ML19179A128

NRR E-mail Capture - (External_Sender) PRB Presentation, (6/26/19)

ML19179A128
Person / Time
Site:	Three Mile Island
Issue date:	06/27/2019
From:	Epstein E EFMR Monitoring Group
To:	Justin Poole Plant Licensing Branch 1
References
Download: ML19179A128 (5)

Text

NRR-DRMAPEm Resource From: Eric Epstein <epstein@efmr.org>

Sent: Thursday, June 27, 2019 8:09 AM To: Poole, Justin; Scott Portzline; Eric Epstein

Subject:

[External_Sender] PRB Presentation, (6/26/19)

Attachments: PRB Presentation, (62619).pdf Justin:

Please include the enclosed comments in the official record from yesterday's conference.

Thank you, Eric Epstein 1

Hearing Identifier: NRR_DRMA Email Number: 71 Mail Envelope Properties (353EDD3F-3C45-49B7-BC00-B73C88DDF7A0)

Subject:

[External_Sender] PRB Presentation, (6/26/19)

Sent Date: 6/27/2019 8:08:32 AM Received Date: 6/27/2019 8:08:47 AM From: Eric Epstein Created By: epstein@efmr.org Recipients:

"Poole, Justin" <Justin.Poole@nrc.gov>

Tracking Status: None "Scott Portzline" <sdportzline1@verizon.net>

Tracking Status: None "Eric Epstein" <epstein@efmr.org>

Tracking Status: None Post Office: efmr.org Files Size Date & Time MESSAGE 139 6/27/2019 8:08:47 AM PRB Presentation, (62619).pdf 42855 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Presentation frm Petitoners:

Regarding the PRBs Initial Assessment June 26, 2019

1) In a correspondence dated May 22, 2019, the Petitioners were notified that Justin Poole would manage a Petition Board to review the the 2.206 Petition relating to steam generator safety challenges at Three Mile Island Unit-1.

1) Who is on the Board, do any of the members have prior stream generator experience, and are the minutes from the two meetings convened by the Board available to the Petitioners?

2) If the NRC has in fact thoroughly investigated the design of the steam generator and tubes, please refer the Petitioners to the documents containing Lessons Learned and implemented by licensees and vendors, Notices sent to other plants using similar configurations and tubes, and NRC review schedules.

3) If this is the Boards initial step - and not the final order - what avenues are available to the Petitioners to have the merits of their Petition examined?

4) The Petitioners disagree with the brief and cursory discussion and dismissal by the Board. Please provide verifiable testing data the NRC used to substantiate their dismissal of the Petition.

5) Was Exelon consulted during the review? If so, in what capacity?

Please provide all existing communications and documents between the Board and Exelon.

6) The NRC states that they have been involved with this issue since 2011.

Involvement is not analogous to an in-depth examination. The NRC has not provided supporting documentation to confirm the Boards position.

The term detailed knowledge was also used without providing any evidence of what detailed knowledge exists, or how that knowledge cures the problems brought by the Petitioners.

a) Please provide verifiable data, documentation, and research conducted by the NRC to substantiate the NRCs dismissal of the Petition.

b) Please provide licensee and manufacturer's data that disapprove the following safety challenges:

i) The Petitioners argued that the steam generators can self-destruct from excessive vibrations and fluttering under reactor transient conditions. The fluttering can be so severe that the steam tubes within the steam generators could bang into each other and rupture. This triggering mechanism is termed thermally induced steam generator tube failure.

Please provide the data, documentation or information the Board used to disprove this scenario.

ii)The Petitioners detail how Exelons aggressive design decreases safety margins. The Petitioners contend that this aggressive design also caused the licensee to be out of compliance with its operating license regarding changes to safety systems.

Can the NRC verify that Exelons aggressive design did not decrease safety margins?

Please provide the data, documentation or information the Board used to disprove this scenario.

iii) The Petitioners assert that some of the steam tubes at TMI have exhibited excessive wear from this behavior under normal temperatures during the first fuel cycle of 22 months. The internal damage could destroy the radiation barrier function of the steam tubes, releasing radiation directly to the environment in what is called a "containment bypass accident."

Please provide the data, documentation or information the Board used to disprove this scenario.

The Boards response is a reminder of earlier insufficient investigations of steam generator problems at TMI-1 that forced the replacement of the original steam generators. From November 1981 to

January 1982. GPU discovered it damaged over 29,000 steam generator tubes at TMI-1. At that time, the NRC instituted a protocol of eddy current testing, and removing tubes from service and sleeving. Eventually a replacement of the steam generators was required.

• The current Boards initial determination lacks data and information to dismiss the Petitioners safety challenges.

The Petitioners respectfully request that the Committee respond to questions and requests contained in this correspondence.

What Happened to the Original Steam Generators?

• November 1981 to January 1982 - GPU discovers it has damaged over 29,000 steam generator tubes at TMI-1.

• December 7, 1983 - The Commissions Office of General Counsel reports that the steam generator tube repairs are a significant hazard consideration and a vote to the contrary would violate the Atomic Energy Act.

• July 16, 1984 - TMIA is the only group to intervene in the steam tube case. The Board refuses to allow evidence relating to the recently discovered steam generator tube problem.

• January 11, 1999 - TMI-1 is operating with thousands of damaged steam tubes. ...OTSG A has plugged 1,300 tubes and OTSG [Once Through Steam Generator] has 395 plugged tubes, totaling 1,695 plugged tubes at TMI-1. Each OTSG has 15,531 tubes. The NRC approved limit is a maximum of 2,000 total tubes plugged. GPUN has analyzed and submitted for NRC review a request to revise the tube plugging limit to 20% per OTSG, or 3,106 tubes per OTSG

• January 26, 2012 - After just one operating cycle, NRC inspectors at Three Mile Island have detected unexpected flaws in the facilitys new steam generators. The two 70-foot tall, 510-ton replacement steam generators sit on either side of the nuclear reactor, and were installed at TMI in 2009. Each cost more than $140 million.