ML19294B981

Second Set of Interrogatories Directed to Licensee.Inquires Whether Recommended Short & long-term Measures Will Reduce Possible Void Formation.Includes Questions Re Natural Circulation & Failure of Relief Valves

ML19294B981
Person / Time
Site:	Three Mile Island
Issue date:	02/25/1980
From:	Weiss E SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	METROPOLITAN EDISON CO.
Shared Package
ML19294B980	List: ML19294B979 ML19294B981 ML19294B984
References
NUDOCS 8003060494
Download: ML19294B981 (3)

Text

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UNITED STATES OF AMERICA '-

NUCLEAR REGULATORY COMMISSION g(h d --

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD + p In the Matter of ) A

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1 )

UNION OF CONCERNED SCIENTISTS SECOND SET OF INTERROGATORIES TO LICENSEE Please use the same instructions as those given in UCS's firs t set of Interrogatories to the licensee.

179. The licensee has stated that it does not yet have final positions on the merits of the UCS contentions. Please provide the licensee's cresent position on each UCS contention.

180. With reference to your answer to UCS Interrogatory

1. 7, which of the short or long term measures recommended by the s taf f and to be implemented by licensee "will reduce the likelihood of void formation?" Explain the bases of your response.

18 1 . Using your definition of " natural circulation" as given in response to UCS Interrogatcry n6, identify which of the short or.long term measures recommended by the staff and to be implemented by licensee will prevent or reduce the likeli-hood of loss of natural circulation. Explain the bases for your response.

18 2. Is it the licensee's position that the consequences of the TMI-2 accident with respect to a) core damage, b) fuel 80030604 M

damage and c) safety system performance fell in all cases within the limits permitted by NRC regulations ?

18 3. If your answer to No. 182 is that this is not the licensee's position, identify the particular equipment failures and/or consequentes which exceeded limits. permitted by NRC regu-lations and specify the regulations considered. In addition, explain the manner in which the limits were exceeded.

184. What measures have been or will be implemented prior to restart to prevent recurrence of any equipment failures and/or consequences identified in the answer to No. 183.

18 5. In response to UCS Interrogatory e46, the licensee states that failure of power operated relief valves, associated block valves, instruments and controls cannot aggravate the consequences of a LOCA beyond that " submitted in the referenced analysis." The referenced analysis are primarily pre-TMI. Is it the licensees position that the consequences of the accident at TMI-2 were no t "beyond that submitted in the referenced an alys is ?"

18 6 . If this is not the licensee 's position , identify which specific failures were the cause of consequences "beyond that submitted in the referenced analysis."

18 7. Which of the short and/or long term measures will prevent future accidents in which the consequences are "beyond that submitted in the referenced analysis ?"

18 8 . With respect to UCS Interrogatory n69, is it the licensee's position that the provisions of IEEE 279, S4.8, as

incorporated in 10 CPR 50.55a(h) do not apply to TMI-l? If this is your position, explain it fully.

Respectfully submitted,

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Ellyn R. Weiss SHELDON, HARMON & WEISS 1725 I S tr ee t , N.W.

Suite 506 Washington, D.C. 20006 (202 ) 833-9070 General Counsel for the Union of Concerned Scientis ts DATED: February 25, 1980