ML19305B890
| ML19305B890 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1980 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Lewis M AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8003200553 | |
| Download: ML19305B890 (27) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSl;'s BOARD In.the Matter of
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Docket No. 50-289 METROPOLITAN EDIS0N COMPANY, ET AL.
y (Three Mile Island, Unit 1)
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NRC STAFF RESPONSE TO MARVIN I. LEWIS' SECOND, THIRD, AND FOURTH SET OF INTERR0GATORIES TO THE NRC STAFF i
Pursuantto'10C.F.R.12.720and10C.F.R.52.744,theNRCStaffhasresponded to Marvin I. Lewis' second, third, and fourth set of interrogatories to the URC Staff.
Each. interrogatory is restated and a response provided. Where appropriate, the NRC Staff has invoked that portion of the Commission's Order of August 9,1979 (Slip 0. at 11) which allows as an adequate response to a 2
discovery request a statement that information is available in the Local 4
j Public Document Rooms and guidance as to where the information can be found.
f Following _the responses to the interrogatories are affidavits identifying the individuals. who prepared the responses and verifying them.
.not included in this pleading will be sent at a later date.
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4 8003200553
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NRC 11 (page 1)
Do you know the location of any FSAR or PSAR for the TMI#1 and
- 2 reactors in the Philadelphia area?
I have had to use these documents in the Harrisburg Middletown area and its very time consuming.
_Pgspgnse The f;RC Region I office in King of Prussia, Pennsylvania, maintains a OMy of the FSAR for TMI-l and Tl11-2.
They also have a copy of the PSAR for TMI-2.
The address is 631 Park Avenue, King of Prussia, Pennsylvania.
You should speak with Mr. Keimig.
NRC12(page1)
On page C4-6 there'is a Paragraph which starts, " Subsequent to the accident...." This entire paragraph seems to be coached in mystery.
I don't understand it. Here are a few of my confusions.
" Subsequent to the accident at TMI-2, the gaseous waste processing system has experienced leakage,"
Does this mean that the system did not experience leakage prior to the accident, during the accident; but only " subsequent to the accident?"
2 How much is leaking? Where is it leaking? What is leaking? Why hasn't it been repaired or stopped?
(It refers to the leak.)
Is this an indication of a minor breach of containment?
If not, why not?
Is this a violation of the TMI-2 operating license?
If not, why not?
"The TMI-l system was pressure tested in June 1979 and no leakage was noted during the test."
Uhat's analogous mean? Specify dictionary or give definition.
Does analogous mean it has analogous cracks?
If not, why not? Was the part or parts which were pressure tested analogous to or similar to those parts in TMI-2 whi,ch were cracked in the vent header?
Helium leak test.
I have performed helium leak tests.
I have found that-the results of helium leak tests are much more sensitive to the pref -
erence of the theoperator than to the helium which may or may nr+, leak out.
Since the operator will be the suspended licensee, what accks do you have to control operator preference in this leak testing ~ Who l
controls the checks? NRC, Suspendee?
How extensive was the pressure testing and how extensive will the helium leak testing be? Will all possible leaks in the gaseous waste system be evaluated? Will all parts in the gaseous waste system be tested both ways? "The vent header system is protected from over-pressure by 2 relief valves on the vent header and by water filled loop seals on the overflow of the misc waste storage tank."
If the "TMI-l gaseous waste system is analogous to that of TMI-1-2".
weren't these safeties in place at TMI-2 on 3/28/80?
If so, why didn't they work?
If these safeties did not work on TMI-2, why do you think that these safeties will work on TMI-1 now? How did you pressure test the system with the " individual relief valves" set as in the table on Page C4-67 If these safeties did work l
properly on 3/28/79, how did the millions of curies of Xe get out?
Since all of the questions above center upon one paragrpah, I have taken the liberty to put them in one interrogatory.
If the Staff wishes to subdivide this interrogatory for ease of answering, please do.
This interrogatory is complicated because my understanding of the paragraph in the SER is so confused.
3R5REnse As is pointed out in the Rogovin report,Section II.B2(e), leaks in the waste gas system existed during the accident representing a radioactivity release path. As is pointed out in the Status Report dated January 11,1980, leaks in the waste gas system continued subsequent to the accident.
Subsequent to the March 28 accident at TMI-2, an effort was begun by V'tropolitan l
Edison personnel to identify sources of leakage from the waste gas system and vent header system which contributed to releases during the accident.
This program continued into the summer of 19/9, and, toward the end of 1979, repairs were nade that were designed to reduce leakage.
Therefore, currently, there is no measurable leakage from the waste gas system. A leak in the waste gas I
system would not be a minor breach in containment since there is no direct connec-
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tion between the containment atmosphere and the waste gas system.
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The waste gas systems for THI-1 and TMI-2 are essentially the same.
Use of the word analogous meant that the design of the system was basically the same.
It does not mean that the systems necessarily have the same leaks.
As is pointed out in the Status Report dated January 11, 1980, Order Item 8, S.ction 2.1.6a, the licensee will be required to leak test the waste gas system in response to lessons 1. earned Item 2.1.6a of flVREG-0578.
This requirement involves leak testing of the entire waste gas system to reduce leaks such as those which occurred at TMI-2 during the March 28 accident.
As indicated above, as part of the requirements to restart TMI-1 the licensee 1
is required by the f4RC to leak test the waste gas system according to the requirements of item 2.1.6a of iiUREG-0578.
The leak rate testing required by Item 2.1.6a of liUREG-0578 indicated in the response above will demonstrate the leak integrity of the entire waste gas system.
In addition, Section 2.1.6a of f!UREG-0578 requires that the licensee implement all practical leak reduction raaasures for the waste gas system. As part of this, the licensee will perform periodic integrated leak tests.
As indicated in the Rogovin Report,Section II.B2(e), the major releases of gaseous radioactivity from TMI-2 were not from the waste gas system relief valves themselves as inferred in the interrogatory.
Section II.B2(e) of-the Rogovin report indicates that one primary cause of the release resulted from a series of events resulting from water from the reactor coolant drain tank getting into the vent header system causing opening of pathways from the -
waste gas system vent header to other untreated systems and subsequer.t venting of.the makeup and purification system to relieve pressure. This caused release
5-of activity into the auxiliary building and subsequent release to the atnosphere. Another release path indicated in Section II.B.2(e) of the Rogovin report were leaks in the vent header system and waste gas decay system.
The NRC is currently implementing measures to reduce the potential for release by those pathways in any future postulated accidents.
NUREG-0578, Item 2.I.6a, discussed above, requires leak testing of vent header and waste gas system which will reduce potential for leakage from these systems.
In addition, Draft 3 of the NRC Task Action Plans institutes a study to ensure that future operation of the vent header system in an accident situation will not permit opening of the system to untreated systems which vent to the auxiliary building. Also, the NRC Task Action Plans include plans to eliminate the need for use of the makeup and purification system following a postulated accident.
Pressure testing of the system will be done in such a way to isolate applicable portions of the system to provide system test capability.
NRC 12 (page 2)
Again, I am confused.
I hope that the Staff will not only answer questions; but also, try to clarify the situation.
Page C4-7 top', "there are no interconnecting gaseous waste systems or ventilation systems.
Since there are no common points, we conclude that decontamination of restoration operations at TMI-2 will not affect the TMI-l high level waste gas system, reactor building purge, or auxiliary building ventilation system."
I cannot understand the idea of 'no interconnecting' and 'no common points." Consider this scenario:
We have a repeat to the minutest detail of the accident at TMI-2 at TMI-1 some time in the future. Allow one difference. The meteorological circumstances are such that no wind is blowing and there is a downdraft from the cracked vent header to the control room and auxiliary building intacts for ventilation.
The outside air is a common point. Any error at TMI-l or 2 can affect the outside air adversely.
The contaminated air then would be used in the other reactor.
This common point about the outside air is ignored by the Staff, and leads me to believe that there are many other common points ignored by the Staff.
I believe that the filters on the incoming ventilation systems for #1 and 2 must b
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be upgraded for this eventuality.
If the Staff disagrees with any or all of the above scenario, please be specific in your answer.
Show how, why and any technical analysis which demonstrates the basis of your disagreement with the above scenario.
If the Staff disagrees on other than technical points (for instance: It's a basic item of faith that nuclear is safe, or I wanna keep my job), include these other points also.
Please note: The scenario on page 2 NRC 12 does not disagree with the scenario on page C4-2.
I merely point out that the scenario on Page C4-2 is not comprehensive or definitive.
Response
The intake air supply for the TMI-l control building and auxiliary building is separate from the intake air. supply for TMI-2 control building and auxiliary building.
In the event of an accident at one of the units, the air intake to the control building of the neighboring unit could be isolated.
General Design Criterion 19 of 10 CFR Part 50, Appendix A, requires that radiation levels in the control room be controlled in the event of an accident.
In addition, filtration units on the control room intake are engineered safety feature systems and thus must satisfy the criteria of Regulatory Guide 1.52
" Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants". These design provisions ensure that personnel at one unit would not be affected by a postulated accident at the other unit. A copy of Regulatory Guide 1.52 has been sent to you.
NRC 13 (page 3)
Filters will have to operate in accident conditions. Are all j
, filter and venting systems seismically qualified and safety grade which may have to operate in accident conditions? Can I get a copy of Regulatory Guide 1.4 and 1.5? Page C8-31.
If the hydrogen gas is vented during an accident, how much radiation in curies and isotope will be released with the hydrogen?
Is there a way to filter this to minimize exposure?. C8-58.
Rg2ponse Filtration systems designed to operate in accident conditions to remove radioactive materials from effluents from the plant are engineered safety feature systems.
The system design and testing provisions satisfy the criter la of Regulatory Guide 1.52 " Design, Testing and Maintenance Criteria for F st Accident Engineered-Safety-Fcature Atmosphere Cleanup Systen Air t
Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants".
A copy of Regulatory Guides 1.52,1.4 and 1.5 have been sent to you.
1 1
If, as is pointed out in Item 10 on page C8-58 of the Status Report dated January ll, 1980, there is venting of the reactor vessel there will be radioactivity released to the containment building with the hydrogen gas i
if there is core damage.
The exact amount of radioactivity released to the containment building atmosphere will depend on the extent of core damage er.perienced.
This radioactivity will not be released to the environment but to the containment building which is isolated from the environment.
ERC 14 (page 3)
Page C2-7 "9."
...to assure that undesired pumping of radioactive liquids and gases will not occur accidentally."
"Our evaluation of the licensee's response in this area is contained in NUREG-0578 Section 2.14 and 2.16."
I read these sectior.s of NUREG-0578.
They speak of " inadequate in three respects" and ' difficulties arose not only in safety systems, but also in systems outside the scope of previous
" safety grade" requirements.'
Nowhere do I see the Staff suggest that the licensce's response to date is adequate in these areas. My concern is about radioactive gases and liquids.
How will I know when the licensee's response is adequate to the Staff on these issues without searching back and forth between documents to find that the licensee's responsa is not adequate to the Staff? How will I know what the licensee is doing and when and if adequate to the Staff? I refer to the matters relevant to the Lewis Contention.
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Response
The Staff objected to tnis interrogatory in its February 25, 1980 filing entitled "NRC Staff Objections to Discovery Requests."
MRC 15 (page 3)
Page C8-30 and A-26.
Has anything been done to implement a leak reduction and elimination program aside from recommending such a program? All I see so far is recommendations and no action?
Is the Staff satisfied merely by recommending things that never happen?
Response
Same response as NRC 14.
NRC 16 (page 3)
Page C5-2.
Can I.get a copy of Regulatory Guide 1.110. "How to Trade dollars for Human Lives" or " Cost Benefit analysis for Radwaste Systems
- for LWRS."- If.I cannot get a copy, tell me what the date of the revision which you used.
C5-9 What's Ke in Table 5-2? C5-10 What's b mean in Table 5-3 following " leakage to containment building."? C5-11 Does the over 3 order of magnitude jump in the curies of particulates teleased in total particulates (75 vs 78) suggest overuse of filters as mentioned in Kemeny report? C5-14 Table 5-8. Which of these items on TMI-2 were in line with the vent header which allowed the Xe to escape?
Is there adequate monitoring on that item now?
_ Response A copy of Regulatory Guide'1.110 has been sent to you.
Ke in Table 5-2 is a typographical l error.
It should read Xe-138.
The "b" referred to is a footnote which was-inadvertantly left off the table.
This footnote refers 'to the quality of radioactivity released with primary system
-leakage'to the contaiment building.
Footnote "b" is as follows: "One percent fper day of the primary coolant noble gas inventory and 0.001 percent per day of the primary coolant iodine inventory".
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v The increase in particulate releases from 1975 to 1978 is related to the i
fact that 1975 was very early in the plant life. After a plant has been l.
- in operation for a few years, particulate releases may increase due to increased radioactivity levels in the plant.
It should be noted that 1
l even during the year 1978 the particulate releases did not exceed the plant effluent technical specifications. Over the operating life of the plant the i
level'of release will vary depending'on radioactivity levels in the plant, i
plant' activities, improvements in plant procedural techniques, etc. Releases
-will be limited by plant effluent technical specifications to levels corres-
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ponding to 10 C.F.R. Part 50, Appendix E.
l Prior to TMI-1 restart, and periodically thereafter during plant operation, the TMI-1 building exhaust filtration systems will be tested for removal A
efficiency to satisfy f1RC regulatory guides.
This testing will ensure that 7
filtration and adsorption components will function as designed.
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As indicated in the response to Item 12, the Rogovin report,Section II.B.2(e) presents a' discussion of the release paths of radioactivity during the accident at TMI-2. The two main sources of leakage, namely release through untreated j
system relief v'alves and from vent header system leaks, resulted in a release into.the auxiliary building atmosphere. This essentially resulted in a bypass of the waste gas system effluent monitors listed in Table 5-8.
The radioactivity in the auxiliary building was released with the auxiliary building ventilation system flow.
The auxiliary building ventilation system flow was continued to maintain a negative pressure in the building and prevent unfiltered releases.
The auxiliary building exhaust ventilation system exhaust monitor recorded this release although the monitor reading went off-scale.
It is the intent of Item 2.1.8-b of NUREG-0578 to prevent a repeat of the situation of the r~cnitor going off-scale by requiring licensees to provide increased range 1
of the radiation monitors.
The system improvements required by NUREG-0578, item 2.1.6(a) and the NRC Task Action Plans described in the response to NRC 12 (page 1) are intended to result in confining the radioactivity of the waste gas system where it will be monitored by the effluent monitor and isolated from the environment.
NRC 17 (page 4)
KyW AM in Philadelphia just stated that the Rogovin Report was just released.
According to KYW AM, the Rogovin Report states that TMI-2 was within 30 to~60 minutes of a meltdown.
If the emergency measure had not 2
- been enacted in the limited time and if a meltdown had occurred, would the
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filters and vent header been adequate or would even more inadequate and dangerous aberrations of these' systems been evidenced?
In such a situation",
would more gaseous effluents been loosed than were loosed in the actual accident on 3/28/80 /_ sic _B -
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Rgsyonse In the event that partial meldown of the core bcgan, core damage would have been more extensive than actually occurred during the accident at TMI-2.
This would have resulted in more radioactivity released from the core and the' possibility of more activity released from the plant.
The additional large quantities of radioactivity available for release could have resulted in lower filter removal efficiencies due to the larger quantities of radionuclides taking up sites on the filter bed.
N_R.C18(page4)
I have before me a letter dated 1-17-80 from Robert Reid to R.C. Arnold.
It was delivered to me on 1-24-80.
This letter refers to "information of a type specified in 10 CFR 2.790(d) and should therefore be withheld from public disclosure."
I am not particularly involved with Safeguards Contingency Plan in this proceeding except where said plan may or may not impinge upon the design, use, or adequacy of the filters and the vent header. Neither am I particularly invol;3d in this proceeding with items " withheld from public disclosure" except where such items nay or may not impinge upon the design, use, of adequacy of the filters or vent header.
How can I be sure that some inadequacy of the filters or vent header is
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not hidden or lost under the cloak of 10 CFR 2.790(d)? How can I be sure to trust the Staff that my and the public's health and safety will be adequately insured where items are hidden from public scrutiny by 10 CFR 2.790(d)? How can I entrust a Staff with these points which I cannot research when I see people like Ronald J. Clary, NRC, and Marcia.Mulkey, Esq., leaving allowing a residue of Tourtellotte's whose obvious leanings are anti-intervenor, to remain? How can I trust the Staff to research those items protected by 10 CFR 2.790(d) adequately as far as vent headers and filters when tha Kemeny Commission report states that the NRC is more interested in licensing nuclear power plants than the health and safety of the public? These are not rhetorical questions. Under the rules, I require written responses, specific to the question, and signed by the individuals working on the response.
Response
~The Staff objected to this interrogatory in its "NRC Staff Objections to Discovery Requests" dated February 25, 1980.
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NRC19_(page4)
I just reread " Status Report" dated 1-11-80, and I erroneous called it SER in my questions 11 through 14.
Is this Status Report an SER or not?
If it is an SER, isn't the Staff derelict to put out such an obviously inadequate and faulty SER? (See my question on just the vent header).
"f_sfonse Same response as URC 18.
4 iaC 20 I have a letter dated October ??, 1979 from Stello to Arnold, subject: Investigative Report Number 50 320/79-10 which was sent to me recently by the NRC Staff lawyer and received 1-23-80.
It was sent out 1-15-80 by Lucinda low Swartz.
I have a couple of questions on the penalties. Was it a violation to operate TMI #2 with a cracked-vent header?
If not, why not? If so, where is the fine?
Re_sponse TMI-2 was being operated with a small leak in the vent leader on March 28, 1979. This was not a violation of the TMI-2 Technical Specifications and therefore no penalty attached. A leak in the vent leader goes to the auxiliary building and is vented from the stack.
As long as the leakace from-the plant stack is below the applicable limit there is no violation and therefore no penalty attaches. Appendix B of the TMI-2 Technical Specifications states the amount of allowable leakage from the plant stack.
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flRC 21 (page 4)
I request that the anmes of these witnesses and the thrust of their testimony be.sent to me-at.the earliest convenience.
I shall then attempt to present a great deal of my case through cross-examination.
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Would the Staff also sent'me some references or literature used in the Federal system-to familiarize me with cross-examination which would be acceptable to the Board and not a matter of continuous objections.
Would you also supply me with the name of the engineer presently working on filters at TMI-l in Harley Silver's group? Same for vent header.
- Response T
The names of witnesses and the thrust of their testimony will be sent to all 1
- parties when that information becomes available. A book which should be available in any law library and which would familiarize you with cross-examination techniques is entitled Proof, Persuasion and Cross Examination.
-The author is Louis E. Schwartz and it was published by Executive Reports Corporation in 1978, 1
The engineers who are working on the filters and vent headers on TMI-l are
~ John T. Collins and Jay Y. Lee.
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NRC 22 (page 5)
Fuel cladding defects produce routine radiological releases.
'(KoshkonongPWREIS) The filters are sized or designed to take care of routine radiological release. Are the filters at TMI-l designed to take care of routine radiological releases if the fuel rods do not meet design requirements?
. Response i
The filters at TMI-l are designed to reduce releases during normal operating ccnditions, including anticipated operational occurrences, to levels which are "as low as reasonably achievable" in accordance with 10 CFR Part 50, Appendix I.
The anticipated operational occurrences affecting routine releases ir clude periods during which fuel cladding defects occur.
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NRC 23 j
Does the NRC keep a donsier of file on intervenors and active anti-nuclear types? Are the names Susan Barley or Marvin I. Lewis on any files in the NRC researching our backgrounds, criminal records, social contracts, hearsay, or other information which is or can be used by investigative organizations within and without the government? Intervenor Lewis is.especially interested in the type of file recently disclosed as being kept by the Georgia Power Company on anti-nuclear activists.
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Response
The Staff objected.to this question in its pleading entitled "NRC Staff Objections to Intervenor. Lewis' Interrogatories to the NRC Staff" dated
' March 7, 1980.
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NRC 24 Docs any other branch of government keep a file.on anti-nuclear activists which is available to the NRC? Have the names Marvin Lewis or Susan Barley been added to these files at the request of or direction from the NRC or any of its employees, consultants or minions?
Resp 2nse_
. San.e response as NRC 23.
NRC 25 Send the cirriculum vitae or Professional Qualifications of Dr. C. Gallina, who made many statements to the press during the TMI Accident concerning releases.
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Same response as NRC 23.
NPC 26 In the Staff'a answers to all my previous interrogatories, are all the documents to which the Staff refers in the LPDR's?
R,qsponse All of the documents referred to in the Staff responses to your four. sets of interrogatories have either been sent to you or are in the local public
- document rooms.in Harrisburg and York, Pennsylvania.
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NRC 27 4
Did the leaking vent header and the HEPA and charcoal filters neet the requirements of a.
GDC 41 b.
GDC 60 c.
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10 CFR 50 Appendix I ALARA (1 Sept 1978).
If any.of the. above are not applicable, please state why.
If these criteria were not met, state specifically how and why they were not met.
(Curies, dollars perfcurie,. release rate).
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Include all the filters in your analysis; not just the filters
-in the auxiliary building.
Response
Same response as URC 23.
NRC'28--
Why was the vent header leaking? What materials failed? Where did they fail? How did they fail? When d.o they fail?
If not a material problem, be specific-as to what was the problem.
State who discovered leak, when, how, where. Who logged leak and when? Where is the work order to fix vent header leak? Above interrogatory refers to the vent header in THI-2.
NRC 27 refers to TMI-2 also.
Rgs_ponse Sane response as NRC 23.
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.
Intervonor Lewis does not remember Staff objected to that size at the time Chair.:an Smith specified it.
Obviously,.the Staff received permission to use other than 8-1/2 x 11" from the Board.
The Staff would not break or ignore a Board Order unilaterally.
Nonetheless, Intervenor Lewis has seen no guidance concerning new sizes of paper for submittals which are now allowed.
Since Intervenor Lewis has very limited filing space, he requires to know what sizes of paper to expect from Staff in their filings. What sizes of paper will Staff use in their future filings specifically with reference to Status Reports.
R_esponse Same response as NRC 23.
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NRC 30_
Has some means been promoted for the f4RC to obtain anonymous tips from informants as to practices on tha construction and maintenance of the Tf41-1 facility? This concern is especially pertinent to the Lewis Con-tention 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 of Westinghouse Turbine Cracking (Varga, Knight, 80,1.16) and concrete problems at Wolf Creek and Summer were also brought to light through anonymous tips.
Resp _onse Same response as flRC 23.
fiRC 31 The letters fiRC/Tril 80-028 and Eisenhut: All Power Reactor Licensees 80.01.29 raise 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 noved 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 " Iodine Filters in the auxiliary and fuel handling buildings did not perform as designed because the charcoal filtering capacity was apparently partially expended due to improper use before the accident.
Required testing of filter effectiveness for the fuel handling building had been waived by the flRC.
There were no testing requirements to verify auxiliary building filter effectiveness."
1.
What was "the improper use" referred to in the quote above from the Kemeny Commission? Give type of use, dates, who authorized, where written authorizations, such as logs, work or job tickets, proper paperwork stored?. Send copies -if not in an eesily, accessible public reading room of all supporting documents referred to in the answer to this and all interrogatories.
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2.
When, why, and how was " required testing for filter effectiveness for the fuel handling building... waived by the f4RC"? Specify names, dates, send copies of letters and any other pertinent documentation with your
- answer, 3.
Considering that there were "no testing requirements to verify auxiliary building filter effectiveness", was the licensee operating in violation of 10 CFR 50 Appendix A GDC 41 " Systems to control fission products... shall be provided as necessary to reduce... the concentration and quality of fission products released to the environment." GDC 60 All.
GDC 61 the fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capacity to permit appropriate periodic inspection and testing... (3) with appropriate containment, confinement and filtering systems."
4.
Was the NRC knowingly allowing the Licensee to operate in violation to any GDC?
5.
Did the NRC allow the Licensee to operate without checking the effectiveness of the filter media because there was a problem of where to get rid of the Low Level waste generated in the filtering systems? Was this a form of relief granted to the Licensee by the NRC to circumvent a LLW disposal problem? Has any form of LLW been refused at any site from TMI?
If so, have the intervenors received any notification of said refusal and why?
, Response Same response as NRC 23.
i NRC 32_
Refer to NRC/TMI 80-020; NRC/TMI 80-022; and NRC News Release L-80-26 (Region 1).
A.
Is the problem described in NRC/TMI 80-022 similar for units land 2? Have all fan and filter housings been checked at both units for compatibility? When, by whom, documentations?
B.
How will r drop of AB negative pressure requirements affect the operation of ilters and filter housings if at all? (Leak rates, condensation transfer to electrical pumps, from the surface of the filter housing, and any other pertinent changes in operating parameters).
NRC/THI 80-022.
C.
NRC News Release I-80-26 3rd paragrph.
"The releases apparently were caused by radioactive water in a water purification system (ion exchanger) seeping past a valve and into piping normally used to carry radioactive gases to a. building exhaust and to the plant stack." Have the filter systems and vent systems been corrected so that this event cannot be repeated at TMI-l?
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.
Response
-A._ NRC/TMI 80-20 refers to a modification to the TMI-2 hydrogen purge system which was proposed by Metropolitan Edison.
Metropolitan Edison proposed to install a higher capacity fan into the hydrogen purge system to modify the system for use in purging the reactor building.
During the NRC review of the proposed nodification, it was found that the proposed higher capacity fan could ovcrstress the filter housing.
Metropolitan Edison was notified of this problem and has changed the design.
The original fan which was installed in the hydrogen purge system was compatible with the filter housing.
The fans and filter housing were designed and checked for compatibility during the original plant design.
They have been operating satisfactorily and there is no reason to suspect that any design problems exist.
8.
Variations in auxiliary building negative pressure are well within the filter and filter housing design parameters and should not affect the operation I
of the filters or filter housings.
C.
The news release cited in the Interrogatory referred to an event which occurred at the Calvert Cliffs Nuclear Station.
The sequence of events occurring at Calvert Cliffs causing the release was not related at all to the events which occurred during the accident at TMI-2.
The release at Calvert Cliffs was of short duration and low release levels.
The. events causing this release began during a demineralizer flush operation
. when a demineralizer valve was inadvertantly left open which resulted in water
.in the system entering the vent header from the demineralizer vent and release me e
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of activity. This activity release. caused a vent header alarm and subsequent syst'em isolation. 'The-filter and vent header problems experienced at TMI-2 are not related to.the problem at Calvert Cliffs.
' Information on the events like that causing the release at Calvert Cliffs is
-eade available to utilities for their use in planning the procedures for similar systen evolutions so~that plant operators are aware of the occurrences at Calvert Cliffs and can avoid repetitions of the sane event.
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Question NRC 33 Supplemental Views by Members of President's Commission on the Accident at Three Mile Island on Page 12, Commis-sioner Pigford states, "Although other components, systems, or features are classed as "non safety related," they must meet requirements appropriate to their operational function."
A.
What requirements applied to the filters and vent header during the day of
'E accident at TMI#27 Were they met? Will the seme requirements hold for TMI#1 if and when it goes back on line?
1
Response
In our Safety Evaluation Report for TMI-2 (NUREG-0107), September, 1976, we fcund that the radioactive waste system design met the requirements of 10 C.F.R. Part 50, Appendix A, GDC-60 and 61.
In Supplement 1 to the SER we evaluated this system design and found it capable of reducing the release of radioactive materials in gaseous effluents to "as low as reasonably achievable"
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levels in conformance with 10 C.F.R. Part 50.34a; it met the requirements of Appendix I-to 10 C.F.R. Part 50, and was therefore acceptable. The vent header t
is not a containment atmosphere cleanup system, therefore, the criteria of
.GDC-41 is not applicable. The fuel handling building ventilation system, the control room ventilation system and the reactor building purge system were
~ designed, tested and maintained to met GDC-61, GDC-19 and GDC-41, respectively.
Regulatory Guide 1.52 (Revision 1) July 1976, " Design, Testing, and Maintenance Criteria for Engineered-Safety-Feature Atmosphere Cleanup System Air' Filtration and Adsorption Units of. Light-Water-Cooled Nuclear Powar Plants" provided guide-lines used to find these three systems acceptable. Prior to_the accident at
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TMI-2, the design requirements were met.
The same GDC requirements hold for the TMI-1 restart.
In addition, the air filtration and charcoal absorbers have been replaced with units qualified to meet Regulatory Guide 1.52 (Revision 2), March 1978 in order to meet the staff position on ESF altosphere cleanup systems.
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Question NRC 34 Letter Plesset: Aherne 80.02.11 states," The ACRS believes that its input into this process has been largely ignored by the Commission and is concerned the " rush to judgment' on those important matters may result in, at worst, error and at best ineffi-
'cient use-of resources important to safety."
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 docu-mentation.
Response
The Staff has searched the documentation and we find no input from the ACRS specific to the subject of vent headers and filters.
- RC 35 The answer to NRC 2 is not responsive; however, rather than going through 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 correctly and adequately in a repeat of March 28 accident at TMI-17 By specifically, cite problem (leak at pump seal), how discovered (metallurgical examination by Met Lab, Mr. So and So) how
. corrected (work order, NRC approval, LER #, 18E 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.
State and document how this is being done on a continuing basis.
_ Response As was discussed in the Rogovin Report,Section II.B.2(e), 'nd summarized in the response'to Interrogatory 12 (page 1) one of the primary sources of releases of. radioactivity during the accident were leaks in the vent header system and waste gas secay systes.
Specific details concerning such items as system examin-ations, work orders, etc. are not av ti'able at NRC. However, NUREG-0578, Item 2.1.6a, as discussed in the response to Interrogatory '#1, requires that licensees implement programs for systems containing radioactive fluids.o periodically leak test these
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and to implement' measures to reduce leakage in these systems.
These requirements are intended to have the effect of reducing the possibility of releases through system leakages that occurred during the TMI-2 accident.
With respect to filters the NRC actions contained in D; aft 3 of the hRC Task Action Plans include requiring the licensees to use improved charcoal in the filtration systems.
NRC 36 NRC 10 was objected to as " burdensome and improper."
It was not r.1: Sot to i
be.
It is rewritten 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 appropriate Staffer) the Licensee's answers to Lewis Interrogatories, and answer the following:
A.
Are the Licensee's answers to Lewis Interrogatories accurate?
1, No opinion on responsiveness is asked.
B.
If 'any of the above answers are not accurate, would the Licensce jeopardize the health and safety of the public by implementing said inaccuracies?
j Pesponse Same response as NRC 23.
NRC 37 The Staff's answer to NRC 8 is not responsive in that it does not give times nor state that they are unavailable.
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:
Does the Staff agree with the dates and times of releases referred to in the Rogovin and Kemeny Reports?
In order to reduce the burden, the Staff need only answer-
- for the major document and not the Staff reports.
However, Intervenor Lewis reserves the right to refer to above mentioned Staff reports in direct and indirect testimony.
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Response
Same response as f4RC 23.
Respectfully submitted, Lucinda Low Swartz Counsel for !;RC Staff Dated at Bethesda, Maryland this l'ith day of March, 1980.
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of i'
METROPOLITAN EDISCN COMPANY, et al'.
)
Docket No. 50-289
)
(Three Mile Island, Unit 1)
)
AFFIDAVIT OF FRANCIS P. CARDIt.E, I, Francis P. Cardile, being duly sworn, do depose and state:
1.
I am a Nuclear Engineer in the Office of Standards Development of the United States Nuclear Regulatory Ccmmission.
I am generally responsible for standards related to waste management.
Previously, however, I was a 4
Nuclear Engineer in the Office of Nuclear Reactor Regulation.
I was responsible for review and evaluation of rad.vaste treatment systems and
.for the calculation of releases of radioactivity from nuclear power reactors.
i My professional qualifications statement is attached.
i
- 2. - The answers to Lewis interrogatories 12,13,16,17, 22, 28, 32c, 35;.
CEA interrogatories 6-8, 6-10; and ANGRY interrogatory 6 were prepared by me.
I certify that the answers given are true and accurate to the best of I
my knowledge.
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Francis P. Cardile Subscribed and sworn to before me this 1g day of March,1980
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Notary Public
'ly Commission expires':
July 1, 1982 a
UNITED STATES 0F AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AtlD LICENSIrlG BOARD In the Matter of METROPOLITAN EDISON COMPANY, et al.
)
Docket No. 50-289
)
(Three Mile Island, Unit 1)
)
AFFIDAVIT OF JACQUES S. B0EGLI I, Jacques S. Boegli, being duly sworn, do depose and state:
1.
I am a Senior Nuclear Engineer in the Effluent Treatment Systems Branch, Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation, of the United States Nuclear Regulatory Commission.
I am responsible for the 4
. safety review of radioactive waste management systems for assigned nuclear power plants, including the Three Mile Island, Unit 1 Restart Program. My professional
- qualifications staterr,ent is attached.
2.
The responses'to M. I. Lewis's Interrogatories NRC-27, 33 and 34 were prepared by me.
I certify that the information given are true and accurate to the best
'of my knowledge.
awa S acques S. Boegli Subscribed and sworn to before me this * ^ day of
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.o Notar D ublic j' [
My Commission expires.s l'/h f
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