ML19262C053

Interrogatories Directed to Licensee & Nrc.Includes Inquiry Whether ALARA Concept Is Adequate for Filter Design

ML19262C053
Person / Time
Site:	Crane
Issue date:	01/06/1980
From:	Lewis M AFFILIATION NOT ASSIGNED
To:	METROPOLITAN EDISON CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19262C054	List: ML19262C053 ML19262C056
References
NUDOCS 8001280199
Download: ML19262C053 (5)

Text

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'4arvin I. Lewis "2

6504 Bradford Terrace Phila, PA 19149 1-6-80.

In the Matter of USNRC. Docket No. 50-289, ThreeMile Island

'4arvin I. Lewis, Intervenor, Internogatories to the Various Particinants In the USNR0 Docket No. 50-289 Proceedings.

The following interrogatories are directed at those.intervenors with Psychological stress contentions: specifically, those intervenors referred to on Page 19 of the Board's Order of December 18, "we are permitting discovery fo proceed on those contentions as if they were admitted by this order."

( CIA,PAliE,Newberry, Aamodt, etc.) (100FR 2.740(b))'.

Psychological Stress Interrogatories Eollow:'

~PS 1.

In order 'to evaluate the present design and dart;pt; design philosophy, Q/A, etc.,

some idea of what the surrounding populace most fears will be let loade from an accident at TMIf1 needs be determined. Since these people are particularly traumatizedby reports f

of radioactive isotopes in the environment, some idea of what would they most fear and would therefore p%efer be fully held in felters is asked.

PS

2. Considering only the psychological stress issue, are tha allowables in 10CPR 51, ZG3IXSO, 100FR20, 40CFR190, Reg Guide 1.109, ALARA concept adeqaute $

for filter design or is more stringent design of filtering effectiveness indicated and,,why?

PS

3. Are there any particular isotopes that'the people in the surrounding area most foar? Pleaae specify 3 which completely.

Krypton 85 ;not just noble gas. ~,

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5 Interrogatoriesforsuspendedlicenseeonjextpage.

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Page 2, Interrogatories.,

Marvin I. Lewis

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t Interroghtories to be answered by suspended licensee, Meted /.

Punsuant to 100FR 2.740(b), I request that the suspended licensee or his legal representative answer the following q questions within the time limits of 100FR 2.710.

Please tell me the name of the person who actually put the answer together, and in the case of technical questions, tell me the name of the techAical person who researched'the answer.

Telephone numbers and mail addresses would also be helpful if there is no objection.

SP 1.

I.mn not sure what accident scenarios most aptly describe the accident scenario.

^1so, I so not believe that I have seen a definitve statement of the accident by the utility.

I have, of course, read many newspaper accounts originating at Met ED, but I would like to give Met Ed a chance to tell its own story on the record.

Vihich accident scenario most aptly and accurately describes the accident at TMIy2 on 3/28/79? ( If you refer to Restart report,g'jggeg 0600 etc, please give page numbers which you feel are/ accurate or most misleading.)

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SP 2. Using the scenarios in SP 1 above, what particular items, materials, filters or what-have-you failed to allow radioactive contamination to escape.imxatixspazifim 3e specific. Answer as to which item failed to allow which isotope to get out.

Describe entire pathway,but refer back to previous parts of your answer to reduce redundancy and lengthiness. A table is suggested. Include where in the Rest, art Report this particular pathway is eliminated or #

repaked.

Isotone Pathway Reference for repair at TMI51 Xe 133 Cracked Vent Restart Report Page ?????

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(Describe path)gyureg Q600

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i etc.

SP 3 Please give a description or accounting over time of what radioactive isotopes escaped at TMIp2 and the causes.

(Pathways, Curies, rate of loss.)

, IX2XMNIXX i

A table is suggested.

1815 299' p

Fase 3 Interrogatories for suspended licensee. Marvin I. Lowls.

JP 4.

Ghht the Vent header actually cracked as described in the Xcaeny Conaission Report, Page 1037 SP 5. Please put in or supply a schematic or working drawing I

of where the vent header is.

(?;orking drawing preferred.

SP 6.

Please pl.ut in a description of cracks: How g g g,

how caused, pas,ure reports, etc.?

Just generally of specif ically tell the story of why there were cracks in the vent header and why they were not fixed.

SP 7. If the vent header also exists on TMI!1, Is it cracked?

If so will it be fired before restatt?

How? Put in mainten ance reports, or job tickets or name of artisan who did war k.

s SP 8. Is there a program to assure no repeat of cracking in the Vent Header at M If1?

Is it long or short ters? Where is it referred to in the Lessons Learned 3uregs?

Page Nos.

s? !.9.Accordins'to some newspaper reports, some filters in the auxiliary building did not work because they got wet.

'0his was echoed,but not verified word for word in NUREG o6co Pase IA 1 thru 123.

Alofo there weren few confusing references in the Kemeny Commission' report referring back to staff reports which I could not find.

i Therefore, I ask Did the filters in the ausiliary building of TMI!2 stop working because they got wet? or Did the filters in TMIJ2 stop working because of s6me other reason?

Or "id the filters in NI!2 work fine?

If all of the filters in the auxiliary building worked fine I

-well within design linits and the design limits allowed V very little contamination out-skip the following questions.!q;t../9 If, however, more radiation escaped the auxiliary building filters or from the auxiliary building by any other path than acrackedventheader,pleaseanswerthefollowingquestions.,',f..h,,

Please put in references and page numbers used in your answer.I SP 10. ?lhich scenario most aptly and correctly describes what happened in the auxiliary building of M I!2 with particular emphasis on how the filters got wet?

Ref and Page 332xxxx::

numbers.

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iPage'I4 Interrogatories for suspended licensee. Marvin I. Lewis.

SP 11. How nuch humidity can the filters work withstand before loosing effectiveness as a filter? Use advertising literature orANSI or other non - 312 3D or non - NRC literature preferably.

Agraph is suggested. Plot a well defined loss of filtering effectiveness against moisture in the air for various rates or volumes of air passing thru filter.

SP 12. Put in a schematic of zusi auxiliary building showing where all filters are, which got wet, which stopped working.

Use working drawing whereever possible.

S? 12.

Whic filters were reduced in effectiveness by what cause?

A table is suggested. Elaborate at your discretion for clarity.

SP 13.

Describe,the filters in the nuailiary Building of T MI31 which are in a similar position or use to those filters which failed in T'!I!2.

JP 14.

Describe what actions have been taken so /

far and will be taken to elininate the same filter problen in TMI91 J

na happened in T3Ip2.

Put in a schedule, where the itas is L

I referred to in the Lessons Learned, NUREG 0600, Restart Report, or an$ other reference deened appropriate by the suspended licensee with Page nunbers.

So not skin the following nuestions even ist if the filters did not get wet. See instructions on botton of Page 3 xt=h which states that questions SP 10 thru 14 nay be skipped if filters did not get wet.

SP 15. Using the,3oard's test in the second paragraph of Page 14 Dec 18 Order:

"Je rule that contentions which use the actual events at TMI as a base and then qx add or change a credible specific occurence or circumstance, set forth sufficiently specific accidents which have a close nexus to the TMI accident. These contentions are therefore admissable."

I ask Have the filters been analyzed for how they will perform in the scenarios which have been accepted from other interv enors?

Will they be adequate?

Specifically Sho11y's; added contentions.

1815 301

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'Page.5 Interrogatories to the suspodded licensee. M. Lewis.

SP 16. Using the various scenarios in SP 15, what unexpected

, unusual, or previously unanalysed rddioactive contamination or isotope may be generated-and in what volumes and curies-which nay or may not have an adverse effect upon the useful-ness of the filters in the auxiliary building?

Interrogatories to be answered by Staff under 100FR 2.720(h)

(2)(11).

D MRO 1. What actione in the Long term and Short tern actions i

are specifically reisted to filters?

Vent header?

3RC 2.

How are the answers in NRC #1 specifically going to help the filters and vent header work correctly and adequa6ely in a repeat of the 3/28 accident at TMI#11 NRO 3.

There/ is a large new filter on the auxiliary building at TMId2. In a repeat of the TMIS2 accident at TMIfi,wouldsuchanewfilterberequiredonT]Idi?

NRC 4.If the answer to SRC 3 is yes, will such a filter k

l of similar design of application be placed on TMIs1 before restart?

"Rc 5 If the answer to "Rc 4 in no, explain why such a new filter will not be needed in a repeat of the TMI#2 accident at TMIdi.

NRC 6.

Krypton 85 seems to be leaking unexpectedly according to Bob ^rnold, Met Ed.

Will any catchments or filters be placed on TMI!1 in order to reduce the leakage of Ir 85 af ter TMIJ1 has a similar accident to TMId2. ' Jill this be done before restart? after another accident? When?

NRO 7.

'#here are the cracks which are allowing the release of Krypton 85 at TMId2?

Have these areas been inspected and repaided at TMIf1?

NRC 8. List the isotopes which got out, when, how much (vol.

and curies) by date and hour if possible. If in the references, nerely 6 7e Pa6e numbers.

1 NRC 9. Using the Table S-3, compare the allowables with the actual releases. Was the utility in violation? Is this-violation specified in NUREG o6co or Lessons Learned.? Page 3/.

3RC 10. Contact suspended licensee and state if you. agree or disagree with his answers to Lewis Interrogatorier: 18iS 302

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