosure 1. Changes in the de-ign will be st':mitted to the NRC for review.

(b) Develop and implement operating procedures for initiating and controlling the Auxiliary Feedwater System independent of the

[~ . , .

ICS control.

sc) Install a hard-wired control-grade reactor trip on loss of main feedwater and/or turbine trip. .

(d) Develop and implement procedures and instructions to define i operator actions for small break loss of coolant accidents.

Review recent B&W analyses of small break loss of coolant

- accidents and confirm their applicability to TMI-1.

(e) Augmented retraining of all Reactor Operaters and Senior Raactor Operators assigned to the control room will be conducted including training in the areas of natural circulation, small break loss of coolant accidents and the TdI-2 accident. All operators will'also receive training at the B&W simulator on the TMI-7 accident.

Met-Ed will conduct 100% repxamination of all operators. .

% F6 6 e 7 9 0 7 0 5 0 3'ict f.j/odl SIl r.>e recenan sesen commyis a r.sm:er:::. e ca.m anue : u s,ste, p

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Mr. Harold Danton .

P00RORIG1MR (f) Cc=plete those additional items in Enclosurs 3 designated as short ter=.

(g) Upgrade station emergency response capability as described ,

in Ericlosure 2.

(h) A degreed " shift" engineer will be on site at all times during plant operation to provide additional support and advise shift operating personnel.

In addition to the above short term improvements, Met-Ed requests the NRC to rece.mify the I'.C-1 operaters. Further, Met-Ed will accomplish the below listed long term items on an expedited basis:

2. Modificatiens/Acticas to be completed en an expedited basis but not necessarily before startup of TMI-1 (long tem):
( (a) Provide, as soon as practicable, a failure mode and effects analysis of the ICS. (This task is underway with high priority

_ at 3 5 W).

(b) The hard-wired trips referenced above under item 1(c) will be' upgraded to safety grade insofar as practicable.

In addition to the above shor ters and long term items, Enclosure 3 also prov: des a list of additional items which Met-Ed intends to accomplish.

These items, we believe, will further enhance the capability and reliability of the reactor to respond to various transient events.

Sincerely, ,

O ,

!~b ' %bt'k J. G. Herbein l

JGH:1,WH:tas -

/ Vice President-Generation i

l Enc'.osures ,

I cc: Mr. R. W. Reid l Mr. D. C. Di! anni I

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ENCLOSURE 1 AUXILIARY FEEDUATER UPCRADING_

. -- . . s . - _. .

1. Automatic . initiation of the motor driven AFW pumT s upon loss of both feedwater pumps or loss of four (4) Reactor Coolant Pumps.
2. Modification of the AFW control valves such that they fail open on loss of air.
3. Automatic block loading of the motor driven AFW pumps on the diesel.
4. Incorporation of AFW in the TMI-I technical specifications as specified in IZ Bulletin 79-05A, item 8. Verification that technical specification
requirements of AFW capacity are in accordance with the accident analysis will be conducted.
5. Provide indication La the control room of AFW flow to each Steam Generator.
6. Provide procedures and training to assure that AFW is available and

-( properly applied when required. Procedures will identify the need to verify proper operation When AFW is initiated.

. 7. To assure that AFW will be aligned in a timely manner to inject on all AFW

. demand events When in the surveillance test mode, procedures will be implemented end training conducted to provide an operator at the necessary location in communications with the control room during the surveillance mode to carry out alignment changes necessary upon AFW demand events.

8. Design review and modifications, as necessary, will be conducted to provide control room annunciation for all auto start conditions of the AFW system. .
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~ -" P00R ORIGINAL E.'IRC D CT RESPONSE CAPA"ILITT UFCRADING the shift and emergency organization 1

Provide the capability to supplement personnel with a .'.et-Ed./GPU organization for off site energency support den called for by the Emergency Plan. In addicion, provide for a compre-

  • Lensive organization to coordinate lcng term accident recovery and pro-tective action.
2. Upgrade communications on site and off site in and to the TMI E=ergency Control Centers.

3 Provide additio:dr.1 e:ergency equipeent including respirators, Significantly dosimetry expand the devices, and conitoring/ analysis equipment.

radial and a==uthal distribution of TLD's as part of the routine radio-logical enviroc= ental monitoring program.

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. ENCLOSURE 3 OTHER MODIFICATIONS TO BE COMPLETED BEFORE STARTUP OR AS SOON AS PRACTICA3LE THERE.GTER 4

A. Before Startup (Short Term)

1. Reduce the high pressure reactor trip to 2300 psig.
2. Upgrade selected instruments and valve operators in containment by applying heat shrink tubing to electrical connections for water tigh tness.
3. Hookup 16 incore thermocouples to the plant co=puter with readout capability to 2300'F.
4. Revise containment isolation signals to isolate all lines which do not degrade core cooling upon initiation of HPI or other appropriate signal such as high radiation.

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]' 5. Revise valve position indications to show actual valve position versus damanded position on all appropriate valves.

. 6. I= prove plant computer printout and alarm capability.

7. Raise the PORV setpoint to 2450 psig.
8. Provide an unambiguous indication of PORY position.
9. Provide remote essential maintenance for the decay heat removal pumps to minimize post accident personnel radiation exposure and improve '

reliability.

10. Install a H rec 2 abiner with provis t.on to hookup a second one.

.11. Install the approved HPI cross connection to eliminata tha need for

-( prompt operator action af ter small break less of coolant accident as

  • described in our letter dated November 21,1978 (GQL-1619
12. Raise selected Steam Generator level instruments to '72 inches above the containment floor.

13 Complete modifications to provide TMI-1 sampling capability indepen-dent of IMI-2 and to isolate the TMI-1 Fuel Handling Building ventila-tion from TMI-2.

B. As Soon As Practicable (Long Term)

1. Hookup all 52 incore thermocouples as specified in A.3 above. -
2. Laprove plant computer data and trend display cap.bility.

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3. . I: stall an instru=ent to alarm and indicate RCS approach to saturation co:ditions.
4. Increase the range of RCS tempera'ture indication for the hot and cold legs.
5. Automate 'svitchover of the ECCS pu=ps from the BWST to the Reactor Building sump.
6. Upgrade the Reactor Building Spray system to eliminate sodium thiosul-face addition.

i

7. C; grade the coating of the Reactor Building and Auxiliary Building icver levels to reduce penetration of radioactive contaminates where additionally required.
8. Previde for Reactor Building sump level seasurement and sampling.

. 9 Provide' a system for vaste gas tank venting to Containment.

10. Raise dba pressurizer level instrument to 72 inches above the contain-mest floor.

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  • e' UNITED STATES OF AMEKICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISCf; COMPANY, ET AL. ) Docket No. 50-289

) (RESTART)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that single copies of " UNION OF CONCERNED SCIENTISTS AND STEVEN C. SHOLLY JOINT PROPOSED REPLY PROCEDURAL FIND.t'.!GS " , dated 18 May 1981, were served upon the persons on the attached service list by Express Mail or by deposit in the U.S. Mail, first class postage prepaid (as indicated bele-this 18th day of May, 1981.

W Steven C. Sholly SERVICE BY EXPRESS MAIL Ivan W. Smith, Esquire Goorge F. Trowbridge, Esquire Administrative Judge Shaw, Pittman, Potts & Trowbridge Chairman, Atomic Safety and 1800 M Street,-N.W.

Licensing Board Panel Washington, D.C. 20036 ,

U.S. Nuclear Regulatory Commission James R. Tourtellottee, Esquire Washington, D.C. 20555 Office of the Executive Legal Director Dr. Walter H. Jordan U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Robert Adler, Esquire 881 West Outer Drive Attorney for the Commonwealth Oak Ridge, TN 37830 505 Executive House P.O. Box 2357 Dr. Linda W. Little Harrisburg, PA 17120 Administrative Judge Atomic Safety and Licensing Board Panel 5000 Hermitage Drive Raleigh, NC 27612 e

.. __m___.__.__._ ____ -.u____. _ . . . _ _ _ _ - . _ _ -

2-SERVICE BY HAND DELIVERY Daniel Cosgrove, Esquire Docketing and Service Sectica Office of the General Counsel Office of the Secretary Federal Emergency Management U.S. Nuclear Regulatory Agency (FEMA) Commission 1725 I Street,'N.W. Washington, D.C. 20555 Washington, D.C. 20472 SERVICE BY FIRST CLASS MAIL John A. Levin, Esquire Robert Q. Pollard Assistant Counsel 609 Montpelier Street Pennsylvania Public Utilities Baltimore, MD 21218 Commission P.O. Box 3265 Marjorie M. Aamodt Harrisburg, PA 17120 R.D. #5 Coatesville, PA 19320 John E. Minnich Chairman, Dauphin County Board Dr. Judith H. Johnsrid of Commissioners ECNP Dauphin County Courthouse 433 Orlando Avenue Front and Market Streets State College, PA 16801 Harrisburg, PA 17120 Thomas J. Germina, Esquire Walter W. Cohen, Esquire Deputy Attorney General Consumer Advocate Division of Law -- Room 316 Office of Consumer Advocate 1100 Raymond Boulevard

! Department of Justice Newark, NJ 07102 1425 Strawberry Square Harrisburg, PA 17127 William S. Jordan, III, Esquire l

Harmon and Weiss Jordan D. Cunningham, Esquire 1725 I Street, N.W.

2320 North Second Street Suite 506 Harrisburg, PA 17110 Washington, D.C. 20006 -

Ms. Louise Bradford l TMI Alert 315 Peffer Street Harrisburg, PA 17102 l

i Gail Bradford l ANGRY l

245 West Philadelphia Street York, PA 17404 Marvin I. Lewis 6504 Bradford Terrace Philadelphia, PA 19149 l

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