ML20133H143

Affidavit of Lh Bettenhausen Re Allegations Raised by Mi Lewis 850919 Petition for New & Expanded Contention Concerning Hartman Leak Rate Allegations.Certificate of Svc Encl

ML20133H143
Person / Time
Site:	Three Mile Island
Issue date:	10/07/1985
From:	Bettenhausen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133H131	List: ML20133H129 ML20133H143
References
SP, NUDOCS 8510160284
Download: ML20133H143 (7)

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UNITED STATE OF AMERICA

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NUCLEAR REGULATORY COMMISSION

! BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289

! (Three Mile Island Nuclear Station, Unit No. 1) )

AFFIDAVIT OF LEE H. BETTENHAUSEN I i

l I, Lee H. Bettenhausen, being duly sworn, state as follows:

! I. I am the Chief, Operations Branch, Division of Reactor. Safety, Region I, United States Nuclear Regulatory Commission. A copy of my professional qualifications is attached to this affidavit.

2. As part of my responsibilities in my current position, I manage the I

j- inspection activities relative to nuclear power plant operations and testing.

This responsibility includes the revie,t and evaluation of reactor coolant leak rate Nasurements at facilities within Region I.

3 3. The purpose of this affidavit is to address certain of the allega-

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.i tions raised in the " Petition of ,":rvin I. Lewis, Intervenor, For a New and Expanded Contention Concerning the Hartman Leak Rate Allegations", dated September 19, 1985.

4. As a result of NRC. inspection's of reactor coolant leak rate tests at Three Mile Is1&nd, Unit 1, my staff prepared, under my supervision, the

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i September 6, 1985' r.emorandum from Stewart:D. Ebneter, Director, Division of Reactor Safety, Region I, to Hugh L. Thomspon, Jr., Director, Division of I

Licensing, NRR. <

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5. Reactor coolant leak rate measurements are made as one method of assuring the integrity of the primary reactor coolant pressure boundary as required by General Design Criterion 30. For pressurized water reactors

. such as Three Mile Island Unit 1 (TMI-1), these leak rate measurements are

[ performed by taking an inventory of reactor coolant system fluid over some fixed period of time. The changes in inventory as the result of temperature, pressure, inflow, outflow and level changes are accounted for in obtaining

a total reactor coolant leakage rate. This total leakage rate is limited by Technical Specifications (TS) for Three Mile Island, Unit 1. The limit is 10 gallons per minute. This TS was originally issued.in April, 1974. Losses through certain identified closed loop systems which can be eventually returned to the i reacter coolant system are not considered as leakage for_ purposes of calculating the 10 gallon per minute limit, so long as the sum of these losses and the total leakage rate does not exceed a TS limit of 30 gallons per minute for TMI-1. Identification and quantification of leakage through isolable paths i

such as valves and valve packings is permitted within the limitations on total

[ 1eakage. When the identified leakage is subtracted from the total leakage, the result is termed unidentified leakage; this unidentified leakage term has 1

! stringent Technical Specification actions required. If the TS value for

!- unidentified leakage (1 gallon per minute for TMI-1) is exceeded the reacter plant is required to shut down.

l 6. TMI-1 and several other facilities have a provision in TS for accounting for " normal evaporative losses".before obtaining a final value of l

unidentified leakage. In the case of THI-1, this evaporative loss term was obtained during a preoperational test, TP600/10 "RCS Hot Leakage Test",

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_3 performed March 14, 1974. The term has been used continuously at TMI-1.ever i

since that d' ate.

When the water inventory balance is done carefully for a reactor coolant system without leakage, the resultant leakage should be zero; repeated determinations should give results statistically distributed about zero, with some negative and positive values in the distributton. Inspectors noted (Inspection Report 50-289/83-20) that there were often negative leak rate results at THI-1. Inquiry into the reasons for this led to questioning the application of the evaporative loss term. As a result of many influences, the RCS leak rate determinations at TMI-1 have been substantially improved.

These improvements also reduced many uncertainties in the leak rate calculation.

When this improved leak rate procedure was used during hot functional tests at TMI-I and the evaporative loss term was applied, the resulting unidentified leak rates consistently were negative and nearly equal to the value of the evaporative loss. These results led first to questtoning the application and, with additional data, to the recommendation that this evaporative loss term be deleted from the TMI-I Technical Specifications, since it no longer appears to be applicable.

7. The inclusion or exclusion of the evaporative loss term has no impact upon safety. The important safety considerations regarding reactor coolant system leakage are that there be diverso systems to detect leakage and, more importantly, the rate of change of leakage be quickly evident and prompt action

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taken to place the plant in a safe condition. In addition to the inventory

.l balance, the following leakage detection methods are used at TMI-1:

containment air particulate radiation monitor

-- containmznt radioactive gas monitor 1

-- leakage detection by moisture collection and < . flow tree sp ee rt 'rdn the containment atmosphere cooling system

-- Reactor Builcing and Auxiliary Buildir.g sump I ,el cha ges.

All of these systems and the invento > balance neasurement provide diverse means of detecting leakage. - . . - i--= ~ 4.. - u..

8. The intent of all of these leakage detection :! stems is to meet the guidance of Regulatory Guice 1.45, dated May,1973 whict stated, "the sensitivity and response time for each leakage cetectirr sys;em. .enp10yEd fo' unidentified leakage should be adequate to detect a leak ge rate, or its equivalent, of one gpn in less than one hour." The incl,:,ior cr exclusicq :f an evaporative lost term has no effect upon the capaoili 3 of detecc'n; reactar coolant pressure boundary leakage from these var'ous syst ems The foregoing and a ccorrparyteg stateme71 of professional ;ualificatirn; etc true and correct to the best of my knowledge.

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U Lee H. Bett nhausen Subscrib

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this swor[ntobeforerue ay 0ct er, 1985 '

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V taff?ublic My ommission expires: _

CY D?LINE. Nciary Puol:c Upper Merion Top, Montg. Co.

My Commission Expires Feb. 22,1986

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l LEE H. BETTENHAUSEN Organization: Operations Branch, NRC, Region I

Title:

Chief Education: B.S., Engineering Science, The Pennsylvania State University, 1956 Ph.D. , Nuclear Engineering, University of Virginia,1974 Experience:

1985-Present Chief. Operations Branch - Manage inspection sections for testing, operations and quality assurance.

1981-1985 Chief. Test Programs Section - Supervise inspectors performing preoperational start-up and leakage tests.

1978-1981 NRC Reactor Inspector - Inspect operating Nuclear Reactors for ccspliance with Government regul'ations.

1974-1978 Regional Radiation Representative - Region III, U.S. EPA, responsible for evaluating environmental effects of radiation activities in the Middle Atlantic States.

1971-1974 Lecturer in Nuclear Engineering, - University of Virginia, Instructor in Nuclear Engineering, Nuclear Weapon Effects, Radiation Monitoring and other topics in formal classroom and field courses.

1966-1971 Graduate Student and Reactor Operator - University of Virginia, Consulting Engineer.

1959-1966 Research Scientist - Battelle Memorial Institute, Columbus, Ohio-Research in a variety of nuclear reactor, nuclear weapon and applied physics problems.

1956-1959 Weather Officer - U.S. Air Force 1956 Research Engineer - Curtiss-Wright Corporation,-Quehanna, Pennsylvania.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION cc 7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

• e5 (CT ~ 5 A10 :34 In the Matter of ) g,ygg ,

METROPOLITAN EDIS0N COMPANY, ET AL.) Docket No. 50-289 $Nfic

) (Restart)

(Three Mile Island Nuclear Station,)

Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S ANSWER TO PETITION OF MARVIN I. 1.EWIS, INTERVEN0R, FOR A NEW OR EXPANDED CONTENTION CONCERNING THE HARTMAN LEAK RATE ALLEGATIONS" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 9th day of October, 1985: i

• Ivan W. Smith Mr. Thomas Gerusky Administrative Law Judge Bureau of Radiation Protection Atomic Safety & Licensing Board Dept. of Environmental Resources U.S. Nuclear Regulatory Commission P. O. Box 2063 Washington, DC 20555 Harrisburg, PA 17120

• Sheldon J. Wolfe George F. Trowbridge, Esq.

Administrative Judge Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Board 1800 M Street, NW U.S. Nuclear Regulatory Commission Washington, DC 20036 Washington, DC 20555 Thomas Y. Au, Esq.

• Gustave A. Linenberger, Jr. Office of Chief Counsel Administrative Judge Department of Environmental Resources Atomic Safety & Licensing Board 505 Executive House, P.O. Box 2357 U.S. Nuclear Regulatory Commission Harris 0*urg, PA 17120 Washington, DC 20555 Michael W. Maupin, Esq.

Ms. Marjorie Aamodt Hunton & Williams 200 North Church Street 707 East Main Street Parkesburg, PA 19365 P.O. Box 1535 Richmond, VA 23212

Mr. Marvin I. Lewis William S. Jordan, III, Esq.

6504 Bradford Terrace Harmon, Weiss & Jordan Philadelphia, PA 19149 2001 S Street, NW Suite 430 Mr. C. W. Smyth, Manager Washington, DC 20009 Licensing TMI-1 Three Mile Island Nuclear Station Lynne Bernabei, Esq.

P. O. Box 480 Government Accountability Project Middletown, PA 17057 1555 Connecticut Ave., NW Washington, DC 20009 Ms. Jane Lee 183 Valley Road Jordan D. Cunningham, Esq.

Etters, PA 17319 Fox, Farr and Cunningham 2320 North 2nd Street Allen R. Carter, Chairman Harrisburg, PA 17110 Joint Legislative Committee on Energy Post Office Box 142 Louise Bradford Suite 513 Three Mile Island Alert Senate Gressette Building 1011 Green Street Columbia, South Carolina 29202 Harrisburg, PA 17102 Chauncey Kepford Ellyn R. Weiss, Esq.

Judith Johnsrud Harmon, Weiss & Jordan Environmental Coalition on Nuclear Power 2001 S Street, NW 433 Orlando Avenue Suite 430 State College, PA 16801 Washington, DC 20009 Frieda Berryhill, Chairman

• Atomic Safety & Licensing Coalition for Nuclear Power Plant Appeal Board Postponement U.S. Nuclear Regulatory Conunission 2610 Grendon Drive Washington, DC 20555 Wilmington, Delaware 19808

• Atomic Safety & Licensing Board Mr. Henry D. Hukill U.S. Nuclear Regulatory Commission Vice President Washington, DC 20555 GPU Nuclear Corporation Post Office Box 480

• Docketing & Service Section Middletown, PA 17057 Office of the Secretary U.S. Nuclear Regulatory Commission Michael McBride, Est;. Washington, DC 20555 LeBoeuf, Lamb, Leiby & McRae Suite 1100 1333 New Hampshire Avenue, NW Washington, DC 20036 tQ Lois R. Finkelstein Counsel for NRC Staff