ML19294B181
| ML19294B181 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/29/1980 |
| From: | Lewis M AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8002270480 | |
| Download: ML19294B181 (11) | |
Text
lw [ s W N
6 Marvin I. Lewis 6
6504 3radford Terrace C
cd gg Phila.PA 19149 l-29-80.
United States of America Nuclear Regulatory Commission Atomic Safety and Licensing Board In the Matter of Metropolitan Edison Company (or its successor corporation) Docket No 50-289, Three Mile Island, Unit !1.
Continuine Set of Lewis Interrocatories to Staff.
NRC 11. Do you know the location of any FSAR or pSAR for the TMIf1 and #2 reactors in the Phila. area. ?
I have had to use these documents in the Harrisburg Middletown area and its very time Cons"miMg.
The following questions are prompted by the information in the Staff's SER dated 11 I was hoping that the 2fn (an 80 which I zeceived on 1-20-80.
SER would be sufficient to answer these points without putting them in interrogatories.
I was disfappointed, but the SER does have some ve,ry good infor-mation in it nonetheless.
HRC 12 On Page C4-6 there is a Paragraph which starts, " Subsequent to the accident...."
This entire paragraph seems to be coached in nystery.
I don't understand it.
Here are a few Af my -
confusions.
" Subsequent to the accident at TMI-2, the gaseous vaste process -
ing system has experignoed leakage."
Does this mean that the system did not experience leakage prior to the accident, during the accident ;but only" subsequent to the accident?"
i How nuch is' leaking ?
, ' ~
6 Yhere is it leaking?
What is lenking?
Why hasn't it been repaired or stopped? (It referaf to the leak.)
Is this an indication of a minor breach of contain: pent? If not,
why not?
Is this a violation of the TMIf2 operating license ? If not,
why not?
"The TMI-1 system was pressure tested in June 1979 and no leakage was noted during the test."
What's ahalogous mean?
Specify dictionary or give def.nition.
Does analogous mean it has analogous cracks? If not, why not?
Was the part or parts which were pressure tested analogous to or similar to those pr.rts in TMI#2 which were cracked in the vent header?
Helium leak test. I have performed helium leak tests.
I have found that the results of helium leak tests are much more sensitive to the preference of the theoperator than to the helium which =ay or may not leak out.
Since~the operator will be the suspended licensee, what checks do you have to control operator preference in this leak testing?
7tho controls the checks? IIRC, Suspendde?
000mO Lh[Q nw
2.
How extensive was the pressure testing and how extensive will the helium leak testing be?
Will all possible leaks in the gaseous waste system be evaluated? Will all parts in the gaseous waste system be tested both ways?
"The vent header system is protected from overpressure by 2 relief valves on the vent header ancby water filled loop seals on the oserflow of the mise waste storage tank."
If the"TMI-1 gaseous waste system is analogous to that of TMI-2",werent these safeties in place at TMIO 2 on 3/28/807 If so, why didn't they work?
If these safeties did not work on TMI#2, why do yut thi.nk T
that these safeties wdll work on TMI#1 now?
T How did you pressure test the system with kka the " individual relthf valves " set as in the table on Page C4-C7 If these safeties did work properly on 3/28/79, how did the millions of Curies of Ie get out?
Since all of'the questions above center upon one paragraph,
~
I have taken the liberty to put them in one titerrogatory.
If the Staff wishes to subdivide this interrogatory for ease of answering, please do.
This interrogatory is complicated because my understanding of the paragraph in the SER is so confused.
NRC.12..
Again., I am confused. I hope that the Staff will not only answer, questions; but also, try to clarify the situation. --
Page C4-7 top *, "there are no interconnecting gaseous vaste
_j systems or. ventilation systems.
Since there are no ocomon a
points, we conclude that decontamination or restoration operations at MI2 will not affect ^-the MI1 high level waste gas system, rea,etor building purge, or auxiliary building ventilation system."
g I cannot understand the idea of'no - interconnecting ' and E
'no common. points."
Consider this scenario:
We have arepeat to the minutest detail of the accident at TMIf2 at THIf1 some time in the future.
Allow one difference.
The meteorological circumstances are such that no' wind is bbwing and thenis a downdraft from the cracked vent header to the control room and auxiliary building intacts for ventilation.
The outside air is a common point.
Any error at Tgle1 or 2 can affect the outside air adversely.
The contaminated air then would be used in the other reactor.
TEtTT This common point about the outside air is ignored be(
the Staff, and leads me to believe that there are many other common points ignored by the Staff.
I believe that the filters on the incoming ventilation systems for # 1 and 2 must be upgraded for this eventuality.
If the Staff disagrees with any or all of the above scenario, please be specific in your answer.
Show how, why and any technical analysis which de=nnstrates the basis of your disagreement with the above scenario.
If the Staff disagrees on other than technical points (for instance: It's a basic itet of faith that nuclear is safe, or I wanna keep my /
job )
include these other points also.
i g
3.
b Please note: The scenario on Page 2 NRC 12 dces not disagree wit).he scenario on Page C4-2.
I merely point out that the secua_io on Page C4-2 in not ecmprehensive :r definitive.
Filters will have to operate in accident conditions.
Are all filter and venting sytems siessically qualified and safety grade which may have to operate in ac::ident conditions?
E Can I get a copy of Regulatory Guide 1.4 and 1,5? Page 08-31.
If the hydrogen gas is vented during and accident, how much radiation in curies and by isotope will be released with the hydrogen?
Is there a way to filter this to minimize eroosure?
08-58 l-NRC 14.
Page C2-7. " 9. "... to assure tha"; vndesired pumping of radioactive liquids and gases will not occur accidentally."
?
"Our evaluation of the licensee's response !.n this area is contained in NUREG 0578 Section 2.14 and 2.
6."
e.-
I read these sections of NUREG 0578.
They speak of " inadequate-
- in three respects "
and 'difficultists af arose not only in dafety systems, but also in systevis outside the scope of previous " safety grade " requirements. '
T Nowhere do I see the Staff suggest that the: licensee's response j
to date is adequate in these areas.
My concern is about radioactive gases and liquids.
How will I know when the licensee's response is adequate to the Staff 2
' on these issues without searning back and forth between docum-
'4 ents to find that the licensee's response is not adequate to the staff? __.
2-How will I know what the licensee'is doing and when and if adequate 1;o the Staff?
I refer to the matters relevant to the levin Contention.
-@=
NRC 15. -
R Page C8-30 and 1-26. Has anything been done to implement a
~
leak reduction and elimination progsam aside from recommending such a program?
111 I see so far is recommendations and no action?
Is the Staff satisfied merely by. recommending things that never happen?/
NRC l'6 Page C5-2. Can I get a copy cf Regulatory Guide 3.110, "How to Trade dollars for Human Lives" or " Cost Benefit analys for Radwaste Systems for IiWRS. "
If I cannot get a copy, tell me what the date fu of the revision which you used.4 L
'C5-9 What's Ie in Table 5-27 05-10 What's b mean in Table 5-3 following " leakage to containment billding."?
C5-11 Does the over 3 order of magnitude jump in the curies of particulates released in total particulates(75vs78) suggest overuse of filters as mentioned in Eeceny report?
C5-14 Table 5-8. Which of these items on TMIG2 were in line with the vent header whinh allowed the Xe to escape?
L Is there adequate monitoring on that item now?
~
4.
SEC 17.
IyW M. in Phila. just stated that the Rogovin Re/ port was just released. According to EYW AM, The Rogovin Report states that TMI#2 was within 30 th 60 minutes of a meltdown.
If the emergency measure had not been enacted in the limited
~
time and if a meltdown had occurred, would the filters and vent header been adequate or would even more inadequate and dangerous aberrations of these systems been evidenced?
In such a situation, would more gaseous effluents been loosed than were loosed in the actual accident on 3/28/80?
I have before me a letter dated 1-17-80 fro: Roh rt Reid to R.C. Arnold. It was delivered to me on 1-24-80. Thls 7
letter refers to "infor=ation of a type specified in 10 CFR f
2.790 (d) and should therefore be withheld from public disclos-ure."
I am not particularly involved with Safeguards continge ney Plan in this proceeding except where said not mmurns impings upon the design, use, plan nay or may the f<ers and the vent header.
or adequacey of involved in this proceeding with itemsNeither I am particularly rithheld from public
~
a disclosure"except where such items may of may not impinge upon the design, use, of adequacey of the filters or vent header.
How can I be sure that some inadequacey of the filters or vent header is not hidden or lost under the cloak of 100FR 2.790(d) 7 How can I be sure to trust the Staff that my and the public's health and safety will be adequately insured here items are hidden from public scrutiny by 10CYR 2.790(d)w?
How can I entrust a Staff with these points thich I cannot res-earch when I see people like Ronald J. Clary, NRC, and Marcia Mulkey,Esq., leaving allbring a residue of Tourte11otte's whose obvious. leaMnra are anti interrenor, to ' remain?
How can I trust the Staff to research those itens protected by 10CFR 2.790(d) adequately as far as vent headers and filters when the Kemeny Commisedion report states that the NRC is morej interested in licensing nuclear power plants than the health and safety of the public?
These are not rhetorkeal questions.
Under the rules I revuire written response specific to the question, and signed by t,he individuals working on the response.
1 NRC 19.
I just rensad " Status Report " dated 1-11-80, and i
I, erroneous called it SER in My questions 11 thru 14.
Is this status report an SER or not?
L If it is an SER, isn't the staff derelict to put out such an obviously inadequate and faulty SER?
( See my question on just.the vent header.)
5
=
I
5.
t NRC 20.
I have a letter dated Oct ??,1979 fron Stello to Arnold,SubVect: Investigative Report Number 50 320 /79-10 which was sent to me recently by the NRC Staff larfer add recieved 1-23-80. It was sent out 1-15-90 by Lucinda Low Swartz.
t I have a couple of questions on the penalties.
Was it a violation to operate TMI#2 with a cracked vent header?
If not, why not?
If so, where is the fine?
ERC 21.. This is not only an interrogatory ; but also, a partial answer to Staff's Interrogatories dated 12-27-79 numbers land 2.
I may have to restrict my expert testimonygbecause the s.,ount e
of material which I am receiving takes all my time to skin; let alone digest. I have very little time to prepare my es e.
I would like to make the following suggestions and see if it is acceptable to the Staff.
I need at least two witnesses or one knowledgeable in two areast Quality control or quality assurance Filters.
I guess that the staff is planning to present witnesses to assure that the filters and quality assurance at TMIf1 is
[
adequate which would rebut the Isewis Contention.
I wurW request that the names of these witnesses and the
. thrust of.their testimony be sent to me at the earliest
/ convenience.
I ah=11 then attempt to present~a great deal of my case thru cross examination.
Yould the Staff also send me some references or literature I
i used in the Federal system to familiarise me with cross-
_'.I eranination whih would be acceptable to the Board and not 1'.
a matter of continuous obVections.
Would you d.so supply me with the name of the engineer presently working on filters at THIf1 in Harley Silver's group? Same for vent header.
NRC 22. Fuel cladding defects produce routine radiological I
releases (Koshkonong PYR EIS)
The filters are sized or E
designed to taki care of routine radiological release. Are the filters at TMI!1 designed to take care of routine radiological releases if the fuel rods do not meet design requirements?
i
f Mar; vin I. Lewis 6504 Bradford Terrace i
Phila. PA 19149 1-29-80.
{
USNRC:ASL3: Docket No. 50-289,Three Mila Island #1 Restart Hearings.
+
, Continuing Set of Lewis Contention Interrocatories to Susnended Li-eensee, Metrotolitan Edisund or it successor concoration.
e SP 17.
Gilbert Associates have been doing a very fine jo) getting the updated amendments to.the Restart Report to me.
fhis is f
a large and complicated document. It would help me greatly if the pages were prepunched for the three ring binder which you so kindly provided.
SP 18.
I xx am particularly worried about two related issues:
Proprietary knowledge protected by Federal Law.
Safeguards issues. (10CPR 2.790(D)).
ThereisnowaythatIcanfindout11thereisanhdataabout filters
-vent headers or angthing else protected within these classifications from my discovery, f
ia r yn y In 1 mply Is there a way to alleviate my concern
.[
on these issues in this proceeding in a reasonable enam manner?
~f SP 19.
In the Radiological Data T,og Book, information is written in by hand. The information is recorded on Incident Message form NRC Control # R A~ 202.
On Form Number R-72 Item 2 there is a statement about a CAE Charcoal filter I_
from the aux liary building which was too hot to read.
Give me the history of this entryr i
When it was vtitten?
There specifically did this filter come from in the Auxiliary building?
What a,nAysis, if any, was dont to this filter. If not,
why.not?
e There are many questions which I have on this book. I am limiting myself to the above for ease and k-1 %
brevity.
Please attempt to clarify the purpose of this book, who is required to make entties, and where and when are these entries released and to whom.
i
2.
SP 20 On Page 91 er Metropolitan E?ison's Company's Statement in Reply to Notice of Violation. there are two entries:
9/78 78-175 2303 m15A/3 Control Room Emergency Ventilation syst em.
9/78 78-181 2322-Al Waste Gas and Unit vent Discharge
- unctional Test.
The titles of these entries suggest that they might have some relationship to the cracked vent header and the fil?,ers in the Lewis Contention.,
Is this true?
Can I get a copy of these "Sury. Proc. No. " and "Sury.
Rep. No."?
I as partleularly interested in the results of these particular tests.
I received the above document 9det Ed Statement in Reply to Notice of Yiolation " dated 5 Dec 79 on or about 23 Jan 80.
SP 21.
In the Restart Report on Page 7-15, Paragraph 7.3.5.2 Samule Drains the vent header la reed to isolate the an=111ary building from the radiochemical laboratory drains in a laboratory waste collection modifica tion.
Till this modification work as plaiined if the vent header is cracked at TmIf1 an it was cracked at EstIf 27 SP22.
Page C4-6 cc the Status Report dated 11 Jan EO and Page 7-11 Amendment 4 appear to depend upon each other heavily.
The Staff states that the Licensee will perform a helium leak test prior to the TMI E 1 start up and has perfocmed a pressure test on the TMIf1 gaseous waste processing' system.
Where in the Restart Report does the Licensee promise to do these tests?
How can I be sure that these tests are performed without undue bias by the technicians doing the test?
(Vested inte rest?)
Can I get the results and procedure of the pressure test referred to on ? age 04-6 by the Staff as done by the Licendee. Please send the if possible.
3.
SP 23. On page 7-13 of the Restart Report, there are tests t
to cualify and naintain Charc'oal and HI?A filters.
?lere these tests used at 7dI!2 and did -he filters allow the escape of radioisotopes above zix and beyond the allowables according to 10 CFR 50, 10 CFR 20, 10CFR 190 antway ?
Please elaborate.
Do you think tha6 preheaters will be needed to nake the filters. work better at TMI!1 in a repeat of the TMIp2 accident ? If not, why not? ~
SP 24.
In Section III D 2 b of the FESfor TMI, Page
}
III 14. Figure 11, which vent header at T2Ip2 was cracked; the low pressure or the high pressure?
Figure 10. Thich charcoal filteza were"too hot to measure *?
(See SP 19)
Which filter sets for Figure 10 do and do not have preheaters?
M T.
O
?
b
~
G e
I
g43%
IV g
!O
.oy &g f*"[*6-C 4
1
' Tr 3
./.
Y January 30, 198 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 " Continuing Set of Lewis Interrogatories to Staff" and " Continuing Set of Lewis Contention Interrocatories to Suspended Licensee",
which were hand delivered to Licensee at Washington, D.C.,
on January 29, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 30th day of January, 1980.
' Robert E.
ahler Dated:
January 30, 1980 9
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. Levin, Esquire Chairnun Assistant Counsel Atcmic Safety and Licensing Pennsylvania Public Utility Ccrm'n Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Camission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atamic Safety and Licensing 505 Fxecutive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chair:ran, Dauphin County Board Atcmic Safety and Licensing of Ccnrissioners Board Panel Dauphin Ccunty Courthouse 5000 Her:ritage Drive Frtat and Market Streets Paleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire
alter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Pegulatory Camission Office of Ccnsumer Advocate Washington, D.C.
20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section Office of the Secretary U. S. Nuclear Pegulatory Ccmrission Washington, D.C.
20555
i 2-i Jordan D. Cunningham, Esquire Karin P. Sheldon, Es @ e Attorney for Newterry 'Ibwnship Attorney for People Against Nuclear T.M.I. Steering Cam 1ittee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006
'Iheodore A. Adler, Esquire Widoff Peager Selkowitz & Adler Ecbert Q. Pollard Post Office Box 1547 Gesapeake Energy Alliance j
Harrisburg, Pennsylvania 17105 609 Montpelier Street Baltirere, Maryland 21218 f
Ellyn R. Weiss, Esquire i
Attorney for the Union of Concerned Gauncey Kepford Scientists Judith H. Johnsrud Sheldon, Har:en & Weiss Environmental Coalition on Ntriear
~
1725 Eye Street, N.W., Suite 506 Power Washington, D.C.
20006 433 Orlando Avenue State College, Pennsylvania 16801 Steven C. Sholly 304 South Market Street
- Parvin I. Lewis Mechanicsburg, Pennsylvania 17055 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 Gail Bradford Holly S. Keck Marjorie M. Aarodt Legislation Chair:ran R. D. 5 Anti-Nuclear Group Pepresenting York Coatesville, Pennsylvania 19320 245 West Philadelphia Street York, Pennsylvania 17404 5
- Person on whose behalf service is being made. Only Certificate of Service is enclosed.
i I