ML19326D884
| ML19326D884 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/18/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Lewis M AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8007230500 | |
| Download: ML19326D884 (15) | |
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UNITED STATES OF AMERICA USHR0 NUCLEAR REGULATORY COMMISSION lb q i 1980 >
5 cmco sSjgy 1 as BEFORE THE ATOMIC SAFETY AND LICENSING BOARD D
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.1 In the Matter of METROPOLITAN EDIS0N COMPANY,
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(Three Mile Island Nuclear Station
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Unit 1)
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NRC STAFF RESPONSE TO LEWIS INTERR0GATORIES ON THE SER Pursuant to 10 C.F.R. 5 2.720 and 10 C.F.R. 5 2.744, the Staff has
.onded to Marvin I. Lewis' intermaatcries based on the SER submitted r
on June 30, 1980. Each interrogatory is restated and a response provided.
Affidavits identifying the individuals who prepared the responses and i
verifying them are attached.
1 Respectfully submitted, 1
Lucinda Low Swartz Counsel for NRC Staff Dated at Bethesda, Maryland this 18th day of July, 1980 80072305oo-1
s-SER #1 The lack of a bypass is not investigated in the SER. What means is provided to overcome the accident sequence in the Power Reactor Events L
P.7 vol 2 No 2 March 80 and IE Cir 79-21? Will this accident sequence harm the vent header and possibly cause leaks?
Response
The lack of a bypass in the TMI-l auxiliary building ventilation system is not investigated in the SER because the Staff does not consider this to be a deficiency. A bypass around a filter system usually means that routine releases do not pass through the filter, with the result that routine releases are untreated and therefore cause larger doses to the offsite population than would be the case if routine releases were treated. Where a bypass exists, a mechanism must be provided to close the bypass in the event of an accident and to divert the release through the previously bypassed filter system. Since the actuation of bypass closure requires the operation of several devices and mechanisms in a short period of time, and since such mechanisms have measurable failure rates, such a system is less reliable than a non-bypassed system. The usual mechanism for closing a bypass and diverting flow into another path 's a motor-operated damper; dampers often leak.
It was for this specific reason that during preoperational testing the bypass dampers on the TMI-2 Auxiliary Building ventilation exhsust system we're modified, i.e., to block off the bypass and route the airstream through the filter-adsorber system. Had such action not been taken, the accident releases of iodine and particulates at THI-2 could have been much greater than they were.
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e-The reference to Power Reactor Events, Vol. 2, No. 2, has no logical connection to the absence of a bypass around the TMI-1 Auxiliary Building ventilation treatment system. The subject event, which is more properly classific. unde-the heading of an " anticipated operational occurrence" rather thm,-
nt," involved a resin change operation at the Calvert Cliffs Unit i.
4n this event an improperly closed valve resulted in radioactive water being forced into a vent pipe connected to the Auxiliary Building ventilation exhaust system, with attendant release of dissolved noble gases to the atmosphere. The event caused no reported damage to the ventilation exhaust system but did result in a release of Xe-133 to the atmosphere.
The term " vent header" can be applied to any of a number of venting systems in a nuclear power plant, but is normally used in reference to a portion of the waste gas collection and decay system, sed to furnish cover gas to primary coolant system liquid storage tanks. Such a system is essentially a closed loop cirulating system and releases only occur after substantial delay, minimizing the total radioactive gas release through the process of radioactive decay.
In a properly operating waste gas system release, sufficient decay time is.provided to allow decay of all gases except Kr-85 and tritium vapor.
I SER #2
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Page C4-8(4) " ventilation system will be modified..."
"(items 3 and 4) will be completed prior to restart."
"(items 1 and 2) will be installed prior to commencing first refueling."
Has any more exact scheduling been agreed upon between NRC and Met Ed than " prior to?" Can NRC Staff provide dates or PERT diagram scheduling at this time?
Have engineering drawings of these modifications been approved by NRC staff? Are they available to Intervenor Lewis? Where? Page Number?
(Drawings in Restart Report do not give sufficient detail (material, welds, installation diagrams and procedures.))
Response
More exact scheduling has not been agreed upon between the NRC Staff and the licensee. As stated, our requirement remains that these items be completed prior to performing the specified actions. The NRC does not have dates or PERT diagram schedulirg.
As noted in the SER, the licensee has not yet submitted all the detailed design information on these modifications. The drawings would be available, if at all, from the licensee.
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SER #3 In NRC 6/25/80 Response to Interrogatory 28..
explain what is meant by "there was no speci?ic failure mechanism?" Wno prepared the above answer?
May I contact that person by phone to eliminate this confusion?
Response
In our response of 6/25/80, we stated that the waste gas header system had been in operation for several months with a number of small leaks, which under normal operating conditions resulted in a low order release of noble gases in the auxiliary building. Even with the leaks, the system was capable of reducing plant effluent noble gas concentrations to less than the T-
.ical Specification limits. When the accident occurred, the existing leaks resulted in much higher releases, since the noble gas concentration in the leaked gas were correspondingly higher.
In other words, there was not a volumetric increase in leakage from the system during the accident --
only an increase in concentration of noble gases.
It was not a matter of sudden failure of gaskets or valve packings; it was not a broken or cracked pipe resulting from the accident, and it was not any of a number of possible failure mechanisms whic'1 cou'd have been triggered or set off by the accident.
Therefore, what was said in describing the condition was + hat "there was no specific failure mechanism." We would not have said that " failure mechanism is unknown at this time" because there was no failure mechanism per se.
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Francis P. Cardile provided the original response to Interrogatory 28 4
(see attached affidavit). He is now assigned to another division of NRC.
Parties are reminded that contact with the NRC Staff must be through the attorneys representing.the Staif.
4 SER #4 Where in the NUREG 0680.is there a requirement to test and change filter media? How often will the adsorber stage be tested per time period?
( ANSI h ~10-1975 Page 13' Will all filter media in the gaseous waste system be tested and how siten? Where is the requirement to change filter media that does not pass the testing?
18 there any mention of testing of filter media in NUREG 0680? Page number?
Response
NUREG-0680 is an evaluation of the licensee's compliance with Section II of the NRC Order dated August 9,1979, and does not originate or promulgate requirements concerning filter media. The requirements for testing of filter media are contained in the plant Technical Specifications. Adherence to the requirements of the Technical Specifications will be verified by the licensee under the station quality assurance programs noted on pages C6-ll and C6-19 of NUREG-0680 and by the Office of Inspection ana Enforcement audit.
Information concerning the timing of testing of the adsorber stage and the filter media.and filter media replacement can be found in the TMI-l Technical Specifications which are available in the local public document rooms.
Testing of filter media is not specifically addressed in NUREG-0680.
UNITEn STA1CS OF AMERICA NUCLEAR REGULATORY CO M ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of Docket No. 50-289 METROPOLITAN EDIS0N COMPANY, et al.
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(ThreeMileIsland, Unit 1)
AFFIDAVIT OF PHILLIP G. ST0DDART_
I, Phillip G. Stoddart, being duly sworn, do depose and state:
I am employed by the Effluent Treatment Systems Branch in the Offic 1.
of Nuclear Reactor Regulation of the United States Nuclear Regulatory Comission.
The answers to Lewis Interrogatories 1, 2, 3, and 4 were prepared b 2.
I certify that the answers given are true and accurate to the best knowledge.
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Phillip'G. Stoddart Subscribed and sworn to before me this 16th day of July,1980.
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}(otarf/Pdlic My Commission Expires:, July 1, 1982
Phillip G. Stoddart iffluentTreatmentSystemsBranch Division of Systems Integration Office cf Nuclear Reactor Regulation My name is Phillip G. Stoddart.
I am a senior nuclear engineer in the Effluent Treatment Systems Branch, Division of Systens Integration in the Office of Nuclear Reactor Regulation.
I attended the New Mexico School of Mines from 1947 to 1949. From 1949 to 1953 I was on active duty with the United States Air Force, assigned as a radiological instrumentation specialist with the Armed Forces Special Weapons Command and as a radio-logical safety instructor with a Strategic Air Command special weapons unit.
From 1953 to 1973 I was on the radiatica safety staff of the Argonne National Laboratory, working from 1953 to 1957 at Argonne's Illinois site and from 1957 to 1973 at Argonne's test facilities at the National Reactor Training Station, Idaho Falls, Idaho. My duties there included conduct of radiation safety programs, including effluent control and waste management, for several research and test reactors and a fuel recycle facility.
In 1973 I joined the Nuclear Regulatory Commissicn (formerly Atomic Energy Commission) as a nuclear engineer in the Fffluent Treatment Systems Branch, Division of Systems Integration.
In this position I am responsible for the review and evaluation of radioactive waste systems and for the calculation of releases of radioactivity from nuclear power reactors.
I am also responsible for determining the adequacy of instrumentation provided for maintaining the radioactive discharges from nuclear power plants and for providing technical bases for guides and standards.
I have participated in generic studies of the relationship between reactor operation and radio-active waste generation and in the preparation of staff reports related to effluent control technology and effluent monitoring.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPNISSION I
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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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 FRANCIS P. CARDILE I, Francis P. Cardile, being duly sworn, do depose and state:
1.
I am a Nuclear Engineer in the Office of Standards Development of the United States Nuclear Regulatory Commission.
I am generally responsible for standards related to waste management. Previously, however, I was a Nuclear Engineer in the Office of Nuclear Reactor Regulation.
I was responsible for review and evaluation of radwaste treatment systems and
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for the calculation of releases of radioactivity from nuclear power reactors.
My professional qualifications statement is attached.
2.
The answers to Lewis interrogatories 12,13,16,17, 22, 28, 32c, 35; CEA interrogatories 6-8, 6-10; and ANGRY interrogatory 6 were prepared by me.
I certify that the answers given are true and accurate to the best of my knowledge.
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Francis P. Cardile Subscribed and sworn to before me.this lh day of March,1980 un l d' w Notey Public My Commission expires:
July 1, 1982
Francis P. Cardile Professional Qualifications Office of Huclear Reactor Regulation My nane is Fran'cis P. Cardile.
I am a Senior Nuclear Engineer in the Effluent Treatment Systems Branch, Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation.*
I attended the University of Notre Dame and received a Bachelor of Science Degree in Mechanical Engineering in 1969.
I attended the University of Illinois and received a Master of Science Degree in Nuclear Engineering in 1970.
After graduation I worked for the Bechtel Power Corporation which is an architect / engineering company engaged in the design and constuction of nuclear power plants.
I was responsible for assessing the effects
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of plant radioactive effluents on the environment and the preparation of Safety Analysis Reports and Environmental Reports.
I also was responsible for the design of process systems and writing specifications for process equipment. My experience included work on both pressurized and boiling water reactors.
In 1974, I joined the Nuclear Regulatory Commission (formerly AEC) as a nuclear engineer in the Effluent Treatment Systems Branch.
In this position I am responsible for the review and evaluation of radwaste treatment systems and for the calculation of releases of 1
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radioactivity from nuclear power reactors.
I have participated in 9eneric studies of the relationship between reactor operation and radwaste ganeration' and in the preparation of staff papers related to effluent contt 31 technology.
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- Since February 1980, I have held the oosition of Nuclear Engineer in the Fuel Process Systems Standards Branch, Division of Engineering Standards, Office of Standards Development.
In that position I am responsible for the development of standards related to reactor waste managenent.
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i UNITED STATES OF AMERICA 11UCLEAR REGULATORY C0!U41SSION k
NKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 'I JUL 211980 >
Pe In the Matter of 3;
8 MElROPOLITAN EDISON COMPANY, Docket No. 50-289 ET AL.
g 7 (Ihree Mile Island, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that a copy of NRC STAFF RESPONSE TO LEWIS INTERR0""0 RIES ON THE SER dated July 18, 1980, in the above-captioned proceeding, been 4
served on Marvin I. Lewis by deposit in the United States mail, Federal Express, this 18th day of July, 1980
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UNITED STATES OF /J' ERICA us NUCLEAR REGULATORY COMMISSION g,1 N,,$
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g D
In the Matter of
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METROPOLITAN EDIS0N COMPANY, Docket No. 50-289 ET AL.
(Three Mile Island, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF RESPONSE TO LEWIS INTERR0GATORIES l
l ON THE SER dated July 18, 1980, in the above-captioned proceeding, have been l
served on the following, by deposit in the United States mail, first class, or, as indicated by as asterisk, through deposit in the Nuclear Regulatory Commission's
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internal mail system, this 18th day of July,1980
- Ivan 1(. Smith, Esq.
Mr. Steven C. Sholly Atomic Safety & Licensing Board Panel 304._ South Market Street U.S. Nuclear Regulatory Commission Mechanicsburg, Pennsylvania 17055 l
Washi.,gton, 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 Harrisburg,. 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.
x 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 1 __
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. Allen R. Carter, Chairman John Levin, Esq.
Joint Legislative Commi~ttee on Energy Pennsylvania Public Utilities Comm.
Post Office Box 142 Box 3265 Suite 513 Harrisburg, Pennsylvania 17120 Senate Gressette Building Columbia, South Carolina 29202 Jordan D. Cunningham, Esq.
Fox, Farr and Cunningham Robert Q. Pollard 2320 North 2nd Street 609 Montpelier Street Harrisburg, Pennsylvania 17110 Baltimore, Maryland 212f8 Theodore A. Adler. Esq.
Chauncey Kepford WID0FF REAGER SELK0WITZ & ADLER Judith H. Johnsrud Post Office Box 1547 Environmental Coalition on Nuclear Power Harrisburg, Pennsylvania 17105 433 Orlando Av9. a State College, Pennsylvania 16801 Ms. Ellyn R. Weiss Harmon & Weiss Ms. Frieda Berryhill, Chairma 1725 I Street, N.W.
Coalition for Nuclear Power Plant Suite 505 Postponement Washington, D.C.
20006 2610 Grendon Drive Wilmington, Delaware 19808 Ms. Marjorie M. Aamodt R.D. #5 Holly S. Keck Coatesville, Pennsylvania 19320 Anti-Nuclear Group Representing York 245 W. Philadelphia Street York, Pennsylvania 17404
- Atomic Safety and Licensing Appeal Board f,
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y U.S. Nuclear Regulatory Commission l
- g,,,gfj,A,g L M g-Washington, D.C.
20555 s
i Counsel for NRC Staff
- Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Conunission Washington, D.C.
20555
- Secretary U.S. Nuclear Regulatory Commission ATTH: Chief, Docketing & Service Br.
1 Washington, D.C.
20555 Susan R. Barley
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1751 E. Granada Avenue, Apt 2 Hershey, Pennsylvania 17033 3
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