ML20116L190

Comments on 850115 Amend to Aamodt 850115 Motion Re Licensee Integrity.Implication That Transuranics Contained in Missing Tons of Core Matl Were Discharged Directly to Environ Is Incorrect.Certificate of Svc Encl

ML20116L190
Person / Time
Site:	Three Mile Island
Issue date:	04/30/1985
From:	Blake E METROPOLITAN EDISON CO.
To:	NRC COMMISSION (OCM)
References
CON-#285-817 SP, NUDOCS 8505030519
Download: ML20116L190 (7)

Text

I' 3O a

g .- . . _ . , ,

April 30, l'985 BSCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '

15 MAY -2 5I :21 BEFORE THE COMMISSION 0FFICE OF SECRETAR

00CKETING & SERVICE BRANCH In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S COMMENTS ON AMENDMENT TO AAMODT MOTION OF JANUARY 15, 1985 In a document entitled " Amendment to Aamodt Motion of January 15, 1985 Additional Health Matters Which Must be Con-sidered Prior-to the Commission's Decision on Restart of Unit 1" and dated April 13, 1985,1! the Aamcdts have submitted addi-tional input to the Commission on the subject of their earlier January 15, 1985 motion. The Amendment includes argument on l

l Licensee's integrity. Licensee provides the following comments l

! on that aspect of the Aamodts' Amendment which postulates that Licensee and the NRC knew in 1980 that the accident had been j more severe than was publicly stated. -

The Aamodts assert that it was known in 1980 that core l

i temperatures exceeded 5000 degrees Fahrenheit when l~

1/ Licensee was served by mail on April 15, 1985. See "Erra-ta -- Amendment to Aamodt Motion of January 15, 1985" (undated).

8505030519 850430 PDR Q

ADOCK 05000289 PDR 6/

x L.

i*

transuranics from the core were observed on filters. Aamodt Amendment at 17. The Aamodts further submit it was recognized at the same time that transuranics which are alpha emitters could have been released to the environment during the acci- .

dent but such information was withheld. Id. at 17-18. There are a number of fallacies in the Aamodt assertions.

First, belief that temperatures in excess of 5000 degrees occurred during the accident has only recently been posited.

That proposition has been the subject of press statements in February, 1985 and discussed openly, for example, with the TMI-2 Advisory Panel in a public meeting on April 11, 1985.

Although after the accident it was recognized that temperatures in the' core had been very high, the quantifications were stat-ed, for example, as "may have exceeded 4000 F." See Technical Staff Analysis Report on Core Damage to President's Commission on the Accident at Three Mile Island, Summary and Findings at

1. It was further widely recognized that knowledge about what actually occurred in the core would necessarily progress with further analyses and actual inspection of the reactor fuel itself. See id. at 2. That is simply all that has occurred now -- with additional work and inspection of the core, knowl-edge has increased.

Second, the Aamodts' Amendment exhibits considerable con-fusion concerning transuranics. That transuranics existed out-side the fuel following the accident is not new news. The a*

identification and quantification of transuranics was described openly. See, for example, Licensee's letter (R. C. Arnold) to NRC (R. Vollmer) of September 13, 1979 (providing the results of an August, 1979 reactor building sump water sample). The .

fact that transuranics were identified outside the fuel after the accident does not, however, necessarily translate into knowledge of the severity of the accident. On information and belief, transuranics may be released into the coolant when the fuel cladding is breached whether from cracking or other fail-ure of the clad; trace quantities can be found in operating re-actors. The damage which the TMI-2 core sustained was not quantifiable merely by virtue of the identity of transuranics outside the f:el.

Finally, contrary to the Aamodts' assertion that 6000-22,000 lbs. of core material is missing, this material is not missing but is contained principally in the Reactor Coolant System (RCS) and supporting systems as shown in the Aamodts' own Exhibit 5. Estimates of the distribution of core material have been recently revised as discussed publicly with the TMI-2 Advisory Panel on April 11, 1985, providing a better estimate of where and how much of this core material is located within the RCS and supporting systems. Thus, the Aamodts' further im-plication that transuranics contained in the " missing" tons of core material were discharged directly to the environment is incorrect. The Aamodt argument that this is shown by having observed transuranics on filters in 1980 is still further l

1 l

s' s

flawed.- These filters in question are part of the Makeup Sys-tem of the RCS and not ventilation filters to the atmosphere or discharge filters to the river.

In short, the Aamodts' misdirected allegations of cover-up lack foundation.

Respectfully submitted, iWo h Ernest L. Blake, Jr., P.C.

Counsel for Licensee April 30, 1985 e-

~

UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION 00LKETED BEFORE THE COMMISSIGSNRC In the Matter of 185 MAY -2 N1 :21

)' Docket No. 50-289 SP METROPOLITAN EDISON COMPANY bFFICE OF SECRETARY (Restart) 00ChETING & SERVICE (Three Mile Island Nuclear ) BRANCH Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Comments on Amendment to Aamodt Motion of January 15, 1985", dated April 30, 1985, were served on those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 30th day of April, 1985.

Respectfully submitted, l?hbck Ernest L. Blake, Jr. P.C.

DATED: April 30, 1985

(,

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP

) Restart

- (Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H. Buck Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory CommissioE U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 James K. Asselstine, Commissioner Administrative Judge Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C. 20555 Board Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commissior Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge Ivan W. Smith, Chairman Lando W. Zeck, Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Washington, D.C. 20555 l

l L

p 3.)

Administrative Judge Mr. Henry D. Hukill Gustave A. Linenberger, Jr. Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C. 20555 Middletown, PA 17057 ,

' Docketing and Service Section (3) Mr. and Mrs. Norman Aamodt

. Office of the Secretary R.D. 5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C. 20555 Ms. Louise Bradford Atomic Safety & Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C. 20555 Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C. 20002 Washington, D.C. 20555 Lynne Bernabei, Esq.

Jack R. Goldberg, Esq. (4)

• ^

Office of the Executive Legal Pr c

.555 Connecticut Avenue U.S Nuc ear- Regulatory Commission Washington, D.C. 20009 Washington, D. C. 20555 Ellyn R. Weiss, Esq.

Harmon, Weiss & Jordan Thomas Y. Au, Esq. 2001 S Street, N.W., Suite 430 Office of Chief Counsel Washington, D.C. 20009 Department of Environmental Resources Michael F. McBride, Esq.

505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W.

Harrisburg, PA 17120 Suite 1100 Washington, D.C. 20036 Michael W. Maupin, Esq.

Hunton & Williams 707 East Main Street P.O. Box 1535

, .. Richmond, VA 23212 I