ML20072M460

Amended Petition of J Lee,B Molholt & N Aamodt for Leave to Intervene Re Steam Generator Tube Repair.Extensive Damage Detected in Tubes.Method of Repair Novel & Unproven

ML20072M460
Person / Time
Site:	Three Mile Island
Issue date:	07/13/1983
From:	Aamodt N AAMODTS
To:	NRC COMMISSION (OCM)
References
NUDOCS 8307140441
Download: ML20072M460 (5)

Text

IIM - 7/13/63 UNITED STA TIS OF MERICA D NUCLEAR REGUlfTORY C0!mISSICN y[og I[g,l p/ ' ,

EEFORE THE C0f7ISSION Y "D4

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" .,3 s a METROTOLITAN EDISON COMP!.NY, et. al. Packet 50-289' T P (Restart)

(Three Mile Island Nuclear j!- } /

Generating Station, Unit 1) )

ABENDED PETITION OF LEE, FOLROLT, AAE0DT FOR LEAVE TO INTERVENE CONCERNING PSPt.IR OF STEAM GENER2 TOR TU3ES The Commission on May 31, 1983 published in the FEDEPJ.L REGISTER (48 FR 24231) a notice of considerz tion of GFU Nuclear Corporation's Ihy 9,1983 application for en amendment to Facility Operating License No. DPR-50 for the Three Mile Island Nuclear Sta tion, Unit No. 1, located in Dauphin County, Pennsylvania. The requested amendment involves steem generator tube repeir at the facility. The FEDERAL P2GISTER notice presented the Commission 's "no significant. hazards" considera t. 2 and propos'e d a public hearing of the issue.

By letter of June 28, 1983, Jane Lee, Bruce Molholt and Norman'lacodt petitioned the Commission for leave to intervene in any hearing provided by the Commission to consider the steam generator tube repairs. The petitioners' interests were stated as the health and safety of themceives, their families and the public.

According to NRC rules of practice, Title 10, Section 2.714 (3),

a petition may be amended (fifteen days) prior to the setting of a prehearing conference. In anticipation of a Commission decision, expected to take place on July 14, 1983, to allow the affected public the opportunity to exsmine the veracity of the steem j l

generator tube repsirs, the petitioners amend their petition herewith. )

1 8307140441 830713 l PDR C ADOCK 05000289 I PDR

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, The Commission also provided the opportunity for comments concerning the need .for a public hearing. The deadline for this filins , June 30, 1983, was missed by the petitioners due to oversight on the part of Normen fatodt who was involved,since the. Commission's notice,with =atters related to the management phase of the res tart proceeding. No notice was recalved by the other petitionera despite their deconstrated interest in the steam generator tube repair issue (es evidenced by their correspondence with the Commission and the Staff. ) Jane Lee and Bruce Molholt first beccme aware of the opportunity to intervene on June 28, 1983,but thay were not fully informed of their opportunity to comment. The petitioners therefore cotion the Cotmission to consider comments included herein if, as a practical matter, they are timely.

Fetitioners' Interesta and Aspects All three petitioners either reside, conduct business and /or have social contacts within the ten mile radius of TMI - Unit 1.

Jcne Lee resides within five milas of the TMI facility and is at high risk in operation of a dairy farm at that location. She has informed herself concernin6 the repair of the steam generator tubes. Of particular concern to her is the identification of the cause of the past corrosion, the likelihood of reoccurrence, reliability of repairs and the progran for future detection of breaks. Sr. Eruce Molholt is a graduate biochemist whose interest in the steam generator tube repairs was expressed to the NRC Staff shortly af ter the discovery of the problem. Dr. Molholt is concerned about effect of power excursions on the repairs and the unrepaired tubes. Normen Aamodt is a graduate mechanical engineer. His chief concern is that continued use of equipment L_______ __ _

. that hasisuffered degradation te the extent of that detected in the steem generator tubes is inconsistent with accepted engineering practices.

The petitioners, es a group, are, by reasons of education end experience, able to participate in a constructive manner toward en appropriate resolution of the steam 6enerctor tube repair issue. They are prepared to present two expert, independent witnesses in addition to development of the record through cross-examina tion.

_ Comments The following are given:

1. The seriousness of the issue of the integrity of the steem generator tubes is undisputed.

2. The damage detected in the Unit 1 steam generator tubes was extensive.

3. The method of repair of the steam generator tubes is novel and unproven.

The petitioners' opinions are as follows: The repair issue

. as resolved by the NRC Staff depends on the soundness of the Staff's judgement and the integrity of the Staff's word. The recent Staff behavior concerning the withholding of information I

concerning the Hartman matter,. the subsequent inadequate related explanations, the advocacy of GIU's indefensible positions to restructure the TMI - 1 organization, taken individually and

( .to5 ether, provide sufficient reason for all petitioners to lack l

confidence in Commission determinations which are based on Staff i

-findings. The petitioners are due, therefore, the opportunity l

l to question the Staff,under oath, concerning their findings.

• parallel distrust of Idcensee's representations concerning 1

, the same problem is justifiably present among the petitioners.

The employn.ent of Dr. Robert long as a corporate mansger in the matter of the repeirc areatly increases the petitioners' distrust of Ilcensee 's assurances. Dr. Iong was found by the Licencing Board to have disregarded his responsibility es corporate director of training end further, to have been untware j of his feilure. The very fact that Ideensee placed Dr. Long in the repair operation causes the petitioners to que.s. tion .the attitude of Licensee in underteking the repairs.

Conclusion The only accomodation sought by the petitioners it that the Commission provide the opportunity fc r a hearing concerning the steam generator tube repairs in Pennsylvania at a location within a few miles of the TMI facility.

Respectfully submitted,

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_ h !/Wkt Norman O. Aamodt A tta ched : Petition, June 28, 1983 Served en the attached Servict list marked (*) by depocit with the Docketing & Scrvice Branch, U. S. Nuclear Regula tory Commission on July 13,13C3 and to cll other parties by deposit in U. S. Fail first cle ss.

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July 13, 1983 Norman C. Aamodt

• UNITED STATE.3 0F AIGRICA NUCIEAR REGUIATORY COPEISSIO:;

3EFORZ THE C0tCIISSION In the Matter of )

IGTROIOLITAN EDISON CCMPANY ) Repair of Stes:

_ET _A L. Generator Tubes

)

(Three Mile Island Nuclear Generating Station, Unit 1) ) -

Service List -

• SerEice & Locketing 3 ranch TMIA U. S. Nuclear Regulatory Cortissicn 315 Peffer St.. ..

Washington, D. C. 20555 Earrisbu g, 3A 17102 Chair an Nunzio Palladino Union of Concerned Scientists U. S. Nuclear Regulatory Co :ission c/o Earcon & Weiss Washington, D. C. 20555 1725 I Street, H. W.

We snington , D. C. 20006

, Cor=issioner John Ahearne U. S. Nuclear Regulatory Cornission Icuglass R. 31acey, Esc .

Wa shington, D. C. 20555 505 Ixecutive House

?. O. Iox 2557

• Co::issioner Victor Gilinsky Earrisburg, PA 17120 U. S. Nuclear Regulatory Co: ission Wa shington, D. C. 20555 Judge Gary 1. Filhollin 4412 Greenwich 3arkway, 5. n.

Cornissioner Thomas Roberts Weshington, D. C. 20007 U. S. Nuclear Regula tory Co::ission Weshington, D. C. 20555 Jane Ice 183 Valley Road Co=rissioner Ja es Asselstine Etters, PA 17319 U. S. Nuclear Regulatory Cornission Washington, D. C. 20555 Farrin I. Iewis 6504 3radford' Terrace

• Ato:ic Safety & Licensing Appeal Icard Ihiladelphia PA 19149 U. S. Nuclear Regulatory Co :ission

.,sh.4ngton, r.a ,. C. c s ,o ppa- cares nurs.

Att: Chair:an Administrative Judre '

PANZ Gary J. Zdles 617 3riarcliff Road Middletown, PA 17057

• ito ic Safety & licensing 3 card 2anel U. S. Nuclear RegulatoryfCor=ission John I. Minnich Wa shington, D. C. 20555 , Chairman, Dauphin County Att: Chair:an Administra tive Judge 3 card of Cornissioners i Ivan W. .5:ith Dauphin County Courthouse i

Front & Earket Streets l Jack' Goldberg, Esq. Harrisburg, PA 17101 legal Offices U. S. Nuclear Regulatory Co :ission Dr. Bruce Molholt Wa shington, 3. C. 20555 Eaverford college Haverford, PA 19041 G. F. Erowbridge, Esq.

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