ML19318A947
| ML19318A947 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/17/1980 |
| From: | Lochstet W AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006240422 | |
| Download: ML19318A947 (2) | |
Text
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~m f4 United States of America Nuclecr Regulatory Commission C00h$
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.JUN 2 01980
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Sefore The Atomic Safety and Licensing s,oardg ctedB t=:"n, m g se,-ge Esad In the Matter of
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'l %TI METROFOLITAN EDISON CO'TANY, ET AL.
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(Three rile Island Nuclear Station, Unit 2)
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Docket No. 50-320 OLA
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Supplement to Request for Hearing and Petition for Leave to Intervene The following are my contentions in this matter.
Contention 1 The Nuclear Regulatory Commission (NRC) ha s snecified certain modifications to the Technical Specifications for Three Mile Island Unit 2 ( TII 2) in its appendix to 11 February 1980 order ( summarized at the 45 FR 11282 ). Section 2.1.3 suecifies a maximum Reactor Coolant System pressure of 2750 osig.
It is contended that this is too high a pressure This was a proper maximum pressu e for normal operation before 28 March 1979.
The events of the accident have subjected the gpa ctor pressure vessel and extragdinary conditions ( a associated components to s temperature) which are somewhat unknown, and whose effect.cn the largely unknown.
strength of these carts is Since the parts are not a the design tressure is no longer valid.
s designed, any longer, Contention 2
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Section 3.3.3 recuires t!'ct one Source Rande and one Intermediate Range Neutron monitor be operable. The action 0
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c: tion renuires that if one tonitor fails that it should
'e restored in 7 days.
It also provides for tha situation c
vdth no channels operating.
It is contended that this recuirenent is too lenient.
Under the cresent conditions it is contended that safety would reauire the oneration of at least one Source range or Intermediate Range monitor.
O should be noted that there are two monitors of each type installed.
Given the present state of knowledge of the core condition, it is-necessary to monitor the neutron flux to be assured tha t the core does not re-configure itself or change in some unexpected way.
Con'tention 3_
Sect 6on 3.6.1.4 of the appendix to the 11 Feb. 19F0 order specifies the operating pressure for t he containment.
It is contended that this reouirement does not prevent the seepare of water containing radioactivity thru the lower nortions of the containment.
Due to the depth of the water, the bottom of the containment is under positive pressure, The welds in the metal membrane centainment liner were not expected to be cerfect. Ek?.
Thus, licuid can escape.
This represents a new unmonitored release to the environment, vhich was not considered in the Final 2nvironmental Assessment at t he operating license stage.
This is in fact a new release ( since 28 I': arch 1979 ) which is not directly authorized by the new Technical Soecifications, but is a consecuence of them and the cresent situation.
It is further contended that this may be sufficient ton recuire and environmental intact statenent be crenared.
nespectfully subm.ttec,,
W S $ h)&'
Milliam A. Lochstet 17 June 1980 119 E. Aaro n Dr.,
State College, Pa.,16801
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