ML20237H419

Board Exhibit B-21,consisting of Lh Bettenhausen 851007 Affidavit

ML20237H419
Person / Time
Site:	Three Mile Island
Issue date:	10/29/1986
From:	Betttenhausen NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
References
LRP-B-021, LRP-B-21, NUDOCS 8708170204
Download: ML20237H419 (6)

Text

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UNITED STATE OF AMERICA NUCLEAR REGULATORY COMMISSION 87 E 12 P12:03

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  ;{^

In the Matter of ) .

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

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

AFFIDAVI.T OF LEE H. BETTENHAUSEN I

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

1. 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 affidavif.

2. As part of my responsibilities in my current position, I manage the inspection activities relative to nuclear power plant operations and testing.

This responsibility includes the review and evaluation of reactor coolant leak rate tihsurements at facilities:within Region I.

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

?, ions raised in the " Petition of Marvin I. Lewis, Intervenor, For a Now 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 Island, Unit 1, my staff prepared, under my supervision, the

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September 6,1985', memorandum from Stewart.0. Ebneter, Director, Division of Reactor Safety, Region I, to Hugh L. Thomspon, Jr., Director, Division of Licensing, NRR. <

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5. Reactor coolant leak rate measurements are made as one method of assuring the 1$tegrity of the primary reactor coolant pressure boundary as e required by General Design Criterion 30. For pressurized water reactors (

such as Three Mile Island Unit 1 (THI-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. Thit 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

t certain identified closed loop systems which can be eventually returned to the reactor coolant system are not considered as leakage for, purposes of calculating the 10 gallon per m.inute 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 THI-1. Identification and quantification of leakage through isolable paths such as valves and valve packings is permitted within the limitations on total _x. ,

lea kag e'. When the identified leakage is subtracted from the total leakage, the ,

result is termed unidentified leakage; this unidentified leakage term has stringent Technical Specification actions required. If the TS value for unidentified leakage (1 gallon per minute for TMI-1) is exceeded the reactor plant is required to shut down. . g

6. TMI-1 and several other facilities have a provision in TS for 43 o accounting for " normal evaporative losses".before obtaining a final value of unidentified leakage. In the case of TMI-1, this evaporative loss term was g 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 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 distribution. Inspectors noted (InspectionReport 50-289/83-20) that there were often negative leak ratt 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-I have been substantially improved. These improvemebtsalsoreducedmanyuncertaintiesintheleakratecalculation.

j When this improved leak rate pr'cedure o was used during hot functional tests at l

TMI-1 and the evaporative loss term was applied, the resulting unidentified leak rates consistently were negative and nearly equal to the value of the evapontive loss. These results led first to questioning the application and, with additional data, to the recommendation that this evaporative loss term be deleted from tha THI-1 Technical Specifications, $1nce 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 diverse systems to detect leakage and, more importantly, the rate of chenge 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 balance, the following leakage detection methods are used at THI-1:

L containment air particulate radiation monitor a

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-- containm. int radioactive gts monitor

-- Taakage detection by moisturI collection and a . flow mea sur6.n-rt from the containment atmosphere cooling system

-- Reactor Builoing and A1xiliary Buildfr.g semp i vel chaiges.

All of these systems and the invento > balance nessurement provide u .. -

Q diverse me'ans of detecting leakage. u .- .~.....-=.+u ,

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8. The intent of all of these leakage detection :! stems is to meet -he guidance of Requlatory Guide 1.45, . dated May,1973 whict stated, "the sensitivity and response time for each leakage detectler. sys em. .etsplayed for unidentified leakage should be adequate to detect a leak ge rate, or its equivalent, of one spm in less than one hour." The inc],sio:. or exclusicq -f an evaporative los: term has no effect L.pon the capaolli'3 of detect'n; re,ctar coolant pressure boundary leakage from these various syst ems The foregoing and accompar.ying statement of profes:,ional qualification.; are  !

true and correct to the best of my knowled.;e.

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V Lee H. Bett nhausen Subscrib ' worn to before me this y ay Oct 'er, 1985 t l V I ,

ta/ D ublic My ommission expites:

l CY O?LINE. Notary Puol:c

! Upper Merion Tv,0. Montg. Co.

My Commission Expires Feb. 22.1986 l d l

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( - LEE H. BETTENHAUSEN l

Organization: Operations Branch, NRC, Region I -

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Title:

I Chief l Edu;ation: B.S., Engineering Science, The Pennsylvania State j University, 1956 Ph.D., Nuclear Engineering, University of Virginia, 1974 l

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.

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l 1978-1981 NRC Reactor Inspector - Inspect operating Nuclear Reactors I for compliance with Government regu1'ations.

1974-1978 Regional Radiation Representative - Region III, U.S. EPA, responsible for evaluating environmental effects of ,

radiation activities in the Middle Atlantic Staten. '

1971-1974 Lecturer 1r. 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 ud Reactor Operator - University of Virginia, Consulting Engineer.

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

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

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