ML19309B996
| ML19309B996 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/01/1980 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Sholly S AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19309B998 | List: |
| References | |
| NUDOCS 8004080019 | |
| Download: ML19309B996 (16) | |
Text
,...
NRC 04-01-80 UNITED STATES OF AMERICA I;UCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In-the Matter of
)
)
METROPOLITAN EDISON COMPANY,
)
(Three Mile Island Nuclear
)
Station, Unit 1)
)
NRC STAFF'S ANSWERS TO SH0LLY'S FIRST SET OF FOLLOW-0!1 INTERROGATORIES The NRC Staff's answers to Intervenor Steven C. Sholly's "First Set of Follow-on Interrogatories" are attached.
The affidavits of the persons who prepared the answers are included.
Respectfully submitted, h
%Q mw.=
James M. Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Maryland, this 1st day of April,1980.
8 004 080C lf
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.In the Matter of.
METROPOLITAN EDIS0N COMPANY, et al.
Docket No. 50-289 (Three Mile Island, Unit 1)
)
AFFIDAVIT OF RICHARD L. BANGART I, Richard L. Bangart, being duly sworn, do depose and state:
1.
I am the Leader of the Systems Analysis Section in the Effluent Treatment Systems Branch, Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation, of the United States Nuclear Regulatory Commission.
I am responsible for the technical supervision of safety reviews of radioactive waste management systems for nuclear power plants. My professional qualifications statement is attached.
2.
The responses to Steven C. Shelly Follow-on Interrogatory to Response to Ques-tion 1-4 was by me.
I certify that the information given is true and accurate to the best of my knowledge.
kass
. $annf Richard'L Bangart "
j Subscribed and sworn to E
efore me this 3/ day of
/ A) tLul
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//
My Commission expires:
- W Notary Public f(/
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PROFESSIONAL QUALIFICATIONS Richa,rd L. Bangart Effluent Treatment Systems Branch Division of Site Safety and Environmental Analysis Office of Nuclear Reactor Regulation My name is Richard L. Bangart.
I am the Leader of the Systems Analysis Section in the Effluent Treatment Systems Branch, Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation..I majored in mathematics and physics at Willamette University, Salem, Oregon and was awarded a B.A. degree upon graduation in 1965.. My graduate study was done at the University of Michigan where I was award-ed a M.S. degree in Environmental Science in 1966 and a Master of Public. Health (M.P.H.) in Radiological Health upon graduation in 1967.
-From 1967 to 1968 I was a technical intern at the U. S. Atomic Energy Commission's Nevada Operations Office.
In 1968 I transferred to the Health Services Laboratory (National Reactor Testing Station), Idaho Operations Office, U..S. Atomic Energy Commission. My duties there as a health physicist included conduct of radiological environmental monitoring programs, applied research on the behavior of radioactive noble gases and radiciodine in the environment and their pathways to man, develop-ment of emergency plans, and management of the waste burial ground.
I joined the regulatory side of the Atomic Energy Commission (now the Nuclear Regulatory Commission) in 1973. As a radiation specialist in the Region'IV office, I inspected the health physics, environmental monitoring, and waste management pro-grams'of byproduct material, uranium milling, and uranium conversion licensees for compliance with applicable regulatory requirements.
In 1975 I joined the U. S.
Nuclear Regulatory Commission's (NRC) Region II, Inspection and Enforcement office as the Chief-of the Environmental and Special Projects Section, Fuel Facility and Materials Safety Branch.
In that capacity I provided technical supervision for seven professionals conducting inspections of nuclear power reactors and fuel faci-lity waste management, radiological and non-radiological environmental monitoring, and emergency planning / preparedness programs.
I joined the Effluent Treatment Systems Branch in 1977 as the Leader of the Systems Analysis Section.
In this position I am responsible for the technical supervision of the reviews of nuclear power plant radioactive waste management systems and the calculations of radioactive effluents released to the environment.
I also have technical supervising responsibility.for the determination of the adequacy of instru-mentation provided for monitoring radioactive discharges from nuclear power plants.
In addition, I supervise the generic evaluations and development of criteria related to the generation and control of radioactive effluents.
I have participated in the preparation of staff reports related to effluent control technology and effluent monitoring.
=..
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Intervenor Steven C. Sholly First Set Follow-on Interrogatory to' Response to Question 1-4 This interrogatory requested an estimate of the amount of radioactivity re-leased to the' environment as a result of the failure of containment isolation to
. occur when there was a high. level of contamination in the reactor sump line. The Staff implies that the-interrogatory implies that a large quantity of radiation was released as a result of this set.of circumstances, and states, "Most of the radioactivity released resulted from' letdown line leakage in the auxiliary building and was not a result of failure of containment isolation..." The interrogatory makes no reference whatsoever to releases due to makeup-letdown system activity during the accident. The interrogatory very clearly asks for an estimate of the radioactivity which was released due solely to late containment isolation. Again, the interrogatory is posed:
Has Staff estimated the quantity of radiation released to the environment as a direct failure of the Unit 2 contain-ment to isolate and prevent pumping of the reactor building sump to the auxiliary building?
If so, provide this data.
Response
No quantitative estimates have been made to our knowledge, of the amount of radioactive material released to the environment as a result of the pumping of water from the reactor building sump to the auxiliary building. No compelling reason has existed for. making this estimate since no core damage hadloccurred uat the time of transfer.of this water and the quantities of radioactive material in the water were very small when compared to the quantities in the reactor coolant system water after core damage occurred.
- l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of
)
')
METROPOLITAN EDIS0N COMPANY, et al.
)
Docket No. 50-289~
)
(Three Mile Island, Unit 1)
)
AFFIDAVIT OF WALTER J. PASCIAK I, Walter Pasciak, beino duly sworn, do depose and state:
1.
I am an Environmental Scientist in the Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission.
I am responsible for reviewing radiological environmental matters of assigned nuclear power plants, including Three Mile Island, Unit 1 Restart Program.
2.
The answer to the Sholly follow-on interrogatory 5-1 was prepared by me.
I certify that the answers given are true and accurate to the best of my knowledge.
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WalterPahciak Subscribed and sworn to beforemethiskh'ayof
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8 Nota /yPublic
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/, Y$$ Y My Commission expires:
9 i
Follow-on ~ Interrogatory To Response to Question 5-1 In response to Question.1-4, Staff states 14 curies of I-131 were released during the entire accident. -Yet in the response to Question 5-1, Staff cites the
. maximum release rate for iodines on March 30th as being "about 20 Ci/sec".
a.
Is the 20 Ci/sec figure' correct?
b..
If so, how does Staff reconcile this with the total estimated I-131 release figure given-in response to Question 1-4?
c.
What was the isotope' makeup'of the 20 Ci/sec release rate?
Response
The 20 C1/sec figure is correct.
The release rate of iodine varied over the time period it was being released. The 20 Ci/sec represents the maximum rate (the average rate would be significantly less).
The amounts of iodine released for specific time periods are described'in an attachment to an NRC memorandum from R. C. DeYoung to W. E. Kreger, " Calculated off-site iodine-131 air concentrations from Three Mile Island," October' 3,1979 (enclosed). The 20 Ci/sec was estimated based on the -information in this memorandum and is for I-131 releases.
1
- v
_3 1-131 RELEASES
\\
1 TDP-TMI-ll6
" Assessment of Of fsite Radiation Doses From The
!;ource of Data:
Three Mile Island Unit 2~ Accident,"
July 31, 1979.
~
Actual measurements from the charcoal cartridge at HPR-219 are used wherever possible. When these data are not available, linear interpolation is used
- from the surrounding time periods that would maxiinize the release.
An asterisk indicates which releases were calculated in this manner.
Time Period Curies I-131 Released Total Curies 1-131 From 3
For Time Period Released from Accident 0400 3/2S 1900 3/28 O.22 (I) 0.22 1900 3/23 1900 3/30 3.90 4.12 1900 3/30 2200 3/30 O.49
- 4.61 2200 3/30 0600 4/1 0.31 4.92 0600 4/1 0315 4/3 1.57 6.49 0315 4/3 1905 4/3 0.13 6.62 1905 4/3 2232 4/3
?
0.09 6.71 2232 4/3 1830 4/5 1
1.15 7.86 1830 4/5 1516 4/6
/-
0.03 7.89 1516 4/6 0600 4/7 O.36
- 8.25-0600 4/7 0245 4/8 t
0.51 8.76 0425 4/9 1.17 9.93 0245. 4/8 II) Based'on auxiliary and fuel handling building release rates.
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- e 0425~ 4/9 0925 '4/9 0.23
- 10.16 10.21 0.05 0925 4/9 1608 4/10
'1603 4/10 1840 4/11 0.12 10.33 1840 4/11 1920 4/11-O.01
- 10.34 1920 4/11 2315 4/13 0.39
'10.73 2315 4/13 1030 '4/14',
0.24
- 10.97 1030 -4/14 1915 4/14 V
0.19 11.16 1915 4/14 0522 4/15 0.24 11.40 0522 '4/15 0304 4/15 0.08 11.48 0504 4/15 1802 4/15 0.51 11.99 1802 4/15 2140 4/15 0.09 12.0E 2140 4/15 2346 4/15 O.05 12.13 2346 4/15 0408 4/16 0.10 12.23 0405 4/16 0755 4/16 0.08 12.31 075S 4/16 1156 4/16 0.07 12.38 1156 4/16 1550 4/16-0.05-12.43 1556 4/16 1810 4/16 0.09 12.52 1810 4/16 2356 4/16 0.13 12.65 2356 4/15 0402.4/17 0.04-12.69 0402 4/17' 0235 4/17 0.05 12.74 0535 a/17
'1226 4/17 0.03 12.77 1225 4/17 1634 4/17 0.03' 12.80 16 0
/17 19a6 4 / '. 7 C.06' 12.56 i
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' Tim ocriod Curies I-131 Released ic:al Curies 1-131 fre -
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0320 4/21 0402 4/21 0.03 13.9S-
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0.02 14.00 0319 4 4/21-1201 4/21 0.02' 14.02-
'1'204 '4/21 1624.4/21
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0103 4/22 0.03 14.09 0105' 4/22 0441 -4/22 0.02 14.11 0447 4/22
-0304 4/22 0.02 14.13 0307 4/22 1229 4/22 0.02 14.15 1230 4/22 1621 4/22~
0.03 14.18 i
'1624 4/22 2024 4/22 0.04 14.22 2036 -4/22 2130 4/22
.4 0.00 14.22 l
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-0.03 14.25 j~
--0007 4/23 0406 4/23 0.03 14.23 8
i 0352 4/23 0758 4/23 0.02 14.30 0501 t/23 1201 4/23 0.02 14.32 l-1223 4/23
- 1614 4/23 0.05 14.37 l
'1617 a/23 2010 4/23 0.01 14.38 2014 -4/23 2156 4/23 i?
0.01 14.39
_2159E 4/23' 0015 4/24 0.01 14.40 10004 4/24 0404-:4/24 0.02 14.42 f
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J Curies 1-131 Released Total Curies 1-131 Tire Period Fre-3 For Time Perioc P.eleased fro-Accident 0000. 5/3 0000 5/4' O.01.
- 14.78-0000 5/4 0000 5/5 0.01 14.79 0000 5/5
'0000 5/6 0.01:
14.80 0000 5/6 0000 5/7 0.01 14.81 0000 5/7 0000 5/8 Neg.
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All Further Releases Negligible.
Stack Casped May 20, 1979.
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i UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
).
METROPOLITAN EDIS0N COMPANY, _et_'_a_l_.
Docket No. 50-289
)
(Three Mile Island, Unit 1
)
AFFIDA/IT OF JACK R0E I,~ Jack Roe, being duly sworn, do depose and state:
1.
I am a Emergency Preparedness Analyst, Office of Nuclear Reactor Regulation of the United States Nuclear Regulatory Commission.
I am responsible for
. reviewing the emergency planning of assigned nuclear power plants, including Three Mile Island, Unit 1 Restart Program.
2.
The answers to Sholly Follow-On Interrogatories 8-1, 8-2, and 8-4 were prepared by me.
I certify that the answers given are true and accurate to the best of my knowledge.
db Subscribed and sworn to before me this2/Nay of 777aut
/PPz.
h La J$h l Notary Public b@
'My Commission expires:
g a
9
Follow-on Interrogatory to Response to Question 8-1 This. question asked the Staff whether it felt that Licensee's Emergency Plan can be fully evaluated without reviewing the Emergency Plan Imple-menting Procedures.
Staff answered, " Prior to restart as part of the
. long-term program the Staff will review the Emergency Plan Implementing Procedures."
This does not answer the question.
Intervenor Sholly requests that Staff answer the original question and explain its answer. Also, Staff's response prompts the following interrogatory:
a.
Why does Staff consider the Emergency Plan Implementing Procedures to be a "long-term" item? Specifically address the issue of whether the Emergency Plan can be expected to protect the public helath and safety if the Emergency Plan Implementing Procedures are inadequate.
Response
The Licensee's Emergency Plan can be fully evaluated without reviewing the Emergency Plan Implementing Procedures.
However, the Licensee's integrated emergency preparedness program can not be fully evaluated without reviewing the Emergency Plan Implementing Procedures.
The Emergency Plan can not be expected to protect the public health and safety if the Emergency Plan Implementing Procedures are inadequate.
The procedures implement the details of the overall concept of operation and the elements of advance planning.
The procedures will continue to develop as the plan changes to. meet the long term program in accordance
. with the-requirements of the final version of the proposed rule (44FR41484) on emergency planning.- The procedures must incorporate these changes and are therefore _directly associated with the long term program.
Follow-on Interrogatory to Response to Question 8-2 This interrogatory asked Staff if the Emergency Plan submitted by the Licensee contains sufficient information about the Ingestion Exposure EPZ.
Staff responded, "The ingestion exposure EPZ is part of the long-term program and outside the scope of the Commission's Order."
Contention 8, subparts "N" and "U" deal with the ingestion exposure EPZ and by their nature challenge tha necessity and sufficiency of the Commission's Order.
Staff should have raised objections to these subparts of Contention 8 when it was submitted, not now.
These subparts have been accepted by the Board and are therefore ripe for discovery.
The Staff's response does not address the original question.
Intervenor Sholly requests that Staff respond to the original interrogatory.
That interrogatory did not requests that the Staff discuss whether the ingestion EPZ was covered by the Commission's Order as a short or long term item, but rather requested an assessment from the Sta'ff as to the sufficiency of
. Licensee's discussion of the ingestion EPZ in the Emergency Plan.
Response
The Licensee's Emergency Plan 'contains sufficient information about the ingestion emergency planning zone.
Follow-on Interrogatory to Response to Question 8-4 The ' interrogatory requested Staff to assess whether Licensee had sufficiently s
a -
. justified the choice of a 10-mile. circular EPZ for Plume Exposure in Licensee's Emergency Plan.
Staff responded, "The Licensee has selected a plume _ exposure EPZ that meets the objectives of.NUREG-0396 and the Commission's Policy Statement of October 18, 1979."
Intervenor Sholly finds this answer vague in that Staff was requested to explain the answer.
The following interrogatory is therefore posed.
Has Licensee, as per NUREG-0396, taken adequate note of local a.
conditions such as demography, land use, transportation routes, and local jurisdictional boundaries in the selection of a 10-mile circulate EPZ for plume exposure? Specifically address in your answer the fact that this proposed EPZ passes through the city of Harrisburg, and the fact that TMI has the 4th largest population within 10 miles of all licensed reactors in the U.S.
Response
The Licensee's selection of the 10 mile EPZ is discussed in section 4.2.1.5 of the Emergency Plan.
The selection of the EPZ considered the jurisdic-tional boundaries of Harrisburg. The Staff finds the 10 mile EPZ acceptable.
6
_. -. -.