ML19323B134

Response to Sc Sholly Followon Interrogatories Re Implementation of Containment Isolation Signal,Procedures of Containment Isolation Reset & Modified Containment Isolation Circuitry.W/Certificate of Svc & Cover Ltr

ML19323B134
Person / Time
Site:	Three Mile Island
Issue date:	04/07/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S AFFILIATION NOT ASSIGNED
References
NUDOCS 8005090483
Download: ML19323B134 (13)

Text

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800509oyrs cr Lic 4/7/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docke t No . 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S RESPONSE TO STEVEN C. SHOLLY'S FOLLOW-ON INTERROGATORIES FOLLOW-ON INTERROGATORY FOR INTERROGATORY 01-002 A. Explain why Licencee believes that the Reactor Coolant System Low Pressure signal is "an acceptable alternative to a safety-grade high radiation signal,"

(Response, page 3), including in the explanation assurance that the RCSLP signal will isolate the containment under condi-tions of high radiation.

RESPONSE

The initial response to Interrogatory 01-002 was incor-rectly written when it stated that " Implementation of this containment isolation signal conforms to the requirements of NUREG-0578 Section 2.1.4 and is an acceptable alternative to a safety grade high radiation signal." The response should have stated that the combination of signals described in Restart Report Section 2 are implemented in a manner that meets the requirements of NUREG-0578, Section 2.1.4. In accordance with l

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that document, the high radiation isolation signal is non-safety grade.

The events which would lead to potential significant hazards are all in a category which would involve a reactor trip and/or a low pressure condition in the RCS. In these events, the occurrence of either initiating condition would precede the development of a high radiation condition suitable for containment isolation.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 01-004 A. Licensee's Fesponse states that "(1) t is not feasible to catalogue in advance all plant conditions under which containment isolation reset after initiation would be appropriate." Intervenor therefore requests that Licensee specify procedural changes made to ensure that containment isolation is not reset under conditions which occurred during the Unit 2 accident; specify also any training which reactor operators received in the OARP which dealt with containment isolation reset.

RESPONSE

Procedures pertinent to containment isolation reset have been previously identified in Licensee's response to Interrogatory No.01-003. Copies of these documents have been placed in Licensee's Discovery Reading Room. Such procedures reflect changes made since the TMI-2 accident to prevent reoccurrence of problems experienced.durng the TMI-2 accident.

With respect to training that operators received in the OARP which dealt with containment isolation reset, Intervenor Sholly is referred to Licensee's Restart Report, Section 6, for details of the OARP.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 01-008 A. Licensee's Response at page 10 states that,

" modifications are being made to the Containment Isolation Actuation logic. As a result of these modifications, additional testing will be implemented." Specify the additional testing which will be so implemented.

RESPONSE

After installation, as part of the Startup and Test Program, the modified containment isolation circuitry will be tested to verify that it is installed and functions as design-ed. Following startup, periodic testing will be conducted to test the actuation logic, calibration, and functions of the containment isolation system as required by associated Surveillance Procedures.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 03-001 A. Licensee's Response at pages 14-15 states that the instrumentation utilized to detect hydrogen gas concentrations in the reactor building has not yet been designed. Will Licensee supply details concerning this instrumentation as soon as it is available, and under no circumstances, no later than 10 days before the date by which testimony must be filed on Contention #3 and/or Contention #11? If not, explain why not.

RESPONSE

Licensee does not commit to filing details concerning this instrumentation prior to the filing of Licensee's testimony on Contention Nos. 3 or 11. The requested information is not relevant to Contention No. 3. Contention No. 11 has not been admitted in the proceeding . Further, even assuming hydrogen control measures are. ultimately required in the proceeding prior to restart, the Commission's Order of August 9, 1979 does not require that the details of implementing such requirements be provided to or approved by the Licensing Board prior to the hearing.

FOLLOW-ON INTERROGATORY FOR INTERROGATORIES03-002 THROUGH 03-004 A. Licensee's Response to these three Interrogatories is to refer to the response to 03-001 (see Response at page 15). Will Licensee supply responses to these Interrogatories as soon as the information is available, but under no circumstances not later than 10 days before the date by which testimony on contentions #3 and #11 must be filed? If not, explain why not.

RESPONSE

See Response to Follow-On Interrogatory No.03-001.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 06-004 A. Licensee's Response at page 20 states that, "B&W relies upon the instrumentation manufacturer's normal practices for measuring accuracy..." Provide the manufac-turer 's accuracy estimates for the instru-ments referenced in Licensee's Response.

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RESPONSE

For the instrumentation identified in the response to Interrogatory No.06-004, the accuracy of each has been determined to be as follows:

Reactor Out'*t Temperature i 2.21*F Reactor Outlet Pressure 1 50 psi Incore Detector Temperature 1 4.5*F FOLLOW-ON INTERROGATORY FOR INTERROGATORY 06-005 A. Licensee's Response at page 21 notes that the requested data has not been developed.

Will such data be developed prior to Restart?

If not, explain why not.

PESPONSE Licensee does not plan to develop the specific data referred to in Licensee's response to Interrogatory No.06-005.

Such information on the subject instrumentation is not required for Licensee design, procurement, installation or operational activities.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 07-001 A. All of the documents referenced in Licensee's Response at page 22 predate the Unit 2 accident. Is it Licensee's position that, in the light of the Unit 2 accident, there is no need to supplement this spectrum of accidents? If so, explain why.

If not, what is Licensee's position regarding the need for additional analysis to ensure compliance with 10 CFR 50 Appendix K?

RESPONSE

The documents referenced in response to Interrogatory No.07-001 demonstrate the capability of the emergency core cooling system to mitigate the consequences of small breaks within the criteric of 10 CFR 50.46. These documents provide the results of the analysis of a spectrum of small breaks. The specific analyses presented in References 5 and 6 were performed using a small break model which complies with 10 CFR 50, Appendix K.

Thus, it is Licensee's position that these analyses are in compliance with 10 CFR 50.46 and Appendix K to 10 CFR 50.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 11-001 A. Licensee's Response at page 24 states a well-known fact to both this Intervenor and the Licensee and is not responsive to the interrogatory. In order to facilitate a response, the interrogatory is restated:

Assuming the failure of the existing hydrogen recombiner, how much time would be required under both ideal and worst-case conditions to install a second recombiner at Unit 17

RESPONSE

A second hydrogen recombiner will be available on site that is compatible with plant systems as explained in the Restart Report. Licensee has difficulty providing time i

estimates for installation for unknown " worst case" conditions.

Licensee has not yet finalized the storage location for the second recombiner and therefore cannot specifically answer this o .

question. However, the second recombiner will be available within several days.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 11-002 A. Licensee's Response at page 24 fails to give the data requested. The referenced document was requested at Licensee's Discovery Reading Room on 3/7/80 and it was not present there. Either make available a '

copy of the' referenced document or provide the data requested in the original Interrogatory.

RESPONSE

A copy of the requested document has been placed in Licensee's Discovery Reading Room.

FOLLOW-ON INTERROGATORY FOR INTERROGATORY 13-006 A. Licensee at page 27 states that the computer and printers are not required to meet the single-failure criterion. This is not the information which was requested.

Intervenor requests that Licensee explain i how the computer and printers meet the l single-failure criterion, and, if they do i net, explain why. Is it Licensee's  !

position that the computer and printers are l not safety-related equipment and that all data available through the computer can be obtained by other methods? Explain your position.

I RESPONSE i Licensee believes its previous response to Interrogatory No .13-006 to be responsive. The plant computer and printers i 1

are not safety-related equipment. Appropriate, dedicated, l l

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hard-wired instrumentation and control systems arranged on control boards are safety-relate 3. The single failure criteria in the context of IEEE-279 is in respect to safety-related equipment.

All required safety-related data available through the computer can be obtained by other means.

FOELOW-ON INTERROGATORY FOR INTERROGATORIES15-002 AND 15-003 A. Licensee's Response at page 29 states that the information requested by these inter-rogatories "will be provided in testimony."

This constitutes a clear example of trial by surprise. Intervenor requests that such information be provided as soon as it is available and in no case not later than 10 days prior to the date by which testimony must be filed on Contention #15. Will Licensee commit to this? If not, explain why not.

PESPONSE Licensee believes its previous response to these Interrogatories to be responsive. Licensee is unable to provide Intervenor Sholly with information before such informa-tion is developed. While Licensee has agreed to cover in its testimony the status of its review of control room design from the human engineering viewpoint, Licensee points out that a general human engineering design review is not included in either the short or long-term requirements of the Commission's August 9, 1979 Order. If such a review is required by the Licensing Board, or if any control room design changes not covered by the August 9 Order are required by the Board, the Board will determine the scope and timing of such requirements.

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l There is no present requirement.or recommended requirement which would necessitate completion of Licensee's review plan prior to the hearing.

Respectfully submitted, SHAW, PITTMAN, POTTS &_TROWBRIDGE  !

By. Aj 'm M / f./

eorge F. Tr"6wbridge /

April 7, 1980

_g_

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

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to Steven C. Sholly's Follow-On Interrogatories," dated April 7, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, this 7th day of April, 1980.

/

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Addel J Q Ge[rJe F.'Trowbridg4 l

Dated: April 7, 1980 i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

_BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquira Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm's Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General ,

Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Pennsylvania 17120 '

Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire (4) Walter W. Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U. S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C. 20555 14th Flocr, Strawberry Square l Harrisburg, Pennsylvania 17127 i Docketing and Service Section (21) l Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555

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• e Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against NucleE T.M.I. Steering Committee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Theodore A. Adler, Esquire Widoff Reager Selkowitz & Adler Robert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Nuclea8 Sheldon, Harmon & Weiss Power 1725 Eye Street, N.W., Suite 506 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 16803 Steven C. Sholly Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Gail Bradford Marjorie M. Aamodt Holly S. Keck R. D. 5 Legislation Chairman Coate:ville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404

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• S H ELOON J. WEISEL SONNIE S. GOTTLaES JOHN A. Mc CULLOUGM ALFRED M. POSTELL J. PATRIC K HICuty SETH M. MOOGASIAN J AM ES TMOM AS LEN MART S M EILA E.McCAFFERTY STEVEN L. M E LTZ E R DELIS SA A. RIDGWAY DEAN O AU LIC K NENNETM J.MAUTMAN JOHN ENGEL DAvlO LAWRENCE MILLER

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April 7, 1980 Mr. Steven C. Sholly 304 South Market Street Mechanicsburg, Pennsylvania 17055 Re: Three Mile Island Unit 1 Docket No. 50-289 (Restart)

Dear Mr. Sholly:

I enclose Licensee's responses to your follow-on interrogatories. Copies of signed affidavits for these responses are not enclosed, but will be forwarded soon.

Sin erely, g s e[s/[r.Trowbridg Enclosure 1