ML19305C549

Fourth Set of Interrogatories & Further Discovery Requests Directed to Nrc.Includes Questions Re Anonymous Informants' Tips on Const & Maint Concerning Filters & Vent Header, Storage & Handling of Radwaste & Purification Sys

ML19305C549
Person / Time
Site:	Three Mile Island
Issue date:	02/27/1980
From:	Lewis M AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19305C535	List: ML19305C534 ML19305C537 ML19305C549
References
NUDOCS 8003310041
Download: ML19305C549 (6)

Text

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O BE10aB Taz iTOM1a SirETr iND t1CENS1NG BoiRD.  : 9 m 22 eo " IN the matter of ) arrM C22232GCN goeS METROPOLITAN EDISON COMPANY ) Docket No. 50-289. , ** (Three Mile Island , No.1) ) {g  ? Intervenor Lewis's FOHRTH SET OF INTERROGATORIES AND.FURTHER DISCOVERY REQUESTS TO NEE NRC STAFF. D_ipcovery Reouests:

1. Please send a copy of NRC Eranslation 628(See letter from '

Varga to all Boards dated 1-24-80 ) in the original' Japanese.)

2. Ms Barley is temporarily without a car. She requires a c'opy of the Rog& vin Report. This report was supp)ied previously to intervenors. Intervenor Lewis cannot share his copy due to distance . and due to the fact both people work full time jobs.

Send Ms Barley a copy of the Rogovin Report at Susan Barley 129 Cocoa Hershay PA 17033.

3. Intervenor Lfewis wished to provide the Staff with Ms Barley's mailing address so that the Staff may fulfil The Board's Order of 2-13-80 ansix at the Pre Hearing Conf -

erence to ' add Ms Barley's name to the Staff's mailing list in this Docket: Susan Barley 129 Cocoa Hershey PA 17033. j Ms Barley requested that her name be added to the taff's , Licensee, and Board mailings only. Ms Barley does not require that she get all the Intervenor l mailings uhless they specifically impinge upon the . Lewis Contention. 4/ Send the Following documents: Regulatory Guide 1.52 ANSI 510-1975 8003sloOLLl

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• Intervenor Lowie's F0HRTH SET OF INTERROGATORIES TO NRC STAFP NRC 29. The Status. Report dated 1-11-80 is much greater than the 8 1/2 x 11" size ordered by the Board in its first Prehearing Conference._ Intervenor Lewis does not remember Staff objected to that size at the time Chairman Smith specified it. '

Obviously , the "taff received permission to use other than i 8 1/2 x 11" from the Board. The Staff would not break or i ignore a Board Order unilaterally. Nonetheless, Intervenor Lewis has se.en no guidance concerning new sizes of paper for submitthis which are now allowed. d ince Intervenor Lewis has very limited Ililing space, he

• requires to know what sizes of paper to expect from StaII in their filings.

What sizes of paper will staff use in their future filings specifically with reference to Status Reports? NRC 30. Has some means been promoted for the NRC to obtain anonymous tips from informants as to paactices on the constructinn and maintenance of the TMI#1 facility? This concern is 44 especially pertinent to the Lewis Contention as the filters and vent header are deep within the facility and any adverse handling or practices would not easily be reported without the threat of anonymous tips. Please note that the problems 21 Wetinghouse Turbine Cracking (Varga: Knight:BO,16Tx 1,16.) and concrete problems at Wolf Creek and Summer were also brought to light thru anonymous

    . tips.

NRC 31. The letters NRC /TMI 80-028 and Eisenhut:All Power Reactor Licensees -80.01.297 rabe several issues which are explored in the following interrogatories. . A. What provisions , if any , are presently in place to guarantee that the requirements specified in Eisenhut:All Power Reactor Licensees-80.01.29 can be met? Answer with specificity for delay and decay tank bottoms, spent charcoal and HEPA filter media pertinent to the Lewis Contention. B. What guarantees are in place to assure that spent filter media can be moved off site to appropriate low level waste sites? Are LLW sites available now and in the future? - C. Referring to Kemeny Report ,Page 30, Item 11.

3. .

    ,     "Icding filtora in the auxiliary and fuel handling buildings did not p;rform as designed because the charcoal filtering capacity   was apparently partially expended due to improper use beforethe accident . Required testing far of filter effectiveness for the fuel hand 14ng building had been waived by the NRC . There were no testing requirements to verify auxiliary building filter effectiveness."

C-1 What was "the improper use" referrei to in the quote above from the Kemeney Connission? Give type of use; dates; who authorized; where written authorizationa , auch as logs, work or job tickets, proper paperwork stored?xxA 8end copies if not ir an eaelly , accessible public reading room of all

• supporting documents referred to in thisxx the answer to tM gggg this and all interro6storio9.7 G@#h C-2 Ehen, why', and how was " required testing for filter E55d effectiveness for the fuel handlin.; building ... waived i gggg by the NRC"? Specify nanes , dates, cend copies of letters E553 and any other pertinent docunentation with youranswer.

hfE[ C-3 Considerin g that there were " no tentin6 requirements E5j$ to verify auxiliary building filter effectivenens",was ci= ggga thelicenseeopedr$tinginviolationof ICC'R 50 Appendix A F--" GDC 41 "dystems to control fission products... shall be provided as necessary to reduce...the concentration and quality of fiosien producte releaned to the environmen.tt." GDC 60 All. < GDC 61 The fuel storage and handl&ng, radioactive waste, and other cystems which may contain radioactivity shall be designed to asnure adequate safety under normal and postulcted accident conditions. These systetsskill be designed (1) with a capacity to permit appropriate periodic intpection and testing... (3)with apppopriate containment , confinement and filtering systema." C-417as the NRC knowingly allowing the Licencee to operate in violation to any GDC? C-5 Did the /ITRC allow the Licensee to operate without checking the effectiveness of the filter media because there was a problem of three to get rid of the loa Level waste generated in the filtering systems? ras thic c form of re1N1f granted to the Licensee by the XRC to circumvent a LLh disposal probleg? Has any form of IL;i been refused at any site from TMI? If so, have the intervenors received any notification of said refusal xts and why?

1 4. NRC 32. Rofor to NRC/TMI 80-020 ; NRC /TMI 80-022 ; and NRC l News Release I-80-26 (Region 1.)

        . A. Is the problem described in NRC/E4I 80-020 similar for               i units land 27    Have all fan and filter Dousings been checked at both units for compatibility? When , by wh6m, documentations?

B. How will a drop of AB negative pressure requirements Affect t the ogration of filters and filter housings if at all? (Engx Leak rates, conddhation transfer to electrical pumps, from the surface ofthe filter housing, and any other pertinent , changesinoperatingpar{{eters.) NRC /TMI 80-022. C. NRC News Release I-80-26 3rd Paragraph. "The releases apparently were caused by radioactive.waterin a water . purification system ( ion exchanger) seeping past a valve and into piping normally used to carry radioactive gases to a building shautxBx23txxf exhaust and to the plant stack." Have the filter systems and vent systems been corrected so that this event cannot be repeated at TMI#1? If so, how so? Provide working drawings and engineering analysis. If not, when will it be corrected? How will it be corrected? Provide schedule and program for correcting this deficiency. NRC'33. Supplemental Views by Members of President's Commission on the Accident at Three Mile Island on Page 12 , Commissioner Pigford states , "Although other components, systems, or features are classed as "non safety related" , they must meet require - ments appropriate to their operational function." A. What requirements applied to the filters and vent header

      ,       during the day of the accident at TMI#2? Ylere they met?

Will the same requirements hold for TMI#1 if and when it goes back on line? NRC 34. Letter Plesset : Aherne 80.02.11 states,e The ACRS believes that its input into this process has been largely ignored by the Commission and is concerned the the ' rush to judgment'on those important matters may result in, at l worst , error and at best inefficient use of resources important to safety." l Has any input from the ACRS been factored into the TMI restart effect? Specifically, of the question of vent headers and filters. If so , provide documentation.

5.

 ,c'            NRC 35.

The anewer to NRC 2 io not responsive; howver, rather than going thru the objection route , Intervenor Lewis resubmits an expanded NRC 2 as NRC 35. How are the answers in NRC #1 specifically going to help the filters and vent header work conrectly and and adequately in a repeat of March 28 accident at TMI#1? . i By specifically, cite problem ( leak at pump seal), how discovered (metallurgical examination by MetLab, Mr So and Sa) how corrected (work order , NRC approval, LER #, I&E action #) and any other facts which would provide assurance that the action was properly grounded on fact and in fact accomplished . Do this both for vent header and all filters which did not - operate within expected limits. See NRC 31 C for guidance on which filters to include. Stde and document how this is being done on a continuing basis. NRC 36. NRC 10 was objected to as " burden-some and improper. " It was not meant to be. It is rewritted and resubmitted as NRC 36. The Licensee has supplied everyone on the Distribution List with his answers to Lewis Interrogatories . The Staff will read (or appropr6 ate S'taffer) the Licensee's answers to Lewis Interrogatories, and answer thef following : A. Are the Licensee's answer's to Lewis Interrogatories accurate? No opinion on responsiveness is asked. B. If any of the above answers are not accurate, would the Licensee je,opardi{e the health and safefy of the public by implementing said inaccuracies?

     '      HRC Ezer 37. The Staff's answer to NRC 8 is not responsive in thatitdoes$$$Igivetimesnorstatethattheyareunavailable.

Intervenor Lewis is not objecting to this answer since he has obtained sufficient times and dates on his and his associate's researches. One question remains: DoestheStaffagreewiththedatesfndtimesofreleasesreferred to in the Rogovin and Kemeny Reports? In order to reduce the burden , the S aff need only answer for the major document and t not the Staff reports. However, Intervenor Lewis reserves the right to refer to above mentioned Staff reports in dir( and indirect testimony. _ v

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6. Intorvanor Lsain's FOURTH SE2 OF INTERROGATORIES TO LICENSEE'.

                          ,      SP C2 28. The answer to SP 2 is not responsive. No attempt is made to answer the sentence," Include where in the Restart Report this particular pathway is eliminated or repaired."

Ratherthan go thru the objection route , the expanded SP2 is, refiled as SP 28. A. State which materials , filters, and items did not worR as well as expected in the vent header and filters. B. State the page number and the paragraph number in the A Restart Report where this problem is investigated. C. State the page number in the Restart Report wheref ' remedial action is described to eliminate each particular problem observed at TMI#2 from TMI#1 in the vent header

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and the filters. The answer to SP 28 requires that page numbers be f cited to be responsive.

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SP 29. The Attachments for SP 5 and SP 1$ are grossly inadequate. Intervenor L ewis sincerely hopes that these are not the size for lettering used on drawings distributed on site. The letters ate so small as to be completely illegible. Resubmit working drawings as specified in SP 5 and SP 21 21 12 which meet the following guidelines: Lettering shall be of such a size that the smallest letter la easily read,by a person with unaided 20-20 vision. Do not send a schematin as ymaxxx yamur your entire attachment. Submit a working drawing which gives details such as ductwork , assemblies, materials and instructions to workers. SP 30. Where did the data in SP 11 attachment A originate? SP 31. Intervenor Lewis cannot find index to drawingpin Reptart Report. It may have been mislaid. Instruct Gilbert Associates to send another index of drawings in restart report to 6504 Bradford Ter. Ph61a. Pa19149 .

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