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{{#Wiki_filter:.
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    '
D' q RELATED CORRESPONDENCE
                                                                      ,/     D' q RELATED CORRESPONDENCE         'G             '
'G f69 9
f69       %
sF'+g>#'o y
9       -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION d
sF'+g>#'o y   "
g(h BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
UNITED STATES OF AMERICA               '-
+
NUCLEAR REGULATORY COMMISSION g(h d        --
p In the Matter of
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD                     +   p In the Matter of                 )                                     A
)
                                        )
A
METROPOLITAN EDISON COMPANY       )     Docket No. 50-289
)
                                        )           (Restart)
METROPOLITAN EDISON COMPANY
(Three Mile Island Nuclear       )
)
Station, Unit No. 1               )
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1
)
UNION OF CONCERNED SCIENTISTS SECOND SET OF INTERROGATORIES TO LICENSEE Please use the same instructions as those given in UCS's firs t set of Interrogatories to the licensee.
UNION OF CONCERNED SCIENTISTS SECOND SET OF INTERROGATORIES TO LICENSEE Please use the same instructions as those given in UCS's firs t set of Interrogatories to the licensee.
179. The licensee has stated that it does not yet have final positions on the merits of the UCS contentions.         Please provide the licensee's cresent position on each UCS contention.
179.
180. With reference to your answer to UCS Interrogatory
The licensee has stated that it does not yet have final positions on the merits of the UCS contentions.
      #7, which of the short or long term measures recommended by the s taf f and to be implemented by licensee "will reduce the likelihood of void formation?"     Explain the bases of your response.
Please provide the licensee's cresent position on each UCS contention.
18 1 . Using your definition of " natural circulation" as given in response to UCS Interrogatcry n6, identify which of the short or.long term measures recommended by the staff and to be implemented by licensee will prevent or reduce the likeli-hood of loss of natural circulation.       Explain the bases for your response.
180.
18 2. Is it the licensee's position that the consequences of the TMI-2 accident with respect to a) core damage, b) fuel 80030604 M
With reference to your answer to UCS Interrogatory
#7, which of the short or long term measures recommended by the s taf f and to be implemented by licensee "will reduce the likelihood of void formation?"
Explain the bases of your response.
18 1.
Using your definition of " natural circulation" as given in response to UCS Interrogatcry n6, identify which of the short or.long term measures recommended by the staff and to be implemented by licensee will prevent or reduce the likeli-hood of loss of natural circulation.
Explain the bases for your response.
18 2.
Is it the licensee's position that the consequences of the TMI-2 accident with respect to a) core damage, b) fuel 80030604 M


                        .
. damage and c) safety system performance fell in all cases within the limits permitted by NRC regulations ?
.
18 3.
damage and c) safety system performance fell in all cases within the limits permitted by NRC regulations ?
If your answer to No. 182 is that this is not the licensee's position, identify the particular equipment failures and/or consequentes which exceeded limits. permitted by NRC regu-lations and specify the regulations considered.
18 3. If your answer to No. 182 is that this is not the licensee's position, identify the particular equipment failures and/or consequentes which exceeded limits. permitted by NRC regu-lations and specify the regulations considered.       In addition, explain the manner in which the limits were exceeded.
In addition, explain the manner in which the limits were exceeded.
184. What measures have been or will be implemented prior to restart to prevent recurrence of any equipment failures and/or
184.
                                                                .
What measures have been or will be implemented prior to restart to prevent recurrence of any equipment failures and/or consequences identified in the answer to No. 183.
consequences identified in the answer to No. 183.
18 5.
18 5. In response to UCS Interrogatory e46, the licensee states that failure of power operated relief valves, associated block valves, instruments and controls cannot aggravate the consequences of a LOCA beyond that " submitted in the referenced analysis."     The referenced analysis are primarily pre-TMI. Is it the licensees position that the consequences of the accident at TMI-2 were no t "beyond that submitted in the referenced an alys is ?"
In response to UCS Interrogatory e46, the licensee states that failure of power operated relief valves, associated block valves, instruments and controls cannot aggravate the consequences of a LOCA beyond that " submitted in the referenced analysis."
18 6 . If this is not the licensee 's position , identify which specific failures were the cause of consequences "beyond that submitted in the referenced analysis."
The referenced analysis are primarily pre-TMI.
18 7. Which of the short and/or long term measures will prevent future accidents in which the consequences are "beyond that submitted in the referenced analysis ?"
Is it the licensees position that the consequences of the accident at TMI-2 were no t "beyond that submitted in the referenced an alys is ?"
18 8 . With respect to UCS Interrogatory n69, is it the licensee's position that the provisions of IEEE 279, S4.8, as
18 6.
If this is not the licensee 's position, identify which specific failures were the cause of consequences "beyond that submitted in the referenced analysis."
18 7.
Which of the short and/or long term measures will prevent future accidents in which the consequences are "beyond that submitted in the referenced analysis ?"
18 8.
With respect to UCS Interrogatory n69, is it the licensee's position that the provisions of IEEE 279, S4.8, as


  .
. incorporated in 10 CPR 50.55a(h) do not apply to TMI-l?
.
If this is your position, explain it fully.
incorporated in 10 CPR 50.55a(h) do not apply to TMI-l?       If this is your position, explain it fully.
Respectfully submitted,
Respectfully submitted,
                                        -'~ ,
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                                                        *
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                                          ,\        j By    ( s  e( \       C. ( k ' % -
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Ellyn R. Weiss SHELDON, HARMON & WEISS 1725 I S tr ee t , N.W.
C. ( k ' % -
Suite 506 Washington, D.C. 20006 (202 ) 833-9070 General Counsel for the Union of Concerned Scientis ts DATED: February 25, 1980}}
,\\
j By s
Ellyn R.
Weiss SHELDON, HARMON & WEISS 1725 I S tr ee t,
N.W.
Suite 506 Washington, D.C.
20006 (202 ) 833-9070 General Counsel for the Union of Concerned Scientis ts DATED:
February 25, 1980}}

Latest revision as of 08:15, 2 January 2025

Second Set of Interrogatories Directed to Licensee.Inquires Whether Recommended Short & long-term Measures Will Reduce Possible Void Formation.Includes Questions Re Natural Circulation & Failure of Relief Valves
ML19294B981
Person / Time
Site: Crane Constellation icon.png
Issue date: 02/25/1980
From: Weiss E
SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:
METROPOLITAN EDISON CO.
Shared Package
ML19294B980 List:
References
NUDOCS 8003060494
Download: ML19294B981 (3)
v • d • e


Text

.

,/

D' q RELATED CORRESPONDENCE

'G f69 9

sF'+g>#'o y

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION d

g(h BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

+

p In the Matter of

)

A

)

METROPOLITAN EDISON COMPANY

)

Docket No. 50-289

)

(Restart)

(Three Mile Island Nuclear

)

Station, Unit No. 1

)

UNION OF CONCERNED SCIENTISTS SECOND SET OF INTERROGATORIES TO LICENSEE Please use the same instructions as those given in UCS's firs t set of Interrogatories to the licensee.

179.

The licensee has stated that it does not yet have final positions on the merits of the UCS contentions.

Please provide the licensee's cresent position on each UCS contention.

180.

With reference to your answer to UCS Interrogatory

  1. 7, which of the short or long term measures recommended by the s taf f and to be implemented by licensee "will reduce the likelihood of void formation?"

Explain the bases of your response.

18 1.

Using your definition of " natural circulation" as given in response to UCS Interrogatcry n6, identify which of the short or.long term measures recommended by the staff and to be implemented by licensee will prevent or reduce the likeli-hood of loss of natural circulation.

Explain the bases for your response.

18 2.

Is it the licensee's position that the consequences of the TMI-2 accident with respect to a) core damage, b) fuel 80030604 M

. damage and c) safety system performance fell in all cases within the limits permitted by NRC regulations ?

18 3.

If your answer to No. 182 is that this is not the licensee's position, identify the particular equipment failures and/or consequentes which exceeded limits. permitted by NRC regu-lations and specify the regulations considered.

In addition, explain the manner in which the limits were exceeded.

184.

What measures have been or will be implemented prior to restart to prevent recurrence of any equipment failures and/or consequences identified in the answer to No. 183.

18 5.

In response to UCS Interrogatory e46, the licensee states that failure of power operated relief valves, associated block valves, instruments and controls cannot aggravate the consequences of a LOCA beyond that " submitted in the referenced analysis."

The referenced analysis are primarily pre-TMI.

Is it the licensees position that the consequences of the accident at TMI-2 were no t "beyond that submitted in the referenced an alys is ?"

18 6.

If this is not the licensee 's position, identify which specific failures were the cause of consequences "beyond that submitted in the referenced analysis."

18 7.

Which of the short and/or long term measures will prevent future accidents in which the consequences are "beyond that submitted in the referenced analysis ?"

18 8.

With respect to UCS Interrogatory n69, is it the licensee's position that the provisions of IEEE 279, S4.8, as

. incorporated in 10 CPR 50.55a(h) do not apply to TMI-l?

If this is your position, explain it fully.

Respectfully submitted,

-'~

m,

(

e( \\

C. ( k ' % -

,\\

j By s

Ellyn R.

Weiss SHELDON, HARMON & WEISS 1725 I S tr ee t,

N.W.

Suite 506 Washington, D.C.

20006 (202 ) 833-9070 General Counsel for the Union of Concerned Scientis ts DATED:

February 25, 1980

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