ML20212D373
| ML20212D373 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/24/1987 |
| From: | Aamodt M AAMODTS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2594 LRP, NUDOCS 8703040104 | |
| Download: ML20212D373 (4) | |
Text
-
o +,
.2 5 k UNITED STATES OF AMERICA CC' M i!-
"r NUCLEAR REGUIAIORY C0bHISSION BEFORE 'IME PRESIDING BOARD
,87 FEB 26 P3 :39 p,3 FO In the Matter of
, gp
'h' INQUIRY IN'IO 'IHREE MILE ISIAND UNIT 2 l
February 24, 1987 LEAK RATE DATA FALSIFICATION j
AAh0I7P RESPONSE 'IO BOARD ORDER OF FEBRUARY 2,1987 The Board granted the Aamodts an extension until February 24, 1987 to respond to its order of February 2, 1987. Board Order February 13, 1987.
On February 20, 1987, the Aamodts informed Judge Kelley that they would not be able to respond to the extent they had anticipated when they requested the extension, if at all. They are able to respond to an important question posed by the Board in its order of February 2, 1987 concerning the Numerous Employees' Memorandum of Law, dated January 23, 1987.
'Ihe Board asked:
5.
Whether it is correct that entry into the action statement was not necessarily required when a leak rate showed unidentified leakage in excess of 1 gpm and there was no clear basis for in-validating that test -- e.g. because of an obvious operator error.
'Ihe basis for this proposition by the Employees appears to be that one of the other surveillance methods might show compliance with the 1 gpm limit. Memorandum, p. 22.
Do you agree? Bd. Order p. 2.
'Ihe operators could make estimates of reactor coolant leakage from:
O gg PDR
i l 1.
Airborne particulate radioactivity; 2.
Airborne gaseous radioactivity; 3.
Condensate flow rate from air coolers; and 4.
Containment sump inventory and discharge.
See Ex. 2, Vol. 2, pp. 35, 21.
(Results of Faegre & Benson Investigation of Allegations of Harold W. Hartman, Jr. Concerning Three Mile Island Unit 2 September 17, 1980).
The airborne particulate and gaseous radioactivity monitoring systems 1
were not sensitive enough to quantify leakage of 1 gpm. The condensate flow rate from air coolers triggered an alarm but was not quantified.
Id.,
- p. 35.
'Ihe sump pump starts could provide an estimate of unidentified leakage.
7 i
' The estimation is " limited" by the incapability of the operator to j
identify and separate other leakage into the sump than that from the reactor coolant system. Wermeil, ff. Tr. 376, p. 11.
Wbere GPU experts attempted to quantify unidentified leakage from the
(
sump data their results diverged widely. Mr. J. P. Moore reported just two l
days of operation (January 9 and 11, 1979) when the unidentified leakage was greater than technical specificatiot: of 1.0 gpm.
Ex. 2, Vol. 2, pp. 25-35
{30). MPH found periods during October 1978, and' January and March 1979, when unidentified leakage exceeded 1.0 gpm.during operation.
Ex. 1-A, Vol.1, l_
pp. 105 - 108, Vol. 3, Table IV.
(mI-2 Reactor Coolant Inventory Balance Testing, Prepared for GPU Nuclear Corp., by Edwin H. Steir, September 5, 1985)
The investigators found "no definitive evidence of the systematic cal-culation of unidentified leak rate at WI Unit 2 by any method other than the water inventory balance." Ex. 2, Vol. 2, p. 139.
The matter of the accuracy of the performance of the pump start surveillance See Footnote was not addressed, to our knowledge, and probably deserves to be.
on p. 3 infra.
l t
, Mr. Moore, in examining the data sheets for tabulating the sump pump starts, found it "significant that the sheet does not specifically direct the operator to calculate unidentified leakage, and there is no box provided on the data sheet to enter the unidentified leak rate value."
Id., p. 22. He also found that the pump start data was collected at intervals of from 16 to 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />,(id., p. 23), showing that the sump pump surveillance was not undertaken to evaluate the leak rate water inventory balance tests which were conducted one or more times per shift (eight hours). *
- The Employee proposition that the operators had other means to quantify unidentified leakage than the water inventory test is without merit, and the Board should reject the Employees' arguments based thereon.
Respectfully subnitted,
/
/L tu a(
T - [E w.r7tl -
i Marjorie M. Aamodt
.The operators were in violation of Technical Specification 4.4.6.2 in performing the sump pump surveillance less than every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
SeeEx.2,Vol.2,p.21forrestatementofsurveillance.vf4*usi~.
..V i
I l
l l
l l
~
e UNITES STATES OF AMERICA NUCLEAR REGULATORY COMMISSION c ;f.. t * !
r; BEFORE THE PRESIDING BOARD
'87 FEB 26 ' P 3 :39
)
In the Matter of
)
gg,
)
Docket No. LRPJ0 Chi' t.a DMC' INQUIRY INTO THREE MILE ISIAND UNIT 2
)
LEAK RATE DATA FALSIFICATION
)
)
This is to certify that copies of AAMODP RESPONSE 'ID BOARD ORDER OF FEBRUARY 2, 1987 were served by deposi U.S. Mail, rst class, postage prepaid, on the following Service Lis.
.Marjori& M. Aamodt February 24, 1987 I
Service Lig Harry H. Voigt, Esq.
[The Honorables Judges James L. Kelley (Chairman)
Mii:hael F. McBride, Esq.
James H. Carpenter Glenn O. Bright Robert St. John Roper, Esq.
Molly S. Boast, Esq.
Atomic Safety & Licen, sing Board James W. Moeller, Esq.
U.S. Nuclear Regulatory Commission Marlene L. Stein, Esq.
Washington, D. C. 20555 C. Christopher Sprague,'Esq.
LeBoeuf, Lamb, Leiby & MacRae Docketing & Service Branch Suite 1100 U.S. Nuclear Regulatory Commission 1333 New Hampshire Ave., N.W.
Washington, D.C. 20555 Washington, D.C. 20036 Jack Goldberg, F.sq.
Smith B. Gephart, Esq.
Mary Wagner, Esq.
Jane G. Penny, Esq.
Office.of Legal Staf f Terrence G. McGowan Esq.
U.S. Nuclear Regulatory Commission Killian & Gephart Washington, D.C. 20555 216-18 Pine Street Harrisburg, PA 17108 Ernest L. Blake, Jr., Esq.
John N. Nassikas, III, Esq.
Michael W. Maupin, Esq.
Shaw, Pittman, Potts & Trowbridge Maria C. Hensley, Esq.
2300 N Street, N.W.
Hunton & Williams Washington, D.C. 20037 P.O. Box 1535 Richmnnd, VA 23212 Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, IL 60602
.. ~._
-