ML19318B482
| ML19318B482 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/25/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Lewis M AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8006260213 | |
| Download: ML19318B482 (12) | |
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NRC 6/25/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDIS0N COMPANY,
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Docket No. 50-289
_E_T, A L.
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(Three Mile Island, Unit 1)
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NRC STAFF RESPONSE TO INTERR0GATORIES SUBMITTED BY INTERVENOR MARVIN 1. LEWIS In its pleading entitled "NRC Staff Response to Marvin I. Lewis' Motion to Compel Discovery from the NRC Staff" dated March 24, 1980, the Staff committed itself to answering Interrogatory NRC 15.
Similarly, in a later pleading entitled "NRC Staff Response to Marvin I. Lewis' Motion for an Order to Compel " dated March 31, 1980, the Staff agreed to answer Interrogatories NRC 27 and 28.
Pursuant to these conmitments, the Staff has answered NRC 15, 27, and 28.
A corrected version of NRC 20 is also included.
In addition, signed affidavits identifying the individuals who prepared responses and verifying them which were not sent before are attached.
Respectfully submitted, Lucinda low Swartz Counsel for NRC Staff Dated at Bethesda, Maryland this 25th day cf June,1980 8606260213 p
Lewis Interrogatory 15 i
Has anything been done to implement a leak reduction and elimination program
-ide from recommending such a program?
Response
Section 2.1.6.a of NUREG-0578 addresses the potential for leakage of radioactive materials from liquid and gaseous systems. All applicants and licensees have been directed to implement a leakage reduction and control program to minimize system leaks on both imrr.ediate and continuing bases. With large and complex high and low pressure systems, elimination of leakage is not practical; therefore, the goal of the leakage reduction and control program is to reduce leakage to as low as reasonably achievable levels.
At TMI-1, the leakage reduction programs specified in NUREG-0578 have not been fully implemented. Gaseous systems were pressure tested in June 1979, at which time no leakagc was found. The licensee has proposed to perform helium leak testing of the gaseous system and to visually inspect the liquid systems for leaks under pressure conditions, as well as providing for continued surveillance of these systems.
The staff's review of the licensee's proposal has not been completed; when the evalua-tion is completed, it will be reported in a supplement to the sD7ety evaluation report for TMI-1 re-start.
Lewis Interrogatory 20 Was it a violation to operate TMI-2 with a cracked vent header? If not, why not? If so, where is the fine?
Response
Preceding the fiarch 28 event at TMI-2, the unit was probably being operated with a small leak in the vent' header.
During normal operations the radio-activity released from the leaking vent header is collected by the auxiliary building ventilation system and goes to the plant stack. The stack effluent is continuously monitored and the rate of radioactivity release was well within Technical Specification limits preceding the March 28 event. Subsequent to the March 28 event leakage from the gaseous radwaste system may have caused releases to be larger then they otherwise would have been but the increase was not quantifiable.
During the accident, however, the rate of radioactivity released did exceed the limits in 10 C.F.R. 20. This was listed as a potential item of noncompliance in the I&E Investigation Report, NUREG-0600 (Appendix IIF, item G).
I&E decided not to cite the licensee for the noncompliance because prior to the accident the licensee was in compliance and once the accident started the release was beyond the licensee's control.
NRC 27. Did the leaking vent header and the HEPA and charcoal filters meet the requirements of a.
GDC 41 b.
GDC 60 c.
GDC 61 d.
10CFR50 Appendix I ALARA (1 Sep 1978.)
If any of the above are not applicable, please state why.
If these criteria were not met, state specifically how and why they were not met. (Curies, dollars per Curie, release rate.)
e.
Include all the filters in your analysis; not just thc filters in the auxiliary building.
RESPONSE
The vent header at TMI-2 collected gases stripped or verited from the primary coolant system. At or before the March 28, 1979 accident at TMI-2, the collected gases were compressed and alternately stored in one of two gas decay tanks with adequate capacity to permit at least 90 days decay of the radioactive gas prior to monitored and controlled r?' ase, through a HEPA filter and charcoal adsorber, to the plant vent.
In our Safety Evaluation Report for TMI-2 (NUREG-0107),
September 1976, we found that this radioactive waste system design met the require-ments of 10 CFR Part 50, Appendix A, GDC-60 and 61.
In Supplement 1 to the SER, we' evaluated this system design and found it capable of reducing the release cf radioactive materials in gasecus effluents to "as low as reasonably achievable" levels in conformance with 10 CFR Part 50.34a; it met the requirements of Appendix I to 10 -CFR Part 50, and was therefore acceptable. The vent header is not a
a RESP 0!iSE (Continued) containrrent atmosphere cleanup system, therefore, the criteria of GDC-41 is not applicable. The fuel handling building ventilation system, the control room ventila-tion system and the reactor building purge system were designed, tested and maintained to meet GCC-61, GDC-19 and GDC-41, respectively. Regulatory Guide 1.52 (Revision 1),
July 1976, " Design, Testing, and Maintenance Criteria for Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled I
tiuclear Power Plants", provided guidelines used to find these three systems accept-able.
Interrogatory 28 Why was the vent header leaking? What materiais failed? Where did they fail? How did they fail? When did they fail? If not a material problem, be specified as to what was the problem.
State who discovered leak, when, how, where. Who logged leak and when? Where is the work order to fix vent header leak? Above interrogatory refers to the vent header in TMI-2.
NRC 27 refers to TMI-2 also.
Response
As is pointed out in the Rogovin Report,Section II.B(d), the size of the leaks in the vent header and waste gas decay systems were small enough to be considered insignificant when they operated according to the normal operation design basis of the system. That is, the amount of radioactivity released from the leaks during normal operation was small because the level of activity carried by the system during normal operation, including anticipated operational occurrences, was small. The fact that this system had to operate in a post accident situation in which it contained radioactivity levels in excess of the system design basis meant that the releases from these leaks were larger.
This means, as the Rogovin report indicates, that system leaks, which released levels of radioactivity during normal operation that were within NRC effluent limits, released large amounts of radioactivity during the accident.
There was no specific failure mechanism involved.
NUREG-0578, Item 2.1.6a, recognizes the possibility of radioactivity being released from this system during all possible plant conditions and therefore requires a program of leak testing and leak reduction by all licensees.
Following the accident, as indicated in the response to NRC 12 (page 1) an effort was begun by Metropolitan Edison personnel to identify systen leaks. Work has been accomplished in the repair of leaks in the waste gas system.
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UNITED STATES OF AltERICA NUCLEAR REGULATORY CGMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDIS0N COMPANY, ET AL.
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Docket No. 50-289
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(Three Mile Island, Unit 1)
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AFFIDAVIT OF LUCINDA LOW SWARTZ I, Lucinda low Swartz, being duly sworn, do depose and state:
1.
I am an attorney in good standing admitted to practice before the Courts of the District of Columbia.
I hold the position of Staff Attorney in the Office of the Executive Legal Dirert'r of the United States Nuclear Regulatory Commission and serve as Staff Counsel in this proceeding.
2.
The answer to Lewis Interrogatories NRC 11, 21, and 26 were prepared by me. I certify that the answer given is true and accurate to the best of my knowledge.
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Subscribed and sworn to before me this 18 - day of _ March,1980 I
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t..u Notary /Public My Commission Expires: July 1, 1982
UNITES STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, et al.
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Docket No. 50-289
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(Three Mile Island, Unit 1)
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AFFIDAVIT OF PHILLIP G. ST0DDART I, Phillip G. Stoddart, being duly sworn, do depose and state:
1.
I am a Senior Nuclear Engineer 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.
. am responsible for the technical review of safety reviews of radioactive waste management systems for nuclear power plants. My professional qualifications statement is attached.
2.
The response to Lewis Interrogatory 15 was by me.
I certify that the informa-tion given is true and accurate to the best of my knowledge.
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' Phillip/G. Stoddart Subscribed and sworn to before me this /
day of 6%
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Notary Public
/4 My Cormission expires:
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDIS0N COMPANY, et al.
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Docket No. 50-289
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(Three Mile Island, Unit 1)
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AFFIDAVIT OF SAMUEL E. BRYAN I, Samuel E. Bryan, being duly sworn, do depose and state:
1.
I am employed by the Office of Inspection and Enforcement of the United States Nuclear Regulatory Commission.
2.
The answer to Lewis Interrogatory 20 was prepared by me.
I certify that the answer given is true and accurate to the best of my knowledge.
Samuel E. Bryan
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Subscribed and sworn to before me this 4 tE day of
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Jh a, 8: &Ls hotary Public My Comission Expires:.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of METROPOLITAN EDIS0N COMPANY, et al.
(Three Mile Island, Unit 2}
AFFIDAVIT OF GEORGE KALMAN I, George Kalman, being duly sworn, do depose and state:
1.
I am employed by the United States Nuclear Regulatory Commission at the Three Mile Island Nuclear Plant.
2.
The answers to the Lewis Interrogatory, questions 32 a and b were prepared by me.
I certify that the answers given are true and accurate to the best of my knowledge.
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GeorgeKdman
-Subscribed.and sworn to before me this y f day of March 1980.
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Notary Putplic CATHY L. BREY. Notry Puthe Londenferry Trip., DaspNn County. Pa.
W Ceni n Expan Ou. M. N3 My Commission expires:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDIS0N COMPANY, Docket No. 50-289 ET AL.
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(Three Mile Island, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO INTERR0GATORIES SUBMITTED BY INTERVENOR MARVIN I. LEWIS," dated June 25, 1980, 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 25th day of June,1980:
- Ivan W. Smith, Esq.
Mr. Steven C. Sholly Atomic Safety & Licensing Board Panel 304 South Market Street U.S. Nuclear Regulatory Commission Mechanicsborg, Pennsylvania 17055 Washington, D.
C.
20555 Mr. Thomas Gerusky Dr. Walter H. Jordan Bureau of Radiation Protection 881 W. Outer Drive Dept. of Environmental Resources Oak Ridge, Tennessee 37830 P.O. Box 2063 Harri:; burg, Pennsylvania 17120 Dr. Linda W. Little 5000 Hermitage Drive Mr. Marvin I. Lewis Raleigh, North Carolina 27612 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 George F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge Metropolitan Edison Company 1800 M Street, N.W.
Attn: J.G. Herbein, Vice President Washington, D._C.
20006 P.O. Box 542 Reading, Pennsylvania 19603 Karin W. Carter, Esq.
505 Executive House Ms. Jane Lee P.O. Box 2357 R.D. 3; Box 3521 Harrisburg, Pennsylvania 17120 Etters, Pennsylvania 17319 Honorable Mark Cohen Walter W. Cohen, Consumer Advocate 512 D-3 Main Capital Building Department of Justice Harrisburg, Pennsylvania 17120 Strawberry Square,14th Floor Harrisburg, Pennsylvania 17127
- John Levin, Esq.
Pennsylvania Public Utilities Com.
Box 3265 Harrisburg, Pennsylvania 17120 Jordan D. Cunningham, Esq.
Allen R. Carter, Chairman Fox, Farr and Cunningham Joint Legislative Committee on Energy 2320 North 2nd Street Post Office Box 142 Suite 513 Harrisburg, Pennsylvania 17110 Senate Gressette Building Columbia, South Carolina 29202 Theodore A. Adler, Esq.
WIDOFF REAGER SELK0WITZ & ADLER Post Office Box 1547
- Atomic Safety and Licensing Appeal Board Harrisburg, Pennsylvania 17105 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Ms. Ellyn R. Weiss Sheldon, Harmon, Roisman & Weiss
- Atomic Safety and Licensing Board Panel 1725 I Street, N.W.
U.S. Nuclear Regulatory Commission Suite 506 Washington, D. C.
20555 Washington, D. C.
20006
- Secretary Ms. Karen Sheldon U.S. Nuclear Regulatory Commission Sheldon Harmon, Roisman & Weiss ATTN:
Chief, Docketing & Service Br.
1725 I Street, N.W.
Washington, D.C.
20555 Suite 506 Robert Q. Pollard Washington, D. C.
20006 609 Montpelier Street Baltimore, Maryland 21218 Ms. Marjorie M. Aamodt R.D. #5 Chauncey Kepford Judith H. Johnsrud Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Frieda Berryhill, Chairman
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y Coalition for Nuclear Power Plant j.
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Postponement Counsel for NRC Staff 2610 Grendon Drive Wilmington, Delaware 19808
-Holly S. Keck
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Anti-Nuclear Group Representing York 245 W. Philadelphia Street' York, Pennsylvania 17404 r