ML19263F404

First Set of Interrogatories Directed to Intervenor Ucs in Restart Proceeding.Poses Questions Re Alleged Inadequacy of Reliance on Natural Circulation to Remove Decay.Certificate of Svc Encl

ML19263F404
Person / Time
Site:	Three Mile Island
Issue date:	01/18/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	UNION OF CONCERNED SCIENTISTS
References
NUDOCS 8001280112
Download: ML19263F404 (12)

Text

'

January 18, 1980 W

UNITED STATES OF AMERICA d' s NUCLEAR REGULATORY COMMISSION C' ,

V -

BEFORE THE ATOMIC SAFETY AND LICENSING BOA A 0 gN9e0 q fM U{

In the Matter of ) \Q (5 3 METROPOLITAN EDISON COMPANY ) Docket No. 50-289 l g

) (Restart) '

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR UNION OF CONCERNED SCIENTISTS These interrogatories are filed pursuant to 10 C.F.R.

S 2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation.

Licensee recognizes that Intervenor Union of Concerned Scien-tists ("UCS") may not now be able to completely answer all inter-rogatories propounded below, since some areas are the subject of discovery by UCS to Licensee. Licensee therefore requests that each of these interrogatories be answered within the time specified in S 2.740b (or such other time as may be agreed upon by counsel) to the extent that responsive information is presently available to UCS. With respect to those interroga-tories for which complete and responsive information is not now available to UCS, Licensee requests that revised answers be provided prior to the close of the discovery period established in the Licensing Board's December 18, 1979 First Special Pre -

hearing Conference Order. O 8001280 .

G '*

- 2 ..

The following definitions apply to each of the inter-rogatories below:

A. " Document" means all writings and records of every type including, but not limited to memoranda, tapes, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, logs, speeches, articles, transcripts and all other records, written, electrical, mechanical or otherwise-B. " Identify" means:

(1) With respect to a natural person, name, present or last known home or business address, present or last known job title or position, and the dates of tenure in that position; (2) With respect to a document, the type of document (e.g., letter, record, list, memorandum.

memorandum of telephone or face-to-face conversation, etc.), date of the document, title of the document, subject of the document, name of person who prepared the document, and name of person for whom the docu-ment was prepared or to whom it was delivered.

Interrogatories on Contention No. 1 1-1. Explain how the TMI-2 accident demonstrated that reliance on natural circulation to remove decay heat is in-adequate.

1-2. Does UCS contend that reliance on natural circula-tion to remove decay heat was inadequate at all stages in the I817 136

sequence of events at TMI-2 following the trip of the feedwater system? If so, explain the basis for the contention. If not, identify the point in the sequence of events when UCS contends that reliance on natural circulation to remove decay heat be-came inadequate.

1-3. Does UCS contend that natural circulation is (a) impossible or (b) ineffective to remove decay heat after voids have formed in the primary cooling system? If so, provide the technical basis for the contention and reference any docu-ments which in UCS' view support the contention.

1-4. What is the basis for the statement that during the TMI-2 accident it was "necessary" to operate at least one reactor coolant pump to provide forced cooling of the core?

Explain why, even assuming forced cooling to be required, opera-tion of the high pressure injection system would not have suf-ficed to cool the core.

Interrogatories on Contention No. 2 2-1. Explain what you mean by operation of the emer-gency core cooling system in a " bleed and feed" mode. Describe all flow paths associated with such mode of operation.

Interrogatories on Contention No. 3 3-1. Does UCS contend that natural circulation cannot be maintained at hot stand-by conditions without use of pressur-izer heaters and controls? If so, explain fully the basis for the contention.

3-2. Explain the basis and provide document references 1817 137

for the statement that the staff recognizes that pressurizer heaters and associated controls are necessary to maintain natural circulation at hot stand-by conditions.

Interrogatories On Contention No. 4 4-1. Refer to the information contained in section 2.1.1. 3.1 of the Restart Report. Does UCS contend in the light of that information that adding pressurizer heaters to the on-site emergency power supplies will degrade the capacity, capa-bility and/or reliability of these power supplies? If so, ex-plain fully the basis for the contention.

4-2. Refer to the safety evaluation performed by the NRC Staff at pages C8-3 through C8-8 of the January 11, 1980 Status Report on the Evaluation of Licensee's Compliance with the NRC Order Dated August 9, 1979. Does UCS contend in the light of that information that adding pressurizer heaters to the onsite emergency power supplies will degrade capacity, capability and/or reliability of these power supplies? If so, explain fully the basis for the contention, indicating with particularity the inadequacies of the NRC Staff safety evaluation.

4-3. Explain in detail in what respect UCS contends that GDC 17 would be violated.

Interrogatories On Contention No. 5 5-1. Provide the technical besis for UCS' con'tention that proper operation of power operated relief valves, associated block valves and the instruments and controls for these valves is essential to mitigate the consequences of accidents.

1817 138

5-2. Describe the accidents or categories of acci-dents to which UCS contends that the first sentence of Conten-tion No. 5 applies.

5-3. Does UCS contend that satisfactory mitigation of the accidents identified in answer to interrogatory 5-2 is not possible without the opening or manipulation of the power-operated relief valve? If so, explain fully the basis for the contention.

Interrogatories On Contention No. 6 6-1. Identify the appropriate qualification testing which UCS contends has not been done and should be done to verify the capability of the reactor coolant system relief and safety valves to function during normal, transient and accident conditions.

Interrogatories On Contention No. 7 7-1. Describe the instrumentation proposed by UCS for direct measurement of the water level in the fuel assem-blies. Explain whether, and if so how, such instrumentation would provide reliable and unambiguous indication of adequate core cooling under all accident conditions.

Interrogatories On Contention No. 8 8-1. Copies of Babcock & Wilcox ("B&W") documents con-cerning small break analyses will be supplied to UCS counsel under separate cover. Does UCS contend in the light of the l'817 139

information contained in such documents that sufficient analyses have not now been done to show that there is adequate protec-tion for the entire spectrum of small break locations? If so, explain the inadequacies which UCS contends exist in the analyses performed to date and describe in detail the further analyses which UCS contends should be performed.

Interrogatories On Contention No. 9 9-1. Provide a technical basis and explanation for UCS' contention that the TMI-2 accident was substantially ag-gravated by the closing of two auxiliary feedwater system valves.

9-2. Explain the basis for any disagreement which UCS may have with the conclusion of the President's Commission (page 94 of its report) that " [t]he loss of emergency feed-water for 8 minutes had no significant effect on the outcome of the accident. "

Interrogatories On Contention No. 10 10-1. Identify each safety function related to the core cooling and containment isolation systems as to which UCS contends that the design of a safety system must be modified so that no operator action can prevent the completion of such safety function once initiated.

10-2. Explain as to each safety function identified in answer to interrogatory 10-1 the criteria proposed by UCS for determining completion of the safety function.

10-3. Describe as to each safety function identified in answer to interrogatory 10-1 the design modification (s) pro-1817 140'

posed by UCS so that no operator action can prevent the comple-tion of such safety function once initiated.

Interrogatories On Contention No. 12 12-1. Identify each item of failed equipment in the containment and auxiliary buildings which is covered by Conten-tion No. 12.

12-2. Stace as to each item of equipment identified in answer to interrogatory 12-1 whether UCS contends that the equipment failed because of the TMI-2 accident environment and, if so, the technical basis for such contention.

12-3. Provide as to each item of equipment identified in answer to interrogatory 12-1 the basis for UCS' contention that such equipment was previously deemed to be environmentally qualified.

12-4. Identif / each item of " safety-related equipment" in the TMI-l containment and auxiliary bulidings which UCS con-tends must be demonstrated to be environmentally qualified.

Interrogatories On Contention No. 13 13-1. Describe the accidents which UCS contends are credible and not bounded by the TMI-l design basis accidents.

13-2. Explain as to each accident identified in answer to interrogatory 13-1 the nexus between such accident and the TMI-2 accident.

13-3. Explain what UCS means when it contends that an accident is not " bounded" by the design basis accidents for TMI. Indicate in particular as to each accident identified in 1817 14i

answer to interrogatory 13-1 whether the term " bounded" refers to accident events or accident consequences or both.

13-4. Describe the criteria proposed by UCS to be used for selecting credible accidents to be considered.

Interrogatories On Contention No. 14 14-1. Define " adverse effect on the integrity of the core."

14-2. Identify each system or component relating to the core cooling system presently classified as non-safety-related which UCS contends must be identified and classified as components important to safety and required to meet all safety grade design criteria.

14-3. Explain how each system or component identi-fied in answer to interrogatory 14-2 can directly or indirectly affect temperature, pressure, flow and/or reactivity.

14-4. Explain how each effect identified in answer to interrogatory 14-3 can have an adverse effect on the integ-rity of the core.

Interrogatorv 21 21-1. With respect to each individual whom UCS intends to call as a witness in this proceeding:

a. Identify by name, address and affiliation each such individual;

b. State the educational and professional back-ground of each such individual, including occupation and insti-tutional affiliations, publications and papers; 1817 142

c. Identify the contention as to which each such individual will testify;

d. Describe the nature of the testimony which will be presented by each such individual, including an identifica-tion of all documents which the individual will rely upon in the testimony.

e. Identify by court, agency or other body, pro-ceeding, date and subject matter all prior testimony by each such individual.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: /pu . /h l1 Sf/ i-

/ Geptge F. Trowbridge /

1800 M Street, N.W.

Washington, D.C. 20036 Tel: (202) 331-4100 Counsel for Licensee Dated: January 18, 1980 1817 143

January 18, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Interrogatories to Intervenor Union of Concerned Scientists", were served upon those persons on the attached Service List by deposit in the United States :aail, postage prepaid, this 18th day of January, 1980.

' Robert E) Zahler Dated: January 18, 1980 1817 144

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Iavin, Escuire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Cam'n Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Camission Harrisburg, Pe.g lvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Permsylvania 17120 Oak Ridge, Tennessee 37830 Pcbert L. Knupp, Esquire Dr. Linda W. Little Assistant Solicitor Atcmic Safety and Licensing County of Dauphin Board Panel Post Office Box P 5000 Hermitage Drive 407 North Front Street Raleigh, North Carolina 27612 Harrisburg, Pernsylvania 17108 James R. Tourtellotte, Esquire John E. Minnich Office of the Executive Legal Director Chairman, Dauphin County Board U. S. Nuclear Regulatory Conmission of Cmmissioners Washington, D.C. 20555 Dauphin County Court 1 ruse Front and Market Streets Docketing and Service Section Harrisburg, Permsylvania 17101 Office of the Secretary U. S. Nuclear Pegulatory Camission Walter W. Cohen, Esquire Washington, D.C. 20555 Consumer Advocate Office of Consumer Advocate 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 1817 145

Jordan D. Cunningham, Esquire Robert Q. Pollard Attorney for Newberry Township Chesapeake Energy Alliance T.M.I. Steering Cm mittee 609 Montpelier Street 2320 North Second Street Baltimore, Maryland 21218 Harrisburg, Pennsylvania 17110 Chauncey Kepford Theodore A. Adler, Esquire Judith H. Johnsrul Widoff Reager Selkowitz & Adler Environmental Coalition on Nuclear Post Office Box 1547 Power Harrisburg, Pennsylvania 17105 433 Orlando Avenue State College, Pennsylvania 16801 Ellyn R. Weiss, Esqu.tre Attorney for the Lhion of Concerned Marvin I. Icwis Scientists 6504 Bradford Terrace Shelcbn, Harnen & Weiss Philadelphia, Pennsylvania 19149 1725 Eye Street, N.W. , Suite 506 Washington, D.C. 20006 Marjorie M. Aamodt R. D. 5 Steven C. Sholly Coatesville, Pennsylvania 19320 304 South Market Street Mechanicsburg, Pennsylvania 17055 Gail Bradford Holly S. Keck Iagislation Chaiman '

Anti-Nuclear Group Papresenting York 245 West Philadelpbia Street York, Pennsylvania 17404 Karin P. Sheldon, Esquire Attorney for People Against Nuclear Energy Sheldon, Harnon & Weiss 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 1817 146

.