ML19323F962
| ML19323F962 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/26/1980 |
| From: | Pollard R Chesapeake Energy Alliance |
| To: | METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19323F963 | List: |
| References | |
| NUDOCS 8005300035 | |
| Download: ML19323F962 (2) | |
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GA: RESP:LIO: DIS-80.Ol+.26 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY A'ID LICENSING DOARD In the Matter of
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METROPOLITAN EDTSON COMPANY
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(Three Mile Island, Unit 1)
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DOCKETED USNRC 6-W 2 O G80 >
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C~A'S FURTHER RESPCN1E TO LIGN3EE'S FIRST SET OF INTERROG ATORIF$
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y Fo11 ewing the Boar:i's Memorandum and Order on Licensee's Motion to C j
Discovery of CA ( April 16, 1980), CEA hereby submita the following further responses to Licensee's First Set of Interrogatories. Wherever it is stated below that CEA's response is changed to read..., the change shall be from GA's Response to Licensee's F1-st Set, of Interrogatories (80.0317).
5-1 CA's respense is changed to read " tanks and pipes with.."
(a) GA is not presently ablu to identify specific TIG-1 accidents that would require use of T U-2 storage space.
(b) See (a) above.
(c) See (a) above.
5-2 GA is not presently able to' identify specific potential accidents at TIC-2 during decontamination and clean-up.
5-3 See 5-2 above.
(a) Sec 5-3 abovo (b) See 5-3 above (c) See 5-3 abeve 5 !+
The TMI-2 Weekly Status Report, dated April 124, 1980 (TMI-NRC 80 reports that EPICOR II dwas started on April 7,1980...arter an extensive outage for several modifications... " (emphasis added).
GA notes thatt this statement appears to be in direct conflict with Licensee's response to GA's Interrogatory 5-9 stating that EPICOR-II has operated 4s projected" and "as originally scheduled". The T rd is correct in its perceptica that GA doesn't know the nanes and dates c. the news reports it had. cited.
5-5 GA's responac is changed to read "The claim is based..."
6-1 The basis for GA's claim is substantiated by Licensee's response to GA's Interrogatory 6-7, and by 'IRC Staff's response to GA's Interrogatory 6-8 (b) GA, like Licensee (in its response to GA's 6-7), is not able to determine the location of the leakage s u ces.
(c) To the best of GA's knowledge, the leakage is into the Containment Building of TMI-2.
Until further n:pling af rsdioactivity in wells bored belcw TMI-2 is completod, it is not elcar whethe r there is subsequent leakage from the containment building.
(d) The aggregcte rate of leakage is betweer. 0.2 and 0.5 gallons por minute.
8005300035-
7-1 CEA is not convinced that the separation cf TMI-l and TNI-2 is adequate to resolve its concerns.
(a) CEA is not presently able to specify particular inadequacies in the proposed physical separation of TMI-1 and IMI-2.
(b) See (a) above.
(c) See (a) above.
(d) See (a) above.
7-2 GA is not convinced that the Cafety Evaluation performed by NRC Staff is adequate to meet its concerns.
(a)
GA is not presently able to specify any particular inadequacces in the Safety Evaluation perforned by NRC Staff.
(b) See (a) above.
(c) See (a) above.
(d) See (a) above.
d-l CEA is not presently able to identify other specific examples of the inadequacy of licensee's nanagenent capability.
(a) See 8-1 above.
(b) See 8-1 above.
(c) See 8-1 above.
12-2 CA is not presently able to specify particular accidents that are credible and that are not bounded by the TMI-1 design basis accidentn, 12-3 See 12-2 above.
12-4 See 12-2 above.
Respectfully rubmitted l' '
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/ l-Robert Q. Pollard, for CESAPEAKE ENERGY ALLIANG, INC.
j Dated: April 26,1980
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