ML20041F616

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Affidavit of RW Keaton Supporting Motion for Clarification. Proposed Movement of Unit 1 Fuel within Unit 1 Fuel Handling Bldg in Absence of ESF Filter Sys Poses No Threat to Public. Certificate of Svc Encl
ML20041F616
Person / Time
Site: Crane 
Issue date: 03/10/1982
From: Keaten R
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20041F612 List:
References
NUDOCS 8203170220
Download: ML20041F616 (7)


Text

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ___ - ___ _______________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

AFFIDAVIT OF Robert W. Keaten State of New Jersey )

SS County of Morris

)

Robert W. Keaten

, been duly sworn, deposes and says:

1.

I am Direc tor of the Systems Engineering Depa rtment of GPU Nuclear Co rporation, and have over 20 years experience in the nuclear field, including expe rience in accident analysis.

In my role as Direc tor of Systems Engineering, I have become familiar with the matters stated herein.

With re spec t to this information, I either have personal knowledge thereof, or have been informed of such information by GPU Nuclear Corporation personnel.

I make this affidavit in support of " Licensee's Motion for Clarification, or in the Alternative Reconsideration, of the Boa rd 's Rulings on the Fuel Handing Building ESF, Filter System."

2.

Licensee has determined that tubing within the TMI Unit I steam has been subjected to some chemical attack.

Investigations a re gener i

u nde rway to determine the precise cause of the observed attack.

Equipment fabricated from materials of a type similar to the steam generator tube s is also located in the reactor vessel ar.d may be subject to attack.

As a result, t

Licensee plans to inspect this equipment to determine if it has been degraded.

l I

I 8203170220 820312 DR ADOCK 0500028]

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Currently, Licensee plans to accomplish this inspection by removing the reactor vessel head and making progressively more detailed inspections of the reactor vessel and its internals.

If it becomes neces sa ry to remove a substantial number of fuel assemblies, this inspection effort may require defueling of the Unit reactor core and transfer of the fuel assemblies to the Unit 1 spent fuel pool for temporary s t., rage.

3.

Licensee's present intention is to remove the reactor vessel head on April 2, 1982.

No detailed schedule has been established for the remaining portions of the inspection effort.

4.

The Unit 1 a rea of the TMI fuel handling building does not have installed an Engineered Safety Feature ("ESF") filter system satisfying the guidelines of Regulatory Guide 1.52, and such a system could not be installed

'l by April 2, 1982.

5.

In order to assess the potential hazard s from a postulated Unit i fuel handling accident, GPU Nuclear Corporation engineers have conducted an offsite dose analysis conservatively reflecting current TMI-1 fuel conditions.

The analysis took no credit for either filter efficiencies or radioactivity dilution due to elevated release from the fuel handling building ventilation system.

It also assumed that TMI-1 had been shut down and that radioactive isotopes in the fuel had decayed for a period of two-and-one-half years.

All other assumptions and methodology used in the analysis were in accordance with the guidelines of Section 15. 7.4 of the S tandard Review Plan and Regulatory Guide 1.25.

I have attached as Exhibit I hereto a list of assumptions and key parameters used in the analysis.

6.

The results of this offsite dose analysis are as follows:

Exclusion Boundary LPZ

-5

-5 Thyroid dose (rem) 8.7x10 1.7x10 Whole-Body Dose (rem) 6.5x10 1.3x10' 7.

The offsite doses projected from this analysis are very low and represent small fractions of the limits of 10 CFR Part 100.

Licensee, therefore, believes that the proposed movement of Unit 1 fuel within the Unit 1 fuel handling building, even in the absence of an ESF filter system, poses no undue risk to public health and safety.

Permitting such fuel movements at this time will allow Licensee to make a timely investigation of possible degradation of materials within the Unit I reactor vessel.

Dated:

March 10, 1982 NOTARIZATION Subscribed and sworn to before me this

/O day of March,1982.

W6LJW J 00

~

.TP'O l

My Commission expires:

EXHIBIT 1 ASSUMPTIONS AND KEY PARAMETERS 1.

Power Level of 2535 MWt 2.

2.5 years of decay time 3.

Peaking factor of 1.68 4.

(a) 10% of noble gases and iodines from a damaged fuel assembly (total 208 fuel pins assumed to be damaged).

(b) 30% of the K -85 and I-129 inventory is assumed to be released.

p 5.

No c redit was taken for either filter e f ficiencies or radio-activity dilutions due to the elevated release from the fuel handling building ventilation system.

6.

Fuel pool water retains 99% of the released iodines, but none of the rioble gases.

7.

Breathing rate of 3.47 x 10-4.3

.c, f

8.

Atmospheric diffusion factors were based on Pasquil stability condition F, wind speed of 1.75 mph:

6.8 x 10-4

.ef,3 X/q at site boundary

=

1.3 x 10-4,,cf,3 X/q at LPZ

=

Lic 3/12/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

METROPOLITAN EDISON COMPANY

)

Dc;hct Me, 50-289

)

(Restart)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Motion for Clarification, or in the Alternative for Reconsideration, of the Board's Rulings on the Fuel Handling Building ESF Filter System", were served by hand on those persons identi-fled with one asterisk, by Express Mail on those persons identified with two asterisks, and upon the remaining persons on the attached Service List by deposit in the United States mail, postage prepaid, this 12th day of March, 1982.

/

c===

Thomas A. Baxter, P.C.

Dated:

March 12, 1982 J

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

)

)

l METROPOLITAN EDISON COMPANY

)

Docket No. 50-289

)

(Restart)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

SERVICE LIST 4

Gary J. Edles, Esquire

  • Jm es M. Cutchin, IV, Esquire Chairman Office of the P-,+1ve Imgal Atanic Safety and Licensing Appeal DirechA Board U.S. Nuclear Regulatory Ocnnission U.S. Nuclear Regulatory Ccanission Washington, D.C.

20555 Washington, D.C.

20555

  • Joseph R. Gray, Esquire Dr. John H. Buck Office of the Executive Imgal Atomic Safety and Licensing Appeal Director Board Panel U. S. Nuclear Regulatory N iasioni t

U.S. Nuclear Regulatory Cannission Washington, D.C.

20555 l

Washington, D.C.

20555 i

Docketing and Service Section i

Dr. Reginald L. Gotchy Office of the Secretary Atanic Safety and Licensing Appeal U. S. Nuclear Regulatory Ocnnission.

Board Panel Washington, D.C.

20555 U.S. Nuclear Regulatory Ccmnission Washington, D.C.

20555 John A. Ievin, Esquire Assistant Counsel Ivan W. Smith, Esquire Pennsylvania Public Utility Ccan'n Chairman Post Office Box 3265 t

Atanic Safety and Licensing Harrisburg, Pennsylvania 17120-Board Panel U.S. Nuclear Regulatory Ccmnissicn

20555 Assistant Attorney General 505 Executive House t

Dr. Walter H. Jordan Post Office Box 2357 Atanic Safety and Licensing Harrisburg, Pennsylvania 17120 Board Panel 881 West Outer Drive John E. Minnich Oak Ridge, Tennessee 37830 Chairman, Dauphin County Board of Cannissioners Dr. Linda W. Little Dauphin County Courthouse Atanic Safety and Licensing Front and Market Streets Board Panel Harrisburg, Pennsylvania 17101 t

5000 Hermitage Drive Raleigh, North Carolina 27612 m,-..

,,.7

. _ - - -, ~ _. _.. -, - _ _.,,

. Walter W. Cohen, Esquire Robert Q. Pollard Consumer Advocate 609 Montpelier Street Office of Consuner Advocate Baltimore, Maryland 21218 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Chauncey Repford Judith H. Johnsrud Jordan D. Cunningh a, Esquire Envimmiental Coalition on Nuclear Attorney for Newberry '1bwnship Power T.M.I. Steering Ccmmittee 433 Orlando Avenue Fox, Farr & Cunningham State College, Pennsylvania 16801 2320 North Second Street Harrisburg, Pennsylvania 17110 Marvin I. Iewis 6504 Bradford Terrace Ms. Inuise Bradford Phi 1adelphia, Pennsylvania 19149

'IMI ALERr 1011 Green Street Marjorie M. Amodt Harrisburg, Pennsylvania 17102 R. D. 5 Coatesville, Pennsylvania 19320 Attorney General of New Jersey Attn: Thcmas J. Germine, Esquire Deputy Attorney General Division of Law - Rocm 316 1100 Raymond Boulevard Newark, New Jersey 07102 Ellyn R. Weiss, Esquire Attorney for the Union of Concerned Scientists Harman & Weiss 1725 Eye Street, N.W., Suite 506 Washington, D.C.

20006 Steven C. Sholly Union of Concerned Scientists 1346 Connecticut Avenue, N.W.

Dupcnt Circle Bi41 ding, Suite 1101 Washington, D.C.

20036 Gail B. Phelps Anti-Nuclear Group Representing York l

245 West Phi 1

Willimn S. Jordan, III, Esquire Attorney for People Against Nuclear t

i Energy Hanron & Weiss 1725 Eye Street, N.W., Suite 506 l

Washington, D.C.

20006 l

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