ML20126C881
| ML20126C881 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1980 |
| From: | Pollard R Chesapeake Energy Alliance |
| To: | METROPOLITAN EDISON CO. |
| References | |
| NUDOCS 8004110175 | |
| Download: ML20126C881 (4) | |
Text
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UNITED STATES OF AMERICA LIC DI3:GA RESP-80.0317 j
4 NUCLEAR REGULATORY CCMMISSIOM BEFORE'THE ATOMIC SAFETY AND LICEN31NG BOARD In the Matter of
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Chesapeake Ine;ry Alliance hereby sub-its tne following answers to the interrot;ateries posed by Licensee en Januvy 16, 1960:
5-1 The 'persible interference' refer.1 to the cceunati n of stcrage tanks, pipes, etc.. wi.th radicactive water frca T:C-2 s'; as to prevent that stcrage space to be used to house cer.taninated water frem a possible accident at T C-1.
(a) The potential Unit 1 accidents assu-ri include any and all such accidenta identified and/or described by Licensoo or NRC in their responses to GA's interrogatories on this contention, along with any and all accidents that should have been included in those answers, but were omitted.
(b) The quantities of radioactivity assumed are thosa quantities are those quantitics described by Licen::ee er NRC in their answers to GA's interr-ogatories on this contention, corrected for any possible errors or omiselons.
5-2 The potential accidents during contanination and clean-up at TMI-2 that are assumed inclu:le all those accidents described by Licensee and/or by MNRC in response to: GA's interrogatories on this matter, along with those accidents that should have been included but were omitted.
5-3 The risks to the safe operation of TMI-l which CSA centends are associated with accidents at TMI-2 include those risks identified by Licensee and NRC in their answers to GA's interrogatories on this matter, along
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with any other such risks that may have.been omitted from those answers.
The specific facts, documents and persons relied upon include those facts, documents and persons identified by Licensee arxi E C.
54 The evidence of lack of effectiveness or reliability of E?I QR-II will include that provided by Licensee and NRC in the r answers to 2A interrogatories -on this subject. Repor$rs of EPICCR-II functioning less effectively than anticipated have been observed in newspapers by GA, however, the names and dates of those newspaper reports are not known to CA.
5-5 The principal element of the claim is the based on the grcwing risk from cor' osion and emb ittlement of co ponents of the reactor. coolant r
system of TMI-2 resulting frcm continued exposure of tho:,e components to high levels of radioactivity, and the ensuing greater prcbabilities
-offurtheraccidentsand/orreleasesofradioactiveeffluentsfromTMI2.
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5 The definiti::n cf ' leal' is included ib'CA's interrogstery :-tc Licensee on this matter, and the specif c infornation on each leak should be provided by Licensee and by NRC i.n their respcnses to the interrogstories fren CA en the matter.
- -2 Tha pr ncip
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- :: cod en n f r. ;t that the e.imnce cf thoca 1sne v:nutitme a yrv.2 ar in repec t.
eniin DZ-2 is not under full c~'trM.,. as w-11 is representing t.u probability that any of the leake - :' de Mlep into 1:r:;er leaks, er that additienal, nere serious loaks any develg, 64 The basis for CA's claim is sunnarized in its response to 6-2 above.
(a)
' Returning to an active emergency status' is meant by CA to refer to the resumption or development of conditions at TM-2, of the existence er ir-inent prospects of existence of release (a) of najor ancunts of radicactive effluents from TM-2, in particubir, where these conditicns are such as to call for the declaration of a site ener;ency or general emergency at TM -2.
(b) The particular risks to the safe operation of TM-1 posed by such
'enercency status' would of necessity depend of the specific ferr,, ad parameters of the e.ergency conditien at TE-2.
(c) Generally speaking, yes. 8 Severe conflict... ' is meant to nean any condition that wculd sevenly conflict with the operation of T M -1, including but not limitad to the release of sufficient radiation to IMquire the ev cuattion of the entire TE facility, and/or would term inate a
offsito and/or ensite power for the operation of TM-1.
7-1 The existence of any such irradequacies, and the facts, documents, and persens relied upon for establishing such inadequacies will be included in the responses of Licensee and NRO to 2A's interrogatorie.s on this matter.
7-2 Same answer as 7-1 above.
8-1 The specifies of the alleged
' evidence of the inadequacy of licensee's managenent capability' will be developed from information received frem Licensee and NRC in their answers to 2A's interrogatories on this subject, as will be the facts, documents, and persons relied upon by EA.
12-1 Yes 12.-2 The answers to this interrogatory include those answers to 2A's interrogatories on this subject provided by Licensee and NRC, along with any such accidentathat may be c=itted from their answers.
12-3 The specific aspects of the nexus between each of the accidents and the T E -2 accident will vary according to the particular elements of each accident' scenario. Every accident will share the common nexus of falling into the class of accidents not include 1 in the design basis of TE-1
'.2 4 CA seans by 'nct bounded' that an accident is not included in the boundaries of.that class of accidents for which the design basis of TM -1 has been established, whether 4cse boandaries refer to specifts events or to the consequences of the accidents..As to which of those
.a given accident is not bounded by, that will vary according to the
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specific char n uristics of each accident.
'. M C. has not y st devel: pod a ec-.plete set of :ritaria to be used for e d ::th ; ::cdible aceddents,
- b. vever, :n) alce:nt cf the crite-ia -111 72 "r
-- t% ?cti.m2ted probabili: cr:r the 1-:it.t f21 3 cal s a ulticl+ (pr:bac17 a factor of fivo er tan) of" tha esti=stou arebability
) ; fore ' arch 23) vf r,h- :.L 2 accident.
13-1 1he 8 -d nd0et ' to which CA refer! 1 defined at granter length in its interre.:::rtes to Licensee and Nre.:.
cas c ey.e.,-tien of the.eaning of ' tindset' does not differ siciificantly fren th'at addressed in
- TJRE": 0590.
13-2 Whi13 the CA.? pr: posed by Licennte ppears to b a the.cugh 2nd detailed trainin;; program as re ;ards the technic ti 2spects of operating e
a nuclear powe. plant, CIA has two basic reservatiens concerning the adequacy cf i':, to resolve CA's concerns in this v.atter.
- Firstly, is the questien of the extent ethat GA can be acrured that the instruct-ienal and training components are as substantdal in practice as they appear en paper ( a frequent scuree of discrepane,t found in education in ;;cneral, and in in-service trainin;; in particular). Secondly, there is the absence of a clear strategy en beh?.f of Licencee to address the devc1cpment of mindsot specifically--semi.r. sing that GA notes, can not under any circunstances be accenpliched in a ons time training program, but nu t be addressed in terns of an engeing nenitoring program, along with'sensitication of staff and supetvisers to the process by which
.mindset can develop and to ways to combat its development.
13-3 The same answer applies as to 13-2 above.
Ibl At this poiht, absent the funds and resources with which it could be able to present witnesses of its own, CEA expects that it will have to rely on cross examination of witnesres presented by Licensee and NRC, and on examir.ation of witnesses pre:: anted by other intervenors with I
contentiens analogous to those of CEA.
o Respectfull'y subnitted '
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b CHESAFEAKE ENERGY ALLIANG, INC.
By Robert Q. Pollard Dated: March 17, 1980.
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L;i!.TED STA:F.A 0F AMERICA L!C0:3: 2A;EI? 3C.C3.17 IiUCLEAR RECULATORY C0!OiISSIO!i i.
BEFORE TiiE ATOMIC SAFETY _Afin LICENSijlj: BOAP.D in the ". aller Of
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'a. j j CERTIFICATE CF ';'J.i'/ ICE 1 do hereby certify that I served a true and corrcet copy of the cbove-lebelled dccument on the below listed parties by first-class mailing:
Ivan W. Smith, Esquire Atomic Safety & Licensing Boat d Panel U.S. Nuc! car Regulatory Commission Washington, DC 20555 0
Dr. Walter II. Jordan
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381 West Outer Drive
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WRC Oak Ridge, TN 37830
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MAR 2 51980> 2 Dr. Linda W. Little W
Office of thaSacretmy 5000 liermitage Drive
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Raleigh, NC 27612 cb O
George F. Trowbridge, Esquire Shaw, Pittman, Potts & Tiowbiidge 1300 M Street, N.W.
Washington, DC 20006 4
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 E::ocutive I.ogal Director U.S. Nuclear Regulatory Cemmission Washington, DC 20555 I
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