ML19309C124

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Response to Second Set of Interrogatories.Includes Info Re History of Incident Message Form R-72 Entry in Radiological Data Log Book
ML19309C124
Person / Time
Site: Crane Constellation icon.png
Issue date: 03/17/1980
From: Zahler R
METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Shared Package
ML19309C125 List:
References
NUDOCS 8004080200
Download: ML19309C124 (5)


Text

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M9rch 17, 1980 6

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEUSING BOARD In the Matter of

)

)

METROPOLITAN EDISON COMPANY

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Docket No. 50-289

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(Restart)

(Three Mile Island Nuclear

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Station, Unit No. 1)

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LICENSEE'S RESPONSE TO INTERROGATORIES (SECOND SET) OF MARVIN I.

LEWIS I

INTERROGATORY NO. SP-17 Gilbert Associates have been doing a very fine job getting i

the updated amendments to the Restart Report to me.

This is 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.

1

RESPONSE

See comments in cover letter.

INTERROGATORY NO. SP-18

[Is there any] way that I can find out if there is any data about filters, vent headers or anything else protected-within these (proprietary and safeguarded] classifications from my discovery?

Is there a way to alleviate my concern on these issues in this proceeding in a reasonable manner?

Response

Licensee is unaware of any information in Licensee's possession that could be characterized as " proprietary knowledge" or " safeguards issues" protected by federal law 8004080 2Od

. which is related to the Lewis contention and that has been withheld from disclosure.

In the event such a situation arises, Licensee would identify such documents and file a request that the materials be withheld from public disclosure pursuant to 10 C.F.R. Sec. 2.740 (c).

INTERROGATORY MO. SP-19 Give me the history of [the Incident Message Form Number R-72] entry (in the Radiological Data Log Book].

When was it written?

Where specifically did this filter come from in the Auxiliary building?

What analysis, if any, was done to this filter?

If none, why not?

[C]larify the purpose of this book, who is required to make entries, and where and when are these entries released and to whom?

Response

The referenced document was prepared by the NRC.

Licen-see is unable to locate documentation for the basis of the information contained within the NRC incident message.

1 INTERROGATORY NO. SP-20 Provide copies of the following:

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Date Surv. Rep. No.

Surv. Proc. No.

Title 3/78 78-175 2303-M15A/B Control Room Emergency Ventilation System 9/78 78-181 2322-Al Waste Gas and Unit Vent Discharge Functional Test Do these reports have some relationship to the cracked vent header and the filters in the Lewis Contention?

RESPONSE

The noted surveillance tests do not relate directly to

' 'the Lewis contention.

However, copies of the two surveil-lance procedures and the accompanying; quality control surveillance will be placed in Licensee's Discovery Reading Room.

The tests were performed as follows:

2303-M15A 9-26-78 Test satisfactory 2303-M15A 9-10-78 Test satisfactory 2322-Al 9-08-78 Test satisfactory INTERROGATORY NO. SP-21 In the Restart Report on page 7-15, paragraph 7.3.5.2 Sample Drains, the vent header is used to isolate the auxiliary building from the radiochemical laboratory drains in a laboratory waste collection modification.

Will this modi-fication work as planned if the vent header is cracked at TMI-l as it was cracked at TMI-2?

RESPCNSE The TMI-2 vent header was not cracked.

INTERROGATORY NO. SP-22 l

Page C4-6 of the Status Report dated Jan. 11, 1980 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-1 startup and has performed a pressure test on the TMI-1 gaseous waste processing system.

Where in the Restart Report does the Licensee promise to do sg these tests?

How can I be sure that these tests are performed without undue bias by the technicians?

RESPONSE

(a)

Licensee's commitment to perform a nitrogen pressure test on gaseous waste processing systems can be found in the Restart Report, Table 2.1-4.

(b)

Licensee is unaware of any " bias" by a technician that might influence the results of this test.

The

_4_

test is subject to appropriate controls to assure that it is performed properly.

(c)'

Documentation of the June 1979 test results will be placed in Licensee's Discovery Reading Room.

INTERROGATORY NO. SP-23 On page 7-13 of the Restart Report, there are tests to qualify _and maintain Charcoal and HEPA filters.

Were these tests used at TMI-2 and did the filters allow the escape of radioisotopes above and beyond the allowables according to 10 C.F.R. 50, 10 C.F.R.

20, 40 C.F.R.

190 anyway?

Please elaborate.

Do you think that preheaters will be needed to make the filters work better at TMI-l in a repeat of the TMI-2 accident?

If not, why not?

RESPONSE

The tests listed in paragraph 7.3.3.2 are to comply with the new Unit 1 technical specifications.

The full scope of this testing program was not required at TMI-2.

l The release and pathways of identified radioisotopes are described in TDR-TMI-ll6.

Preheaters are generally provided to ensure moisture 1

does not degrade charcoal filter efficiency.

Both the TMI-2 accident, and postulated design basis events, do not identify any basis for assuming moisture within process gas streams could significantly degrade charcoal efficiency.

Licensee, therefore, believes preheaters are not required.

INTERROGATORY NO. SP-24 In Section III.D.2.b of the FES-for TMI, Page III-14,

, Figure 11, which vent header at TMI-2 was-cracked; the low pressure or the high pressure?

[In] Figure 10, which charcoal filters were "too hot to measure"?

Which filter sets for Figure 10 do and do not have preheaters?

RESPONSE

There were no cracks in either header and only a few identified flange leaks in the low pressure header.

These flange leaks did not significantly addLto the release.

No charcoal filter listed on Figure 10 of the FES (Page B-25) was "too hot to measure".

There are no preheaters on any of the filters in Figure 10.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 7

By:

jr Robert

3. 'Zahler'-

Dated:

March 17, 1980 i

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