ML19291C086
| ML19291C086 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/13/1979 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19291C084 | List: |
| References | |
| RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 8001180397 | |
| Download: ML19291C086 (4) | |
Text
l ' '/
'l
'. E w
UNITED STATES OF AMERICA (5=i NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Doc 0-289 MEIROPOLITAN EDISON COMPANY s
(Three Mile Island Nuclear Station, Unit No.1)
PEIITION FOR EXCEFIION TO 10 CFR 50.44 Steven C. Sholly, Petitioner, pursuant to 10 CFR 2.758, hereby petitions the Atomic Safety and Licensing Board in the above-referenced proceeding to make exception to 10 CFR 50.44 in the Three Mlle Island Nuclear Station, Unit No. 1, Restart proceeding.
The ground for this petition is that the special circumstances in this proceed-ing are such that application of 10 CFR 50.44 will not serve the purposes for which it was adopted, d$l Petitioner argues that on the basis of the facts contained in the accompanying affadavit filed pursuant to 10 CFR 2.758, it is clear that there is not adequate assurance that the public health and safety will be protected by the application of 10 CFR 50.44 with respect to the Three Mile Island Nuclear Station, Unit No.1.
It is obvious from a review of the facts associated with the Unit 2 accident that far more than five percent of the zircalloy metal in the core reacted with water to form hydrogen.
Petitioner asserts, therefore, that in the case of Three Mile Island Unit 1, it is inappropriate to continue to apply the five percent rule concerning the design basis of hydrogen control systems.
It is also very clear that when a sizeable fraction of the zircalloy in the core reacts to form hydrogen, there is also a very significant amount of radiation which is released into the containment atmosphere along with the gxW f 7 9 0 18.5 800118 0 39 7-
e $h" hydrogen.
In the case of Unit 2, such radiation in the con-tainment atmosphere to register radiation readings on the containment dome monitor in excess of 1000 R/hr.
It is argued that such readings would have been greater had the accident occurred close to.a refueling shutdown of the T plant when there would be a near full inventory of fission products and activation products in the core.
It is further argued that the amount of decay heat would also be greater, resulting in more significant metal-water reaction than was experienced with the Unit 2 accident.
According to the Lessons Learned Task Force Status Report (NUREG-0578), a decision not to vent the Unit 2 containment due to the potential for large off-site release of radiation contradicts previous NRC rulemaking decisions not to require recombiners at older plants, among them Three Mile Island Unit 1.
In the absence of a new rulemaking proceeding, and due to the uncertain nature of when such proceeding may be initiated versus the uncertain time frame for the
==
outcome of this proceeding (TMI-1 Restart), Petitioner asserts that an exception to 10 CFR 50.44 is needed in this case to provide adequate assurance of protection of public health and safety.
Petitioner urges the Board to note the distinction between the obvious generic problem of hydrogen generation and the specific circumstances being addressed herein.
Petitioner asserts that while a generic problem may very well exist with regards to hydrogen gas control at nuclear' power plants in general, the similarities in design, construction, and operation of Unit 1 and Unit 2 at Three Mile Island make it abundantly clear that there is a specific problem at Unit I which can be best dealt with within the scope of an exception to 10 CFR 50.44 and litigation in the Restart proceeding of a hydrogen control contention.
Petitioner takos note of the plan on the part of the hb 1790 186
< Jh
~~
Licensee to install a hydrogen recombiner prior to restart.
Petitioner notes also that there is no protection against a single failure involving the recombiner (i.e., if the on-line recombiner falls, an undetermined period of time 5 gasses before another recombiner can be installed).
In view of the rapid accumulation of hydrogen gas during the Unit 2 accident, such a lack of protection agalnst the failure to operate of the recombiner is clearly not an acceptable plan.
Petitioner is not prepared at this time to suggest a percent figure for hydrogen generation which should be considered as the design basis for a hydrogen control system for Three Mile Island Unit 1.
However, experience in the Unit 2 accident suggests that, as a minimum, the Licensee should be required to include in the hydrogen gas control system design basis that percentage of clad metal whLch reacted during the Unit 2 accident, plus
(.._
whatever incrememtal amount could be expected to have been
- generated had there been a near-full inventory of fission products (and the extra decay heat which accompantes such conditions).
The Licensee should be required to demonstrate that any proposed hydrogen gas control system for Unit 1 be able to successfully control hydrogen gas concentrations below the limit of combustion for the length of time such control may be necessary and that the system is able to provide reasonable assurance of meeting this level of control in the event of a single active failure of a recombiner unit or other such hydrogen control system.
Additionally and finally, the LLcensee should be required to demonstrate compliance of any proposed hydrogen control system with the General Design Criteria requirements as well as the radiation protection standards of 10 CFR 20 and Appendix I of 10 CFR 50, and the site criterla of 10 CFR 100.
ta=
(. -
\\19D \\81
W Petitioner asserts that such requirements should be made a condition of permission for Restart in order to provide reasonable assurance of protection of public health and safety.
liATED:
13 November 1979 Steven C. Sholly f
304 South Market Street Mechanicsburg, PA 17055 (717) 766-1857 (717) 566-3237,-3238 3
.\\ 7 9 0.\\ B8 '
iis O