ML20078B801

Contentions of J Lee,N Aamodt & B Molholt Re Steam Generator Degradation & Repair.Svc List Encl

ML20078B801
Person / Time
Site:	Three Mile Island
Issue date:	09/21/1983
From:	Aamodt N, Jun Lee, Molholt B AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8309270254
Download: ML20078B801 (5)

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UNITED STATE G' AMEICA 00CKETED NUCLEAR BEGULATORY COMMISSION U RC BETWE THE ATOMIC SAFEIT AND LICENSING BOAR %3 9 26 R2'32 In the Matter of 0FFICE OF SECRETA.

METROPOLITAN EDISON COMPANY, et al. eket d. T h N

( hree Mile Island Nuclear Generating Station, Unit 1)

LEE et al. CNTENTIWS CWCERNING STEAM GDERATW DEURADATION AND REPAIB Introduction. i i

In response to Boarti Memorandum and Ortier of August 08,1983, Intervenors  !

Jane Lee, Norman Aamodt and Bruce Molholt, consolidated as Lee et al., submit the following contentions concerning the repair of the OSCT at Unit 1. f Contentions. .

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Contention 1.

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here is no assurance that steam generator tube repairs have not

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i contributed to a condition which will cause early failure upon restart. i

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TMI.J ahall not be pernitted to restart before such assurance is provided . !_

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Contention 2. .-.

I here is no assurance that the steam generator tube repairs will i e.

maintain their integrity under the environmental conditions attendant to u.

operation. 5 TMI-1 shall not be permitted to restart before such assurance j".

is provided, g n'

sd Discussion 1 & 2

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he SIiB states that the steam generator tubes are in a highly sensitized -

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metalurgical state (APP 4, Pg. 2/26) dynamic stresses (e.g. stresses caused j,?.i, n

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l by operation) greatly enhance the initiation of SCC (Att. 4, Pg. 4): it has not been established that the addition of ionic lithium can be relied upon to inhibit the growth of cracks in Inconel 600 (att.4,Pg.6)and polysulfites, very labile compounds, can be present in the RCS. (Att. 4, Pg.20/25). Nowhere in the SE has it been shown that the steaa generator tubes have not suffered significant morphological changes outside the areas observed IGSCC. Nowhere in the SE is the effect of dynamic stress on tubes in the repair area analyzed. Nowhere in the SE is the effect of chemical stress cracking agents other than sulfur predicted. Nowhere in the SE is the past operational history of the steam generator tubes analyzed as a function of expected resistance to ICSCC. Consequently, it can be stated unequivocally that the SE is void of valid predictive analysis of the expected operational life of the OTSG tubes.

] Contention 3.

There is no assurance that elements or compourmis other than or in addition to culfur did not contribute significantly to IGSCC. TEI-1 shall not be peraitted to restart before such assurance is provided.

_ Discussion: .

Nowhere in the SE is there evidence of any significant ,

effort to investigate alternative, complementary or synergistic chemical corrosion agents.

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l Ccntention 4 ,

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Sere is no assurance that beyond-design compressive fatigue stress '

t did not predispose the OTSG tubes to IGSCC. TMI-1 shall not be permitted to restart before such assurance is provided.

Iiscussion l Nowhere in the SE1 is tha: e evidence of any significant analysis of '

operational stresses in the OTSG tubes. 1 Contention 5.

i hen if we were to assume that the repairs at present were adequate, I there is no assurance that licensee possesses the requisite :ompetence and

- integrity to protset, maintain and monitor the integrity of OISG of Unit 1.

L Discussion:

I Several questions arise out of the recent NRC assertions that leak rates were falsified at Unit-is l

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- Was this done to " hide" OTSG tube leakage? $

Vere tube cracks present prior to Nov.1931 testing?

- Vere tube cracks present prior to Unit-1 shutdown? I i

Was leak rate falsification at TMI Unit-1 as extensive as alleged at Unit- 2 h

,n Contention 6:

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here is no assurance that the repairs of the OTSG will maintain their integrity under transient conditions .

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f4 Discussion: #

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he SER is void of adequate analysis of tube inte6rity during transients.

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. -h-Concerning the standing of Dr. Bruce Molholt for leave to intervene:

Dr. Molholt does not request status as a party on his own cognizance but as a member of the intervenor group Lee et al. Although the individual standing of Dr. Molholt is arguable,las allowed by the Licensing Board, and may have been signaled by the original and amended petitions Dr. I Molholt's standing results as a member of the group Leo et al. which qualifies under NRC rules because of the residencien of Jane Lee and Norman Aamodt, the other two members, within ihe Daergency Planning Zone.

r RECPEC ULLYSUEf2 TIED, l47/ / LC e Lee

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Norman Aamodt Bruce Molholt, Ph. D.

A</d- 0t pg'/,

j Dr. Molholt is not new to the TMI hearing, having participated as a witness for EX:NP in the w.in hearing and the Aamodts in the Reopened Proceeding .

Dr. Molholt conducted the cross-examination of Dr. George Tokahata (Pa. Dept.

of Health) concerning health effects in the TMI area which cross-examination was described by the Licensing Board as follows: "Of particular note is the expertise with which Dr. Molholt cross-examined the Commonwealth's witness, Dr. George Tokahata." PID 14 Vol. 2 - Para. 1722 - Pg61D.

Dr. Moholt prepared expert testimony for the TMI-2 hearing concerning the Krypton venting. Following the discovery of the de6raded steam generator tubes at TMI Unit-1, Ir. l'olholt evidenced immediate interest in this problem in a letter to Harold Denton.

Dr. Molholt, as a member of the Eiladelphia Academic Community, Sa knowledg-able and conversant in engineering topics.

SERVICE LIST Sheldon J. Wolfe Chairman Service & Docketing Branch Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission i

Washington, DC 20555 Washington, DC 20555 Chairman Nunzio Palladino Dr. David L. Hetrick U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Commissioner Victor Gilinsky U.S. Regulatory Commission Dr. James C. Iamb, III Washington, DC 20555 Atomic Safety & Licensing Board Panel i U.S. Nuclear liegulatory Commission i Commissioner 'Ihomas Roberts Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Jane Lee -

183 Valley Ed.

Commissioner James Asselstine Etters, PA 17319 k U.S. Nuclear Regulatory Commission Washin6 ton, DC 20555 Dr. Bruce Molholt Bryn Mar College .

Atomic Safety & Licensing Appeal Board Biology lept. Science Center  :

U.S. Nuclear Regulatory Commisaion Bryn Mawr . PA 19010 Washington DC 20555  ;

Norman Aamodt h.D. 5, Box 478 Jack Coldberg, Esq. Coatesville, PA 19320 ' y Legal Offices i U.S. Nuclear Regulatory Commission Washington, DC 20555 Douglas it. Blazey, Esq. r 505 Executive House E G.F. Troubridge, Esq. P.O. Box 2357 Harrisburg, PA 17120 Shaw, Pittman Potts & Trowbridge s 1800 M. Street, N.V. E

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W:shington, DC 20036 g; )

TMIA Ei \

315 Peffer St. ['

Harrisburg, PA 17102 -

Union of Concerned Scientists it c/oHarmon& Weiss T5 1725 I Street, N.V.

El W:shington, D.C. 20006 John Minnich, Chairman Board of Dauphin Co. Commissioners Dauphin Co. Courthouse Front & Market Sts.

Harrisburg, PA 17101 5

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