ML20128A544

Protests Sections of Amend 108 to License DPR-50,including Removal of Hydrogen Purge Sys Tech Specs & Assumptions Allowing Operation W/Steam Generator Tube Rupture & High I-131 Readings

ML20128A544
Person / Time
Site:	Crane
Issue date:	05/20/1985
From:	Lewis M LEWIS, M.
To:	Stolz J NRC
References
NUDOCS 8505240254
Download: ML20128A544 (2)

Text

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e M. l. LEWIS 6504 BRADFORD TERR.

j Mr John F. Stolz PHILA., PA.19149 mNRC Kashingttn, D.C. 2555

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Dear Sir:

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This letter is a protest against parts.of the Amendment 108 to OL DPR 50 dated f

May 8,1985 in your comer letter to Henry Hukill.

Your cover letter states that the hydrogen purge system TSs ate removed because d

they are no longer needed to perform a safety related function.

1. What was the safety related function of the hydrogen purge system that is 1

no longer needed and why?

2. Is this" function " no longer cafety related or is there a safety related system j

that is now dedicated to perform this " function?"

c Page 3-9 of the amendment states," steam generator tube rupture."

1 In this a single steam generator tube rupture or is there an assumption that the arc of the ruptured tube does not hit and rupture other tubes after the first tube breaks?

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2. Is there a further assumption that the tube is a failure on its own and not the effectof another situation cuch as overpressurizatbn of some other

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part of the system or exceeding of other limiting conditions of operation?

Instherwords how is the assumption of tube rupture made? Is it one single tube failing for random reasons without any other system initiating the tube failure and does the failed tube interact in any way with other tubes degraded or not.?

1. 3 Also on this page there are many assumptions that would allow for operation while a f.ube might be ruptured and for operation while high I 131 is being read.

In fact this page reads like an invitation for the GPU management to perform the 9

same maneuvers for testing of I 13.1 as were performed to hide the leak of water at TMI 1 and 2 pri>r to the accident. A good technician could find many ways to hide a I 131 leak given tre proviso's on Page 3-9 to hide the operation of a nuclear power plant despite the so-called limitation provided.

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My protest is simply trat the entire change is written as.an invitation to cheat on the very requirements that are supposed to protect the public. This y

company has a record in the TMI hearings of cheating on leak testing and operator testing. There is no need to give this company more opportunities to cheat. Clear rules that do not provide may proviso's thru which cheating 1 1) is invited would be most appreciated by the public.

Very truly yours, (66Qsi j ? d J' 3..-

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