ML19296B990
| ML19296B990 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/28/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8002250011 | |
| Download: ML19296B990 (14) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s) 7 1 -, '
~~. :N k In the Matter of
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METROPOLITAN EDISON
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Docket No. 50-289 sj x
COMPANY, et al.
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(Three Mile Island Nuclear
)
Station, Unit No.1)
)
NRC STAFF RESPONSES TO INTERROGATORIES SUBMITTED BY MARVIN I. LEWIS Pursuant to 10 C.F.R. 52.720 and 10 C.F.R. 52.714, the NRC Staff has re-sponded to Marvin I. Lewis' Interrogatories to the Nuclear Regulatory Commission dated January 6,1980. Each Interrogatory not objected to is restated and a response provided. Following the responses is an unsigned affidavit identifying the individuals who prepared the responses. Signed and notarized affidavits will be provided in the near future.
INTERROGATORY No. 1 What actions in the Long term and Short term actions are specifically related to filters? Vent Header?
RESPONSE
The long 'erm and short term recommendations made in NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations,"
do not specifically relate to plant ventilation filters.
For the gaseous radwaste vent header however, the short term recommendation (Section 2.1.6a,
Integrity of Systems Outside Containment Likely to Contain Radioactive Materials) requires that tr.e licensee immediately establish and implement a program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids (gaseous radwaste vent header is included because gas is considered as fluid) during a serious transient or 8002250 O
. accident to as-low-as-practical levels. The recommendation further re-quires that the licensee provide a summary description of his program to the NRC for review and approval.
INTERROGATORY No. 2 How are the answers in NRC #1 specifically going to help the filters and vent header work correctly and adequately in a repeat of the March 28 accident at TMI #1?
RESPONSE
During the accident at TMI-2, the reactor coolant drain tank, in accordance with the design of the system, vented highly radioactive gases to the waste gas system vent header which subsequently leaked into the TMI-2 auxiliary building. The leakage is believed to have originated from the waste gas compressors and also from valves in the waste gas vent header.
It is also suspected that the makeup tank vent valve was leaking directly into the TMI-2 auxiliary building at the time of the accident.
The lesson learned in this case was that more positive control and knowledge of the leakage rates of the system is needed to provide the operating staff with information on operability of usable equipment to restrict or control the release of radioactive materials to the environment.
The solution recommended in NUREG-0578 is to make every effort to eliminate or reduce the leakage from the systems, perform periodic tests to assure that the leakage from these systems are maintained as low as practical, and provide the plant staff with current knowledge of the system leakage rates.
. INTERROGATORY No. 3 There is a large new filter on the auxiliary building at TMI #2.
In a repeat of the TMI #2 accident at TMI #1, would such a new filter be re-quired on TMI #17
RESPONSE
In a repeat of the TMI-2 accident at TMI-1, a new supplementary auxiliary building ventilation filtration system installed on the roof of the TMI-2 auxiliary building subsequent to the TMI-2 accident will not be required at TMI-1.
INTERROGATORY No. 4 If the answer to NRC #3 is yes, will such a filter of similar design of application be placed on TMI #1 before restart?
RESPONSE
The answer to interrogatory No. 3 is no and therefore, this interrogatory is not applicable.
INTERROGATORY No. 5 If the answer to NRC is no, explain why such a new filter will not be needed in a repeat of the TMI #2 accident at TMI #1.
RESPONSE
Subsequent to the TMI-2 accident, a new supplementary auxiliary building filtration system was installed on the TMI-2 auxiliary building vent exhaust.
This was done to provide additional capacity for removing airborne radio-active iodines. The originally installed activated carbon adsorbers were found to be less efficient than design rating for removal of radiciodine from exhause air during and after the accident. During the original testing
. of the TMI-2 auxiliary building filtration system prior to the accident (tests were performed during February 1978), the licensee experienced leakage through the bypass damper in the bypass line around the filters resultin'g in the pre-operational tests of the filtration system being unacceptable. After the leaking damper was temporarily sealed, the result of retesting of activated carbon adsorbers (March,1978) exceeded the requirements specified for decontemination efficiencies in Regulatory Guide 1.140, " Design, Testing, and Maintenance Criteria For Normal Ventilation Exhause System Air Filtration and Adsorption Units of Light Water-Cooled Nuclear Power Plants".
However, no subsequent decontamination efficiency tests were performed between the time the bypass line was semi-permanently sealed on April 1978 and the time of the accident in March 1979.
Since the TMI-2 auxiliary building filtration system was not an engineered safety-feature filtration system, there were no technical specification requirements to conduct retesting. The activated carbon adsorber material which had been installed to remove airborne radioactive fodines apparently became degraded losing part of its decontamination efficiencies at the time of the accident
- fter being in service continuously for almost one year.
The TMI-l auxiliary and fuel handling building filtration system is an engineered-safety feature filtration system to mitigate the consequences of postulated accidents by removing from building atmosphere radioactive material that may be released in the accident and therefore, the filtration system design is in accordance with Regulatory Guide 1.52, " Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants". Regulatory Guide 1.52 requires, among other things, testing of activated carbon adsorbers for decontamination efficiencies for
. every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation.
In addition, the TMI-l auxiliary building filtration system is not designed with bypass and bypass damper which caused leakage in the TMI-2 system.
We believe therefore, in a repeat of the TMI-2 accident at TMI-1, a new supplementary filtration system will not be required at TMI-l since de-grading activated carbon adsorbers would be identified and replaced periodically as required.
INTERROGATORY No. 6 Krypton-85 seems to be leaking unexpectedly according to Bob Arnold, Met-Ed.
Will any catchments or filters be placed on TMI #1 in order to reduce the leakage of Kr 85 after TMI 81 has a similar accident to TMI #2. Will this be done before restart? After another accident? When?
RESPONSE
The gaseous release of about 1 uci/sec (Kr-85) to the environment due to this leakage pathway has been less than a thousandth of the TMI-2 technical specification limit. Consequently, the resulting annual external dose to any individual in unrestricted area would be less than a thousandth of limit specified in Appendix I to 10 CFR 50 limits. We believe therefore, that no provisions for removing Kr-85 (gas compression, charcoal adsorption, and cryogenic process) from such a minute leakage pathway are required.
No filters are known to have the capability to remove noble gases (Kr-85) from gas stream at the present time.
-E.
INTERROGATORY No. 7 Where are the cracks which are allowing the release of Krypton 85 at TMI
- 2? Have these areas been inspected and repaired at TMI #17
RESPONSE
The leakage path is believed to be through steam valve packing in the main steam line inside containment. The steam valves will be visually inspected for leakage at TMI-1 prior to restart.
INTERROGATORY No. 8 List the isotopes which got out, when, how much (vol, and curies) by date and hour if possible.
If in the references, merely give page numbers.
RESPONSE
We have enclosed an Executive Summary of TMI-l and TML 2 radioactive liquid and gaseous releases as a result of the TMI-2 accident on March 28, 1979 continuing throughout October, 1979. The summary was prepared for the licensee by his consultant, Porter Gertz Consultants, Inc. of Ardmore, Pennsyl va nia.
INTERROGATORY No. 9 Using *able S-3, compare the allowables with the actual releases. Was the utility in violation? Is this violation specified in NUREG-0600 or Lessons Learned? Page Number?
RESPONSE
The Table, S-3, " Summary of Environmental Considerations for Uranium Fuel Cycle," in 10 CFR 51.20 has values of 400,000 Ci of Kr-85 and 0.83 Ci of I-131 normalized to model LWR annual fuel requirement or reference reactor year. These values set forth ir. Table S-3 are for use in evaluating the contribution of environmental effects from uranium fuel cycle excluding reactor operation. The executive summary of radioactive liquid and gaseous releases enclosed in response to Interrogatory No. 8 indicates a release of approxi-mately 10 million curies of noble gases (xenons and kryptons) and 14.7 curies of iodine-131 through October,1979. We do not have a separate release data for Kr 85 alone.
The licensee was in violation of 10 CFR 20.106, " Radioactivity in Effluents to Unrestricted Areas," and the TMI-2 Technical Specifications. This violation was specified in Appendix II-l to NUREG-0600 as a potential item of noncompliance (page 11-16, item G).
The NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations," does not specify this violation because it was intended to make recommendations in the areas of design and analysis and plant operations to provide additional protectior for public health and safety and was not intended for investigation of the accident specifying the licensee's potential violations.
-ed
. INTERROGATORY No. 10 Contact suspended licensee and stato if you agree or disagree with his answers to Lewis Interrogatories.
RESPONSE
The NRC Staff objects to this Interrogatory as being burdensome and improper.
Respectfully submitted,
- 7,/i,
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~, ' l l' Lucinda Low Swartz
-f Counsel for NRC Staff Dated at Bethesda, Maryland this 28th day of January 1980.
s The answers to Marvin I. Lewis' Interrogatories 1-9 were prepared by us.
We certify that they are true and correct to the best of our knowledge.
Jay Y. Lee Senior Nuclear Engineer NRC/TMI Technical Support Staff ONRR/NRC John T. Collins Deputy Director NRC/TMI Technical Support Staff ONRR/NRC Sworn and subscribed before me, a Notary Public in and for the County of Dauphin, Commonwealth of Pennsylvania, this day of January 1980.
My Commission expires
Page ; of 3 EX20CTI*.'E SiHMARY e
THREI H:LI ISLAND UN'TS I and I! LIQUID and SASEOUS RELL\\SES
'st In c id en-2nd Quarter Feriod 7:arter 1/1/79 to 3/25/79 o 4/1/75 to 5/1/79 to 6/:/79 to L/'./79 to 8 DISCEARGE PATEWAYS 3/31/73 3/31/79 4/ 3/79 5/3;/79 6/30/79 5/30/79 d
cr;;p I.
Li uid heleased:
W, ggij a) Dischary.c less Tritit.m:
'. ) Ceri:tr.t ret ic:t ('-Ci/cc) 1.29E-6 (s) 7.442-3 !a)
. 75E-7 (a) 2.dcE-S (a) 2.842-S (a) 6.62E-S (.
t
@jy[$
- 2) Totr.1 Ac-iv:ty (01) 0.27700 (b) 1.0}E-1 (S)
. 6200 (b) 2.21E-1 (b) 1.622-1 (b) 2.C21C (b (d=D,
~
5)
Ind ir.e-13 ~. ReletscJ :
hg
- 1) Concen ratio: (pC;/cc) 4.972-9 (a) 7.16E-S (a) 1.73E-a la:
2.25E-9 (c}
5.63E-lC.(c) 7.57E-9 (.
gg{zs
- 2) !stal A-tivity (Ci!
0.;37E3 9.02L-2 1.572-1 1.72E-2 3.73E-3
. 7 d E '.
Cg b
c) Tr t-itra Eeleased:
$Eb,
Cor.tcr.trr.t len ('.01/ce)
A.53E-6 (a) 5.13E-7 (a)
G.LSE-7 (a) 7.C52-7 (a) 4.60E-7 (a) 6.771-7 (
- 2) Tctcl Ac-ivity (01)
- C4. t ?.0 3.65E3
?.33LO 3.JSEC 3.C423 1.552'.
Airbcrne ladir.e Released:
c) Quarterly Re case Eate ( Ci/sec) 5.57.-l 5.8E.
1.23E3 9.29E-3 2.;2E-5
'. 22EC S) Tc al Io:ine-13~. Released (01) 4.57I0 4.57E0 9.tSIO
?. 67.- 2 1.67E-4 S.6IC
- .. ' sob:c Ctses 2eleases-s) Quar erly Rtleast Tate (Cl/se:)
1.12E3
- 1. ' 2 7.C 1.41E _
. 5 E-t 9.5E-5
. 4*.E *.
'C Tctel Ncble Caner. 3eletse-1 (C;;
S.33T6 8.3305
- 1. *.1 T.6 1.?2F3 7.30E2
- 1. I ' E6 ff TC0rNOT:5:
- a. ) Ccr.ce-trttiens att based upon actual :DCT f;cus. These. cre canceatra: Lor.s in LSe ef fluen: averc2ed over the perlad.
S Tr. s da t e. f r.cl e:'.c s !c c' a e -i 31 r t'_ ca s ei t o tSe 9:si.uer.anr.a 7;ver as o regult cf the TVI Unt: I: ace:de.t aa
a r c'r. 2.9. 19 7 9.
? age 2 cf 3 EXECUTIE S~.YMARY TEREE. VILE '.S:.ANIl UNI S ! and 11 1.IQ 1D ar.d GASE3 S 3El. EASES
__. j}
3rd Quarter
,. : ;7J 7/1/79 to 8/1/79 to 9/1/79 to 7/1/79 to
[ M,
O!!CHARCT. PA!!NAY3 7/3!!79 d/3.'/79 9/3C/79 9/30/79 c_
@cS 1.
Liquid P.eleasei:
c - =n (RP~'
E 3 a) Cischt.56e less Tritic.m:
0~~3)
.)
C:>ncen: ratio-. (p:'t/tc) 1.I22-a (a) 2.66~.-5 (a) 2.322-9 (a) 5.18E-9 (a) 2)
Tota'. A:tiv ty lCL) 7.852-2 (b)
. 39E-2
. 13E.
.%w b)
Icdine '.31 Releas ed :
(=q
- 1) Concentra: lor (9Ci./cc)
- t. 57E-13 (a) 9.lOE-;l fa) 9.62E-il (a) 2.37E-10 (a)
{
- 2) 70:9;..ctiv! y (CO 3.2CE-3 6.4 6 E-!.
- 6. 59 E-l.
4.512-2 c) Tri:Lu-3eleasei;
.)
Ocnc er.trat !::t ( l/ c)
- 7. 2 3':-7 (a 3.202-7 (a) 3.342-7 (a) 4.53E-7 (t) 2)
tr.1 A::ivity CL) 5.042C
- 2. 2 ? ?.C 2.5520 9.86EC
- 1.
Airbc:r.e icdine 3eler.sei:
a; Quarterly Xelcue 3 ate ('.~:l/sec)
. 58E-6 WDA WDA 1.552-6 b) Tcte.1 !cci e-131 Realeese (Ci; 1.24S-5 WDA EDA
- 1. 2 I.E-5 II!, Noble Cases Releasel:
a) Qur.r t'crly Eclease T. ate (CL/s ec}
- 1. 27 E.~
1.14E-5 8.68E-6 3.332-5
- )
Tott1 Nc'21e Cases 3eleased (::1)
'. 3C 93 73 263 2
100:5CTES:
a) Ccucentra-lo.1 are base:' u.'o. a:tua; FDC: t 1% 9.
These are center.tre.ttons in ti.e eff'.uent averagei cver the pericd
- )
This itta I n t l u :' r s :>i. i : e - 13 ! r e l c es ed to t'ie S u sq ue'.u nt.a R i. c r a s a r e s.ul t of t*ie TNI L~ nit II accident on
' I'.c r ci. 2 5, *379.
Oe
Page 3 of 3 EXECUTIVL
SUMMARY
TEREE MILE ESLAND UNI!S : er.d 11 L:QU:3 and GASEOUS RELEASES 4th Quartee
- C/'/79 to 11/1/79 to 12/!/79 to 13/1/79 :o CISCEARGE PATWAYS ir/3!/79 11/30/79 12/31/79 12/31/73 M.,,)
I.
LLgs.id acleased:
e c' m EL-J a
isc'.arge less Teitium 6Sb5)
- 1) Caicentrattor. ( Ci/ct) 1.252-9 jfhjf
- 2) Total Activity (Ci; 9.23E-3
=u Acr" h) iciir.c-13! 3clensci-Ocncer.tration l Ci/cc) 4. B ~ 2 -l '.
@53$$
- 2) Tc:al.Ac:ivity (01).
3.62E-i c>
Q _ :)
(@
c) Tr:. tat Etieastd :
{gg
- 1) Conect: ratio- ( Ci/cc) 7. 5 '. r.- 7 2)
Tota..*.ctivity (C1) 5.6LE3 d) N3CT.7;ov For Man-t. (:c 7.412-12 I:. Air:ocne Iodlue F.eleased:
t) Cutrterly Reicase F. ate ( Ci/sec) <PDA 5
Tctal Ic/ir.e-131 r eleased (CL)
<M]A III. 5cb1c Cases.Relemaco:
a) quarterly Eclease liate (OL/ set)
- 9. 5 '. E-6 S: Tc a1 Nchle Gas =s released (Ct 75 700!N0??s:
- r. ) Co ec7:ra tiens are tcste upon ac ud.1113CT f tcus. These are concentrations in the ef flues; average 3 over the pericd.
l
UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION BETORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL.
)
Docket No. 50-289
)
(Three Mile Island Nuclear Sttrien,
)
Unit 1) :
~
)
a CERTITICATE OF SERVICE 6
I hereby certify that copies of NRC STAFF RESPONSES TO INTERROGATORIES SUBMITTED BY MARVIN I. LEWIS in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 28th day of January 1980.
Ivan W. Smith; Esq.*
Mr. Steven C. Sholly Atomic Safety and Licensing Board 304 South Market Street U.S. Nuclear Regulatory Commission Mechanicsburg, PA 17055 Washington, DC 20555 Mr. Thomas Gerusky Dr. Walter H. Jordan Bureau of Radiation Protection 881 m'.' Outer Drive Department of Environmental Oak Ridge, TN 37830 Resources P.O. Box 2063 Dr. Linda W. Little Barrisburg, PA 17120 5000 Hermitage Drive Ealeigh, NC 27612 Mr. Marvin I. Lewis 6504 Bradford Terrace George F. Trowbridge, Esq.
Philadelphia, PA 19149 Shaw. Pittman, Potts & Trowbridge 1800 M Street, N.V.
Metropolitan Edison Company Washington, DC 20006 ATTN:
J.G. Herbein, Vice President f
Karin W. Carter, Esq.
P.O. Box 542 505 Executive House Reading PA 19603 f
P.O. Box 2357 Harrisburg, PA 17120 Ms. Jane Lee R.D. f3, Box 3521 Honorable Mark Cohen Etters, PA 17319 512 E-3 Main Capital Building Harrisburg, PA 17120 Walter W. Cohen, Consumer Advocate Department of Justice Strawberry Square, 14th Floor Harrisburg. PA 17127
Holly S. Keck Anti-Nuclear Group Representing York 245 W. Philadelphia Street York, PA 17404 John Levin, Esq.
PA Public Utilities Commission Box 3265 Harrisburg, PA 17120
. Jordan D. Cunningham, Esq.
Robert Q. Pollard Fox, Farr and Cunningham Chesapeak Energy Alliance 2320 North 2nd Street 609 Montpelier Street Harrisburg, PA 17110 Baltimore, MD 21218 Theodore A. Adler, Esq.
Chauncey Kepford Widoff, Reager, Selkowitz & Adler Judith H. Johnsrud P. O. Box 1547 Environmental Coalition on Harrisburg, PA 17105 Nuclear Power 433 Orlando Avenue Ms. Ellyn R. Weiss State College, PA 16801
. Sheldon, Harmon, Roisman & Weiss 1725 I Street, N.W.
Ms. Frieda Berryhill, Chairman Suite 506 Coalition for Nuc1 car Power Plant Washington, DC 20006 Postponement 2610 Grendon Drive Atomic Safety and Licensing Board Panel
- Wilmington, DE 19808 U.S. Nuclear Regulatory Co= mission Ms. Karen Sheldon Washington, DC 20555 Sheldon, Har=on, Roisman & Weiss 1725 I Street, N. W.
Atomic Safety and Licensing Appeal Suite 506 Panel (5)*
L*:rhington, DC 20006 U.S. Nuclear Regulatory Co= mission Washington, DC 20555 Ms. Marjorie M. Aamodt R.D. #5 Docketing and Service Section (7)*
Coaterfille, PA 19320 Office of the Secretary
.U.S. Nuclear Regulatory Commission Washington, DC 20555
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lA ucinda Low Swartz C/
Counsel for NRC Staff M '.