ML20078A354

Suppl to 830808 Petition to Intervene,Listing Contentions. Certificate of Svc Encl

ML20078A354
Person / Time
Site:	Three Mile Island
Issue date:	09/21/1983
From:	Doroshow J THREE MILE ISLAND ALERT
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20078A346	List: ML20078A342 ML20078A349 ML20078A354
References
NUDOCS 8309230178
Download: ML20078A354 (8)

Text

c .

. .c . . \

UNITED STATES OF ANERICA ffh[C NUCLEAR REGULATORY COMMISSION id SB'21 P4:i6 BEFORE THE ATOFEC SAFETY AND LICENSING BOARD In-the Matter of- ) [0CffTftfG sihd.[~

) BRANCH hETROPOLITAN EDISON COFFANY ) Docket No. 50-289

) (Steam Generator Repair)

(Three Mile Island Nuclear )

Station , Unit No.1) ) ,

f ,

TNEA SUPPLEhENT TO PETITION FOR LEAVE TO INTERVENE Pursuant to the Board's Order of August 8, 19 83 , TbEA hereby supplenents its petition for leave to intervene with contentions TNEA seeks to have litigsted in this na tter .

TNEA subndts the following contentions:

1. Neither Licensee nor the NRC staff have denonstrated that the kinetic expansi-on steam generator tube repair technique, conbined with selective tube plugging, provides reasonable assurance that the operation of TNE-1 with the as-repaired steam generator can be . conducted without endangering the health and nafety of the public, for the folloaing . reasons:

a. Post repair and plant perfornance testing and analysis, including the techniques used, enpirical infornation collected, and data evalution, and proposed license conditions are inadequate to provide sufficient

- assurance that tube r,uptures, including but

~

8309230178 830921 PDR ADOCK 05000289 G PDR e

6 h a

not linited to those which could result upon restart, a turbine trip at maxi mu m poa er , thernal shock from inadvertent actuation of energency feedaater at high poaer or folloaing rapid cooldo.'n af ter a LOCA, will be detected in tine and prevented to avoid endangering the health and safety of the public through release of radiation into the environnent yeyond pernissible li ni ts .

b. Because of the enormous nunber of tubes in both steam generators which have undergone this repair process , the-possibility of a sinultaneous rupture in each steam generator,"which would force the operator to acconplish cooldoen and depressurization using at least

~

one faulted steam generator, resulting in release of radiation into the environnent beyond pernissible levels, isn' t an incredible event," (see, Septenber 19., 1982 me nora ndu m f rom Paul Shea non , then Chairnan of the ACRS), and could lead to a sequence of events not enconpassed by energency procedures , and in the course of a LOCA, such a scenario could create essentially uncoolable conditions.

c. The t,ype of plug used, the nu nber of tubes requiring plugging, and choice of tubes to be plugged, including failure by Licensee to plug 66 degraded tubes, support

, a conclusion that plant operation with the as-repaired steam generator can not be conducted without endan-gering the health and safety of the public, considering 4

e P

• h

.- ~

among other things interference which plugged tubes will havc in the plant's ability to respond to tran-sients and accidents.

d. Neither the " Report of Third Party Revied of Three Mile Island, Unit 1, Steam Generator Repair" nor the Staf f 's Saf ety Evaluation Report (NUREG-1019) are credible docunents in their eva%uation of the kinetic

, expansion repair -technique, including leak tightness and load carrying capabilities , and thus can not be ,

used as a Basis for conclusion that the repairs insure safe plant &peration, because of the reports' inherent

~'

inconsistencies , their failure to provide data or calculations to support their ' evaluations , assunptions ,

and conclusions , the fact that nuch of the analysis is based on laboratorf conditions which do not take into account the age oY the plant, and the fact that those t

individuals participating in the Licensee and NRC revisas lack proper qualification to render an expert opinion on this issue, as evidenced for exanple by the fact that their basic assunptions and conclusions rest improperly on linear fracture nechanics theory as opposed to non-linear theory, axial synetric stress analysis which would not be applicable to all cracks, failure to analyze crack resistance on the basis of toughness as opposed to hardness which has no relation to crack resistance, and failure to dif ferentiate in e e o y

, ,-m --- , -, - , , - - - - 4 ,-. ,- - . - . , - -

--.y

c their analysis bebd een the ef fects of thernal stress on snall versus large cracks.

e. Neither the staff nor the Licensee consider any .

alternative repair process, including the safest alter-native in terns of potential tube rupture, i.e.,

renoval of the steam generators.

2. Neither Licensee nor the NRC stapf have denonstrated that the corrosion which danaged the steam generator and other RCS conponents and systens, will not reinitiate during plant operation and rapidly progress, attacking either the steam generator or elssahere in the prinary pressure boundary, thus providing no reasonable assurance that the operation of TNE-1 with the as-repaired steam generator can be conducted without endangering the health and safety of the public, for the folloaing reasons: y

a. T,here is no assurance that the the causative agent

. qr the scurce o~f' initiation or the conditions under which initiation originally occurred, have been properly identified, thus undernining any conclusion that the causative agent has been renoved from the system, and undernining the reliability of any proposed clean-up process , procedures neant to elininate the corrosive environnent , or the reliability of the Licensee and staf f stress analysis as to when corrosion could reoccur. ,

b. Neither the Licensee nor the staf f have denonstrated that the proposed clean-up process , w hich will renove

~ '

e e

m e g

the sulfur by solubilizing a large part of the sulfur by sulfur oxidation, will provide reasonable assurance that the plant can be operated without endangering the health and safety of the public, for the folloaing reasons:

1. The staff's oen consultant on this issue, Paul W u, believes that the rislks associated with cleaning , i .e , that a relatively large inventory of sulfur conpounds will be put into solution, are greater than sinply "living with a large S inven-tory in the system," supporting a conclusion that the only bao p'dssibilities being considered by the Licensee and 3taff pose substantial risk that corrosion will reinitiate.

2. Even if the proposed cleaning process presented

. no risks, there is no assurance that the proposed

- process c$n renove more than 50-80% of the conta nd-nation, thus there can be no assurance that the contandnation which would be lef t a'i ter the .

process is conplete will not cause reinitiation.

3. Neither the Staf f nor the Licensee consider any a1ternative process, including the one alternative which presents no risk of corrosion reinitiation, i.e., renoval of the stea m genera tors .

. c. Neither the " Report of Third Party Revisa of Three Fdle Island, Unit 1, Steam Generator Repair" nor the Staf f's Safety Evaluation Report (NUREG-1019) are

~

- e

e .

credible docurents in their evaluation of the causative agent, clean up, or procedures to prevent conta ninant reintroduction, and thus can not be used as a basis for conclusion that the repairs insure safe plant opera-tion, because of the reports' inherent inconsistencies, their failure to provide data or calculations to support their evaluations, assuy tions, and conclusions, the fact that auch'of the analysis is based on laboratory conditions which do not take into account the age of the plant, and the fact that those individuals participating in the Licensee and NRC revisas lack proper qualification to render an expert opinion on this issue, as evidenced for exanple by the fact that their basic assunptions and conclusions rest inproperly on linea.g fracture nechanics theory as opposed to ngn-linear theory, axial synetric stress

. a,nalysis which sould not be applicable to all cracks, failure to analyze crack resistance on the basis of toughness as opposed to hardness which has no relation to crack resistance, and failure to differentiate in their analysis 'bebs een the effects of thernal stress on snal1 versus large cracks.

Respectfully subnitted ,

/

, D'ttW1 g/Joanne Doroshoa

- - Louise Bradford Septe nber 21, 1983, ThEA

j UNITED STATES OF ANERICA NUCLEAR REGULATORY COhm2SSION BEFORE THE ATObHC SAFETY AND LICENSING BOARD In the batter of )

) -

PETROPOLITAN EDISON COPPANY ) Docket No. 50-289 l

) l (Three Plle Island Nuclear )

Station , Unit No.1) )

r CERTIFICATE OF SENVICE I hereby certify that copies of the attached T>EA.

SUPPLE >ENT TO PETITION FOR LEAVE TO INTERVENE dated Septenber 21, 1983, was served this 21st day of Septenber 21, 1983, by'dep$ sit in the U S . . bsil, first class, postage prepaid, or hand delivered, to those on the attached service

. list.

.: w 17 NNE DOROSH09 9

e 9

O O O 4

e e e e o

l l

l SERVICE LIST '

l mry W agner, l Office of Executive Legal Director l U.S. NRC

• W ashington, D.C. 20515 George F. Troabridge, Esq. Ms. burjorie Aamodt Shaw, Pittnan , Potts & Troabridge R.D. 5 1800'M St. N .W . Coatesville, PA 19320 W ashington, D.C. 20036 Sheldon W olfe, Esq., ASLB Dr. Dayid Hetrick, ASLB U.S. N.R.C. U.S.NRC W ashington , D.C. 20555 W ashington, D.C. 20515 Docketing and Service Dr. Janes La-b

~

U.S. N.R.C. U.S. NRC-W ashington , D.C. 20555 Washington, D.C. 20515

. Jane Lee ..

Douglas Blazey R.D. 3 - -

Assistant Attorney General Etters, PA Executive House Harrisburg, PA 17120 e e I'

i e

e 5

e 4

e o e

i_ - .