ML19312D823

Answers to Applicant Interrogatories Re TMI-2 Related Contentions.Urges Consideration of Possible Component Interactions Per Sandia Labs 791221 Rept Re Interaction Methodology.W/Certificate of Svc,Affidavit & Cover Ltr

ML19312D823
Person / Time
Site:	Waterford
Issue date:	03/24/1980
From:	Irving S LOUISIANA CONSUMER'S LEAGUE, INC.
To:	LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8005050177
Download: ML19312D823 (8)

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UNITED STATES OF AMERICA O O NUCLEAR REGULATORY COM4ISSION Cv s Before the Atomic Safety and Licensine Boar In the Matter of LOUISIANA POWER AND LIGHT COMPANY DOCKET NO. 50-382

[Waterford Steam Electric Station, Unit 3)

ANSWERS TO APPLICANT'S INTERROGATORIES ON TMI-2 RELATED CONTENTIONS OF LOUISIANA CONSUMER'S LEAGUE DTI'ERROGATORY 1-1:

It is impossible at this time for the LCL to identify all possible interactions between safety related and non-safety re-Lated components included in its TMI contention number 1. This Lssue is being considered in the development of a document en-titled, "NRC Action Plans Developed as a Result of the TMI Accident", NUREG 0660;the latest draft of which is dated March 5, L980. Until this document is published and LP&L has responded thereto it will not be possible to identify what steps will be required by the NRC with regard to component interactions. It is also possible that some systems not now classified as safety re-l Lated will be reclassified. All possible component interactions l

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Ldentified in a report from Sandia Laboratories entitled, " Systems Interaction Methodoloev Aeolications Program" by Boyd G. Jay, et 11., dated December 21, 1979 and/or a letter from Mr. Max Carlson, hairman, Addisory Co:::mittee on Reactor Safeguards to Mr. Lee ossick dated October 12, 1979 and published in NRC New Releases

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No.79-183 should be considered. Also all components which are l i

not considered safety related due to the existance of alternate or backup systems are included.

INTERROGATORY 2-1:

Generally occurring after the event, certadn operation actions such as the operation of the plant with till emergency feedwater flow paths isolated can occur before + he incident, be a contributor to the incident and have consequer.ces thereafter.

This should also be considered.

INTERROGATORY 2-2:

(1) FSAR Chapter 15.6.3.1.3.3. The applicant should con-sider the effect of an operator failing to recognize the event as a LOCA for a period of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. It should be assumed

- that an operator, actinc under such a belief, might throttle back the HPSI pumps for the same 2A hour period. During the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ,

period it should not be assumed that the operator would take any action inconsistent with his belief that a LOCA had not occurred.

( 2 ) 15. 6. 3. 2.1. 2. Assume the same operator actions as in the small break LOCA above. Assume that because the operator does

- not believe a LOCA has occurred he does not isolate the faulty steam generator for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

(3) 15.6.3.222. Assume that the operator has previously Lsolated all emergency feedwater systems. Also assume the operator.

throttles the HPSI for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and takes no action inconsistent alth a belief that a LOCA has not occurred.

(A) 15.7.3.1.1. Assume that previous operator actions have caused a 90f. fuel rod failure.

INTERROGATORY 3-1:

(1) An operator or technician at Three Mile Island closed all emergency feedwater block valves and failed to reopen them.

NUREG 0600, pg. I-1-13.

(2) The operators failed to recognize that the emergency feedwater flow was blocked. NUREG 0600, pg. I-2-L.

(3) The operators at Three Mile Island failed to recognize that a LOCA had occurred for at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. NUREG 0600, pgs.

I-2-19, I-2-20, and I-2-31; Volume 1 - Three Miles Island - A; Recort to the Co=nissioners and to the Public; Mitchell Rogovin, Director; George T. Frampton, Jr. , Deputy Director - Nuclear Regulatory Commission Special Inquiry Group.

(L) The operators at Three Mlle Island failed to isolate a leaking valve for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 19 minutes. NUREG 0600, pg. I-2-3.

(5) The operators spent considerable time believing that a steam generator was leaking rather than the pressurizer valve which was the actual leak. NUREG 0600, pg. I-2-30.

(6) The operators throttled the HOP flow and the emergency j feedwater flow during the accident. NUREG 0600, pgs. I-2-7, I 8, I-2-9, and I-2-15.

A review of any of the literature on Three N11e Island com-pels a conclusion that 1800 seconds is not a conservative period

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within which to identify a problem if the circumstances are extra-ordinary.

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INTERROGATORY L-18 This interrogatory is unclear as to whether you mean fission products released from the core or released into the environment.

It is also important to note that much of what has been written about radiation introduced into the environment at "II states a dose or dose rate rather than a fission product release.

It must also be pointed out that the publi:;hed doses are based on sporadically measured dose rates and c ticulations which contain known flaws. See NUREG 0600, pg. II-3-90.

If the interrogatory means fission product relt.ases from the core the LCL believes the best available source is: Paul Cohen, Fission Product Release from the Core, Three Mile Island 2, July l

20, 1979 referenced in the Technical Staff Analysis Report on Core )

Damage to the President's Commission on the Accident at Three Mile Island.

If the interrogatory means fission product releases into the environment then the LCL believes the best available source is 1 probably a memorandum from Lake Barrett entitled, "Preliminarv

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Estimates of Radioactivity Releases from Three Mile Island,"

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dated April 12, 1979. These emissions were calculated to be 13 million curies of Xel33 and 1.E curies of I-131. It must also be pointed out that total emissions from the accident are over

, until the plant is cleaned up. There is presently a strong likeli-l hood of, substantial releases in the future from TMI.

Respectfully submitted,.

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STNH W M.'IRVIN Dated: March 2L, 1980 Attorney for int rvenors ,

l Louisiana Cons .er's League,I.H 8

One American Pldce Suite 1601 Baton Rouge, LA 7082$

(50L) 333-9970 l

CERTIFICAT;E I hereby certify that a copy of the above and foregoing document entitled " Answers to Applicant's Interrogatoriea on TMI-2 Related Contentions of Louisiana Consumer's League" were served on those persons listed on the attached Service List by deposit in the United States mail, first class, postage prepaid, to the last known address, this 29 th day of March,1980.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COM4ISSION Before the Atomic Safety and Licensine Board In the Matter of LOUISIANA POWER AND LIGHT COMPANY DOCKET NO. 50-382 (Waterford Steam Electric Station, Unit 3)

SERVICE-LIST Sheldon J. Wolfe, Esq. Lyman L. Jones, Jr., Esq.

Chairman, Atomic Safety and Gillespie & Jones Licensing Board 1A20 Veterans Memorial Blvd.

U.S. Nuclear Regulatory Suite 201 Commission Metairie, LA 70005 i Washington, D.C. 20555 I Luke B. Fontana, Esq.

' Dr. Harry Foreman 824 Esplanade Avenue Director, Center for New Orleans, LA 70116 Poupulation Studies Box 395, Mayo Harry H. Glasspiegel, Esq.

University of Minnesota Ernest L. Blake, Jr.

Funneapolis,. Minnesota 55455 Counsel for Applicants Shaw, Pittman, Potts &

Jr. Walter H. Jordan Trowbridge

$31 West Guter Drive 1800 M Street, N.W.

Oak Ridge, Tennessee 37830 Washington, D.C. 20036 Henry J. McGurren, Esq. Atomic Safety & Licensing Office of the Executive Legal Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555

, Washington, D.C. 20555 Atomic Safety & Licensing Docketing and Service Section(21) Appeal Board Panel Office of the Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission l Washington, D.C. 20555 Washington, D.C. 20555 1

I LI.ATED COIIE3 POND AFFIDAVIT STATE OF LOUISIANA PARISH OF EAST BATON ROUGE BEFORE ME, the undersigned authority, personally came and appeared Stephen Miller Irving, who, after being by me first duly sworn, did depose and say that the above and foregoing " Answers to Applicant's Interrogatories on TMI-2 Related Contentions of Louisiana Consumers's League" are turn and correct to the best of his knowledge and belief.

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,.- ,s. s STIPHEN MILLER IRVING SWORN TO AND SUBSCRIBED BEFORE ME this -71 Aday of March, 1980.

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Public Law Utilities Group

]O, One American Place, Suite 1601 Baton Rouge, Loulslana 70825 (504)383-9970 )

Stephen M. Irving, Director dh  !

Doris Falkenheiner, Assistant Director .

l March 24, 1980 Mr. Harry Glasspiegel, Esq.  !

Mr. Ernest L. Blake, Jr., Esq.

Shaw, Pittman, Potts and l Trowbridge l 1800 M Street, N.W.  !

Washington, D.C. 20036 RE: Louisiana Power and Light Company (Waterford Steam Electric Station, Unit 2);

No. 50-382

Dear Sirs:

Please find enclosed our " Answers to Applicant's Interrogatories on TMI-2 Related Contentions of Louisiana Consumer's League".

Sincer ,

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- hen M. Irving Docmgo Counsel for Int ,enors - , usNac Louisiana Constimer's League, Inc. 9- g3 CC: See Service List ,

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g An agency of the Louisiana Consumers'llag'ue,Inc., funded by the Community Services Administration P

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