ML19329F763
| ML19329F763 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/19/1980 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8007110075 | |
| Download: ML19329F763 (7) | |
Text
y 6/19/80 UNITED STATES OF A> ERICA
. NUCLEAR REGULATORY CO>O!ISSION BEFORE ~THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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METROPOLITAN EDISON COMPANY, ET AL.
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Docket No. 50-320 OLA
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e (Three Mile Isind Nuclear Station, )
4 Unit 2)
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USNRC L7 JUN 2 41980 > 1
- CONTENTIONS CF STEVEN C. SHOLLY Office of the SecretM D:g*et Se @
(SUPPLEMENT TO PETITION TO INTER-g VENE, PURSUANT TO 10 CFR 2. 714)
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4 In an order dated 23 May 1980, the Chairman established the date for th'e Special Prehearing Conference in this proceeding as 7 July 1980. Accordingly, the contentions of the petitioners are due 15 days before this date, specifically on or before 23 June 1980 (since 22 Jur 1980 is a Sunday). Herein are the final contentions of Steven C. Sholly, petitioner in this proceeding.
CONTENTION #1 It is contended that in the absence of data to support the proposed maximum Reactor Coolant System pressure (Technical Specifications, 2.1. 3),
the inherent asstnption within the Technical Spreificaticas that the reactor coolant pressure boundary is capable of withstanding the specified pressure of 2750 psig is not tenable.
It is additionally contended that for the Reactor Coolant Syste=. pressure to approach the level suggested would recuire a severe trattsient situation, initiation of which would present significant hazards to the public health and safety.
It is therefore contended that
-a ruch lower Safety Limit for the Reactor Ccolant System pressure is required, i
and that.the proposed limit of 2750 psig dces not adequately protect the public health and safety.
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.i y-SHOLLf CONTENTIONS, 50-320 OLA 6/19/80
- l BASIS FOR CONT'._hTION #1_
j The accident of 23 March 1980 and continuing has subjected the reactor coolant pressure boundary to conditions which were not.
anticipated during the. design of the system.
The impacts of these
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conditions, including extremely high levels of radioacti-ity, temperatures in excess of design, and pressures in the high range,.oupled with-
. extended.ma'intenance of conditions within the reactor building which f ar exceed the environmental qualifications for which most of the equipment therein was designed, lead to a measure of uncertainty as to the structural integrity of the reactor coolant pressure -
boundary, particularly in the instance of code safety valves and the PORV on the. pressurizer. For the Reactor Coolant System pressure to~ reach the proposed limit of 2750 psig, a very large increase would have to take place from the pressure which theoretically will exist when - the MDHR system is operating.
Such a large increase could only come from a very severe transient, which has serious consequences not only for the stability of the reactor, but also for public health and safety. A pressure of 2750 psig is therefore not reasonable as a safety 4
1:Lnit; it is not conservative. A lower limit is in order and should be required in the revised-Technical Specifications.
CONTENTION #2
' Technical Specification 3.3.1.1 Action provides that with no channels operable. in the Neutron. Monitoring Instrumentation, compliance with boron concentration re_quirements of Specification 3.1.1.2 be performed cnce per
,24. hours by mass balance calculation and at least once per 7 days by a chemical canalysis.
It is contended that these provisions are insufficient to protect
' the public health and safety by assuring that a recriticality accident cannot
~ 6/19/80 5 HOLLY CONTEWTIONS, 50-320 OLA occur.
It is therefore contended that more frequent assessment of compliance with boron concentration limits be performed when no operable neutron monitoring channels exist.
It is further contended that an additional require =ent to the Action statement should be added, namely that upon detection of the condition of no operable neutron monitoring instrumentation channel, the NRC must
- immediately be notified, and further that dae Emergency Plan classification of Unusual Event be declared, with the result being that the Pennsylvania Emergency Management Agency be informed i= mediately.
BASIS FOR CONTENTION #2 Assuming that no operable neutron monitoring instrumentation channel exists, the only feasible means of assessing the chances of a recriticality incident is assuring that the boron concentration in the primary coolant is maintained at a sufficiently high level.
A calcul'ation of what the concentration should be on a mass balance calculation basis provides less assurance than a chemical analysis.
In the event - that the monitoring instrumentation is inoperable, this constitutes a serious situation.
Reliance on calculational models when a direct chemical analysis means is available to determine the boron concentration is not conservative practice. No: is it conservative to assume that if one test is taken per day, that particular test will be accurately carried out.
Therefore, it is more conservative
-to perform a chemical analysis more than ence per day when the neutron instrumentation is inoperable.
'A reasonable frequency, at a minimum, would be once per operating shif t- (i.e., three times per day).
In the alternative, at least a confirmatory test should be performed to be more certain of the validity of the initial result.
Further, when the situation of inoperable channels occurs, this-is a serious situation which should result in the ini:iatien of at 1 cast the lowest classification r
4 T-
SHOLLY CONTESTIONS, 50-320 OLA 6/19/80 e
of Licensee's Emergency Plan, namely the' unusual Event class. This would result in the notification of dhe Pennsylvania Emergency. Management Agency.
As a result, the Co==cnwealth would be required to be notified l
I of this situation, which is clearly not normal, not desirable, and has i
an inherent degree of risk.
CONTENTION #3 It is contended that Technical Specification 6.2.2 does not provide adequate assurance of the prote ction of public health and safety because it references Table 6.2-1, which permits shif t crew composition to be less than the minimum specified for a period of two hours, thus potentially permitting i
the plant to,be without a licensed operator for two hours.
It is contended that there must be in the control room at all times at least one licensed reactor operator who it licensed for TMI Unit #2.
BASIS FOR CONTENTION #3 Technical Specification 6.2.2 references Table 6.2-1 of the proposed Technical Specifications, which provides that, " Shift Crew composition may be less than the minimum requirements f or a period not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to acce=odate unexpected absence of on duty shift crew members provided i==ediate action is taken to restore the shif t crew compos ion to within the minimum require =ents of Table 6.2-1."
This would appear to permit both the operator with the SQL
'and the operator with' the OL to be absent for two hours, with the shif t consisting solely of two ncn-licensed operators.
This is clearly unacceptable. Tuere must be at least one licensed operator in the control room at all times in order to be prepared to take whatever action; may be needed to protect the public health and safety, f
u
SHOLLY CONTENTIONS, 50-320, OLA 6/19/80 CONTENTION #4-Technical Specification 6.10.1 provides that certain records be retained j
for at least five years.
It is contended that this is an insuf ficient period of time for retention of such records, and that such records should be maintained until the facility is decommissioned. It is further contended that an additional requirement relating to such records should be added to this ' Specification in that. any of. the records Frequired to be retained by this provision must be available for public inspection and copying upon request.
BASIS FOR CONTENTION #4 The records referenced in Specification 6.10.1 contain information that is potentially very significant from several standpoints,' including legal," technical, and public health standpoints.
To permit the disposal of such records af ter a five-year period is unwarranted and unnecessary.
Fruther, public access to such records upon request is an entirely reasonable prevision given the need to protect the public health and safety, a need which is viewed by the Commissien and certainly by myself as being the paramount concern of the Commission.
CONTENTION #5 It is contended that the time limit permitted by Technical Specification 3.3.3.5 for returning inoperable remote shutdown monitoring instrumentation channels to operable status is unnecessarily lengthy at a period of 30 days, and that a requirement for a, shorter time period of 7 days is more conservative and would therefore better protect the public health and safety.
SASIS FOR CONTENTION #5 The period referenced in the. language of the cententien is unnecessarily long, considering the fact that the remote shutdewn
- SHOLLY - CCNTENTIONS, 50-330 OLA' 6/19/80 location is necessary to ensure protection of public health and safety
-in-' the event that the control room becomes uninhabitable during the i
period of operation in.the Recovery Mode.
Such an eventuality cannot
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l reasonably be excluded given the tenuous nature of many of the steps i
1
~ involved in the~ cleanup of the plant.
Therefore,-it would be more conservative and more protective of public health and safety to require a shorter period of time within which to restore instrumentation in the remote chutdoun locction to,, operable status.
Ideally such
. restoration would be as immediate as possible, but this is probably A
not always feasible. However, 30 days does not take sufficient note of -the seriousness of the situation as a limit for restoration to
-operable status. Therefore, a shorte:. period is specified.
DATED:
19 June 1980 Respectfully submitted, Yt Stree t {/
Steven C. Sholly 304 South Market Mechanicsburg, PA 17055 home--717/766-1857 work--717/233-4241
~ UNITED STATES OF AMERICA NUCLEAR REGULATORY COSDtISSION
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In the Matter of
)
METROPOLITAN EDISON COMPANY, ET AL.
Docket No. 50-320 OLA
)
(Three Mile Island Nuclear Station,
)
f Unit 2)
)
h CERTIFICATE OF SERVICE I hereby certify that single copies of "Contentiens of Steven C.
Sholly (Supplement to Petition to Intervene, Pursuant to 10 CFR 2. 714)"
I were served upon the parties below by deposit in the United States mail, e
first class, postage prepaid, this 20th day of June 1980.
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Steven C. Sholly
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Dr. William A. Lochstet Mr. John F. Wolf, Esq.
119 E. Aaron Drive Atomic Safety and Licensing Board
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State College, PA 16801 3409 Shepherd Avenue q
Dr. Judith H. Johnsrud i
Environmental Coalition on Dr. Oscar H. Paris Nuclear Power U.S. Nuclear Regulatory Co= mission 433 Orlando Avenue Atomic Safety and Licensing Board Penel State College, PA 16801 Washington, D.C.
20555 Mr. George F. Trowbridge, Esq.
Mr. Frederick J. Shen Shaw, Pittman, Potts, and Trowbridge U.S. Nuclear Regulatory Coreission 1800 M Street, NW Atomic Safety and Licensing Board Panel Washington, D.C.
20036.
Washington, D.C.
20555 Of fice of the Executive Legal Director U.S. Nuclear Regulatory Commission 9M(, a '. -
Washington, D.C.
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