ML19323F967

Answer to Licensee Interrogatory 8-1.Includes Info Re B&W Small Break LOCA Analysis Reinforcing Ucs Contention That Insufficient Analysis Has Been Done to Show Adequate Protection.W/Trowbridge 800122 Ltr & Certificate of Svc

ML19323F967
Person / Time
Site:	Three Mile Island
Issue date:	04/28/1980
From:	Weiss E SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	METROPOLITAN EDISON CO.
References
NUDOCS 8005300039
Download: ML19323F967 (8)

Text

. _ _ _ .

UNITED STATES OF AMERICA

-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

@lI -

)

In the Matter of ) 9- -

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g( .980 3 METROPOLITAN EDISON COMPANY, )

~~

-2 et al., ) Docket No. 50-289 b OWceo,ffgf DAehga .7

) (Kestart) ET 3 2

(Three Mile Island Nuclear ) 9 fj gN Station, Unit No. 1) ) or D

)

UNION OF CONCERNED SCIENTISTS ANSWER TO LICENSEE'S INTERROGATORY NO. 8-1 Question Copies of Babcock & Wilcox ("B&W") documents concerning small break analyses will be supplied to UCS counsel under separate cover. Does UCS contend in the light of the informa-tion contained in such documents that sufficient analyses have not now been done to show that there is adequate protection for the entire spectrum of small break locations? If so, explain the inadequacies which UCS contends exist in the analy-ses performed to date and describe in detail the further analy-ses which UCS contends should be performed.

Answer l UCS has reviewed the documents provided us by the licensee l l

on B&W small break LOCA analysis. A copy of the letter forward- l ing the document is attached. We will refer to each by one l number assigned to it in that letter. This material reinforces our contention that insufficient analysis has been done to show 00063 0g 0 3 cl

that there is adequate protection for the entire spectrun of small break locations. It should first be noted that several of the documents contain no information relevant to this question. Instead they can be characterized as conclusory, promises to do analyses and, in one case, notification of the existence of a proprietary report which UCS was not forwarded and thus, could not review. Those with no usef,ul information are #4 (for which the attachments are missing and which states conclusions and promises), #5 (which references but does not include a proprietary report), #6, #7 (which states conclusion based on an " attached document" which is neither attached nor identified), #12, #15, #18. To the extent that these documents were intended to be included within the scope of the interrogatory, we have found them to contain no useful information and, therefore, they have not formed any portion of the bases for this answer.

UCS has noted the following general deficiencies in the analyses:

1. The analyses are inconsistent with the require-ments of NRC regulations because the assumptions with regard to the availability of equipment do not distinguish between safety and non-safety equip-ment. For example, many of the analyses rely on the operation of systems and components not classified as safety grade to mitigate the acci-dents and transients considered. These include

.i

9 reactor coolant pumps, pressurizer heaters, auxiliary feedwater, pressurizer power-operated-relief valve, PORV block valve, pressurizer level instrumentation.

Because this equipment is not classified as safety-related and thus not subject to the strict requirements for safety-grade equipment (see Standard Review Plan, Table 7-1, caiumn labelled

" Applicability (SAR Section) 7.3"] In evaluating the adequacy of protection against LOCA's, the applicant is not permitted to rely on the availability of non-safety equipment. The Standard Review Plan specifically requires that each of the non-qualified and non-safe ty-grade components and systems is assumed to fail to function if failure adversely affects core cooling capability and is assumed to function if functioning adversely affects core cooling capability (SRP, Appendix A, 67.3)

2. The analyses are also defective in that they rely upon operator action to initiate or control a protective function despite the clear requirements of IEEE Standard 279 and GDC 20 that protection system functions shall be initiated automatically.

For example, in various accident sequences, operator action is required to " bump" the reactor coolant pumps, to align the suction of the low-pressure injection pumps to either the borated water storage tank or the containment sump, to balance high pr essure injection flow between injection lines, to isolate a leaking steam generator, to close the PORV or associated block

valve, to maintain adequate suction head for the low-pressure injection pumps. Such extensive reliance on the operator is unwise, particularly because there has been no analysis of the competing demands on his time and attention during an accident.

3. Even where the analyses rely on safety-grade systems and components, they do not take account of the actual experience at TMI-2. Safety systems such as decay heat removal have an acceptable leak rate and provisions for radia-tion shielding that are based upon the assump-tion that no significant fuel failures will occur. If significant fuel failures do occur, as they did at TMI-2, the safety systems can be rendered unusable because the high radio-active contamination will exceed the design bases. That is, the contamination from leaks in the decay heat removal system-to the auxi-i liary building may be so high as to preclude the use of that system.

The interrogatory goes on to ask UCS to describe the further analyses which we contend should be performed. As a general matter, there is nothing in the analyses which could not have been done before the accident occurred. As noted above, our basic criti-cisms are with various assumptions used in the analyses. We

( believe that loss-of-coolant accidents should be analyzed over

I a spectrum of sizes ,and locations under the following conditions:

1. Equipment which does not meet NRC regulations for structures , systems, and components important to safety should be assumed to fail or to function depending upon which assumption yields the most adverse results on core cooling capability. .

2. No operation action is credited. Or, in the alternative (which we do not believe is acceptable), at least the analyses should consider the effects of operator errors of commission and omission, such as failure to initiate transfer of LPI suction from the borated water storage tank to the contain-ment sump or too early a transfer, when adequate positive suction head is unavaila-l ble.

3. Demonstrate that the leak rate from all

! systems outside containment and the radia-tion shielding for those systems is acceptable assuming fuel failing in excess of 10 CFR 50.46.

Respectfully submitted:

Ellyn R. Neiss SHELDON, HARMON & WEISS 1725 I Street, N.W., Suite 506

' Washington, D.C. 20006 (202) 833-9070 I DATED: April 28, 1980

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anuary 22, 1980 HAND DELIVERED .

Ellyn R. Weiss, Esquire Sheldon, Harmon & Weiss Suite 506 1725 Eye Street, N.W.

Washington, D.C. 20006

Dear Ellyn:

In Interrogatory 8-1 of Licensee's Interrogatories to UCS, dated January 18, 1980, I indicated that copies of certain B&W documents concerning small break analyses would be supplied to UCS counsel under separate cover. I enclose with this letter the following items:

1. Volumes I and II of B&W '" Evaluation of Transient Behavior and Small Reactor Coolant System Breaks ~

in the 177 Fuel Assembly Plant," dated May 7, 1979.

2. Letter Taylor to Mattson, dated April 17, 1979 (with attachments)'.

3. Letter Taylor to Mattson, dated April 25, 1979 -

(with attachment) .

4. Memorandum Roy to Mattson, dated April 26, 1979.

5. Letter Taylor to Hanauer, dated May 3, 1979.

6. Letter Taylor to Ross, dated May 4, 1979.

7. Letter Taylor to Mattson, dated May 7, 1979.

S H AW, PITTM AN, POTTS & TROWB RIDGC Ellyn R. Weiss, Esquire January 22, 1980 .

Page Ivo

8. Letter Taylor to Novak, dated May 10, 1979.

9. Letter Taylor to Rosztoczy, dated May 16, 1979 (with attachment).

10. Letter Taylor to Mattson, dated May 18, 1979 (with attachment) .

11. Letter Taylor to Mattson, dated May 24, 1979 (with attachment) .

12. Letter Taylor to Mattson, dated June 8, 1979.

13. Letter Taylor to Mattson, dated June 13, 1979 .

(with attachment) .

14. Letter Taylor to Novak, dated June 14, 1979.

15. Letter Taylor to Tedesco, dated June 15, 1979.

16. Letter Geissler to Case, dated July 20, 1979.

17. Letter Taylor to Ross, dated August 30, 1979 (with attachments).

18. Letter Taylor to Denise, dated October 9, 1979.

19. Letter Taylor to Eisenhut, dated November 2, 1979 (with attachments).

20. Letter Taylor to Eisenhut, dated November 9, 1979 (with attachments).

21. Letter Taylor to Eisenhut, dated November 20, 1979.

22. Letter Taylor to Denise, dated December 10, 1979 (with attachment) .

Sincerelv, M

Georg F. Trowbridge Enclosures l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

METROPOLITAN EDISON )

COMPANY, ~~~ ---et al., ) Docket No. 50-289

) (Restart)

(Three Mile Island )

Nuclear Station, Unit )

No. 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Union of Concerned Scientiats Answer to Licensee's Interrogatory No. 8-1" was mailed first class postage prepaid this 28th day of April, 1980 to the following parties:

Secretary of the Commission ATTN: Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ivan W. Smith, Esquire Atomic Safety & Licensing Board Panel ,.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 "' ' J 4)' -

N Dr. Walter H. Jordan 881 W. Outer Drive [- gggg3 ,,

Oak Ridge, Tennessee 37830 fp g)X. 9yg5} > 2 -

Dr. Linda W. Little -

Ottics ci68IN toc \,etint a SCUIC8 ' d 5000 Hermitage Drive k B@th Raleiegh, North Carolina 27612 9 c) j g i

• George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 "M" Street, N.W.

Washington, D.C. 20006 James Tourtellotte, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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l

/ .

Ellyn R. Weiss 1

• Hand-delivered 9