ML19291C088

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Affidavit in Support of 791113 Petition for Exceptions to 10CFR50.44.States Technical Facts Leading to TMI-2 Accident & Cites NUREG References Upon Which Request for Exception Based
ML19291C088
Person / Time
Site: Crane Constellation icon.png
Issue date: 11/13/1979
From: Sholly S
AFFILIATION NOT ASSIGNED
To:
Shared Package
ML19291C084 List:
References
RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 8001180407
Download: ML19291C088 (3)


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UNITED STATES OF AMERICA E

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Doc t No 0-289 C. METROPOLITAN EDISON COMPANY es (Three Mile Island Nuclear

)

Station, Unit No. 1)

)

AFFADAVIT IN SUPPORT OF PEIITION Steven C. Sholly, Petitioner in the above-referenced proceeding, submits this affadavit in support of the attached Petition for exception to 10 CFR 50.44.

Petitioner sets forth the following as the facts in this matter 1.

Commencing on or about 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />, 28 March 1979, at Unit No. 2 of the Three Mlle Island Nuclear Station there began a series of events, including 5I mechantcal malfunctions and operator errors, which culminated in a loss-of-coolant accident accompanied by serlous core damage and the off-site release of over 10 million curtes of radioactivity.1 2.

At approximately 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br />, 28 March 1979, hydrogen gas combustion within the containment at Unit No. 2 caused a pressure spike in the containment to about 28 psig.

The extstence of said pressure-sptke was not reported to NRC personnel untti 29 March 1979.2 3.

The cause of the pressure sptke was not determined to be hydrogen combusticn until at least the after-noon of 29 March 1979.3 4.

Initial reaction to the pressure spike by personnel of Metropolttan Edison Company, the Licensee, was to ascribe the cause of the pressure spike to electrical interference.4 gaa 5.

The source of the hydrogen which combusted in the s:

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Unit No. 2 containment was the metal-water reaction of a sizeable fraction of the zircalloy in the core of the reactor.5 6.

The amount of hydrogen so-generated was well in excess of the amount required by NRC regulations to be C

considered in the design basis for post-accident combustible gas control systems.0 7.

Under the provisions of 10 CFR 50.44, Three Mile Island Nuclear Station Unit No. 1 is required to assume a 5% reaction of cladding with coolant water in the design basis for the hydrogen control system.

8.

Further,10 CFR 50.44 provides that, for Unit No. 1, only a purge system is required for hydrogen control in post-accident situations.O 9.

A decision was made during the Unit 2 accident not to vent the containment, atmosphere to the environ-ment.

This decision was made partly on the desire jg; to keep releases of radioactivity to the off-site environment at a minimum.

This contradicts the basis for previous rulemaking decisions not to require recombiners at certain plants, among them Unit No.1 at Three Mile Island Nuclear Station.9 10.

Recombiner technology is well-established and is not very costly.10 11.

Events occurring at Unit No. 1 similar to those.

during the Unit No. 2 accident have the potential for appreciable offsite releases of radioactivity in the event that the containment atmosphere must be vented to control hydrogen gas concentrations.11 REFERENCES 1.

NUREG-0600, Appendix I-A, " Operational Sequence of Events", and page II-3-17.

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2.

NUREG-0600, pages I-4-47 through I-4 '51.

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3.

NUREG-0600, pages I-4-47 through I-4-51.

4.

NUREG-0600, pages I-4-48 through I-4-49.

5.

NUREG-0578, page A-22.

6.

NUREG-0578, page A-22.

7.

10 CFR 50.44.

C.

8.

10 CFR 50.44.

9.

NUREG-0578, page A-22.

10.

NUREG-0578, page A-22.

11.

NUREG-0578, page A-22.

State of Pennsylvania

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Before me the subscriber personally appeared who being duly sworn, according itave-c. 25 e' 7-to law, doth depose and say

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and further sayeth not.

Sworn to and subscribed before me this 13th day of Novenber 19 79 A n>s u MfJ

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D fdANCY G. ?AN*,ER, NOTARY PtJSUC C/:AP H!LL CCRO CUV3ER AND COUNTY MY CO d W J.0:4 DPIRES MAR. 21,1931 u c,r.'s a y've 's 8.ux'stiep9 No'erles 9

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 11/16/79

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s

In the Matter of

)

)

METRO?OLITAN EDISON COMPAflY,

)

Docket No. 50-289 ET AL.

)

)

(Three Mile Island, Unit 1)

)

NRC STAFF BRIEF ON THE EFFECT OF RULEMAKINGS UPON THE ISSUES OF THE TMI-1 SUSPENSION PROCEEDI',3 I.

INTRODUCTION Several contentiens submitted by petitioners in this proceeding relate ir: so e way to issues that are or may become the subject of rulemak-ing by the Comission.

In that connection, the NRC Staff has attempted

~ to identify issues raised by petitioners that are within the scope of this proceeding as we understand it and that are pending rulenakings.

In addition, we identify certain areas proposed by the NRC Staff as appropriate for rulenaking.

These areas are,specifically identified in NUREG-0578. We also attempt to identify other related areas that have been the subject of formal Staff recom-mendations for rulemaking. While these latter issues are not, therefore, pend-ing rulemakings, their status as recommendations for rulemaking may be of-interest to the Board.

This Brief is submitted in response to the Board's re-quest that the NRC Staff report on '

upon the issues in this hearing. A DUPLICATE DOCUMENT options and considerations of the L Entire docun'.ent previously entered into system under:

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l~.I, November 30, 1979 h=

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)

)

LICENSEE'S OPPOSITION TO PETITION OF STEVEN C.

SHOLLY FOR AN EXCEPTION TO 10 C.F.R. S 50.44 Intervenor Steven C.

Sholly ("Sholly"), pursuant to 10 C.F.R.

S 2.758 (b) (1979), has filed with the Licensing

=

Board a petition seeking an exception from the provisions of

- 10 C.F.R.

S 50.44 with respect to proceedings in the above-captioned docket.

For the reasons set forth below, Licensee opposes the petition.

Grant of the Sholly petition is a necessary predi-cate to litigation of his proposed contention no. 11.

That contention states:

It is contended that the production of hydro-gen in the reactor core from clad metal-water reactions follow" ably high risk o reactor pressure tainment, with t DUPLICATE DOCUMENT stantial portion environment.

It Entire document previously a safe'and relia entered into s stem under:

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gen gas from the ANO

,J No. of pages:

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.s November 30, 1979 p=g 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)

)

LICENSEE 'S RESPONSE TO

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NRC STAFF ERIEF ON THE EFFECT OF RULEMAKINGS UPON THE ISSUES OF THE TMI-l SUSPENSION PROCEEDING I.

INTRODUCTION In response to the Board 's request that the NRC Staff repcrt on the status and effect of rulemakings upon the issues in this proceeding, the NRC Staff has submitted a brief addressing the options and considerat' Board when (1) the Commission DUPLICATE DOCUMENT rulemaking in the Federal Regi Entire document previously entered into s stem under:

that has been proposed by the g

by the Commission.

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