ML20078F907

Response to Proposed Contentions Re Steam Generator Repair. Joint Petitioners Fail to Identify Concerns Which Warrant Consideration.Certificate of Svc Encl

ML20078F907
Person / Time
Site:	Three Mile Island
Issue date:	10/06/1983
From:	Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
83-491-04-OLA, 83-491-4-OLA, ISSUANCES-OLA, NUDOCS 8310110224
Download: ML20078F907 (18)

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UNITED STATES OF AMERICA

• NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 2

i In the Matter of )

i ) Docket No. 50-289 METROPOLITAN EDISON COMPANY ) ASLBP 83-491-04-OLA

)

(Three Mile Island Nuclear ) (Steam Generator Repair)

Station, Unit No. 1) ) ,

LICENSEE'S RESPONSE TO PROPOSED CONTENTIONS OF JOINT PETITIONERS LEE ET AL.

I. INTRODUCTION i

On September 21, 1983, Jane Lee, Norman Aamodt and Bruce Molholt (" Joint Petitioners") proposed six numbered contentions in support of their petition to intervene in the above-captioned proceeding. Licensee herein presents its response to those contentions.

i The Joint Petitioners are not the only prospective inter-venors in this proceeding; Three Mile Island Alert, Inc.

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("TMIA") has filed proposed contentions as well. TMIA's con-tentions.are addressed in " Licensee's Response to TMIA 8310110224 831006

{DRADOCK 05000289PDR gs03

Supplement to Petition for Leave to Intervene" (hereafter referred to as " Licensee's Response to TMIA"), which is being filed contemporaneously with this document. Several of the issues raised by Joint Petitioners are also raised by TMIA.

Where this is the caso, Licensee has cross-referenced its Re-cponse to TMIA, rather than duplicating that document's de-tailed discussion here.

II. RESPONSE TO_ CONTENTIONS The issue before the Board now is not whether Joint Peti-tieners are right or wrong about the assertions made in their contentions, but whether or not their contentions meet the NRC's standards for admission into the proceeding as a matter of controversy which then will be decided on the merits by the Board.

An analysis of the legal requirements which proposed contentions must meet to warrant adjudication -- including the basic criterion in 10 C.F.R. 52.714(b) that "the bases for each contention [must be] set forth with reasonable specificity" -- $

is set forth in Licensee's Response to TMIA at 2-8. We rely on that analysis for our response to Joint Petitioners as well. -

Suffice it to say here that a number of detailed analyses of the steam generator repairs and their impact on operations, to-gether with extensive supporting information, are in the public  :.1 e

domain.1/ Joint Petitioners' awareness of this material is _

E 1/ 5 The most significant examples are the NRC Staff's "TMI-1 [.;.

Steam Generator Repair Safety Evaluation Report" (NUREG-1019) g (Footnote continued) y M

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apparent from:.the citations in their proposed contentions. It is encumbe'nc upon 'a petitioner, especially in-circumstances x such as these, to honor the requirement to set forth-the bases for its contentions.with'_ reasonable specificity and with refer-ence to available relevant documentation.

1 Proposed Centention 1 s s Joint Petitioners' first proposed contention is that there.

is no assurance-that~the'" steam generator tube repairs have not contributed to a condition which will cause early, failure upon restart." 'The only bases articulated for this co'n'tention are those whi~ch'are se: forth in the section (following Joint Peti-tioners' second contention) entitled " Discussion 1 &

s 2". None -

l of the bases there asserted, however, have any" applicability to the' impact of the: repairs on the steam generator tubes. Pro-posed Contention 1, standing alone, should therefore be

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rejected forilack of specificity and for lack of basis. In any case, as the analysis below of Proposed Contention 2 will show, Joint Petitioners' discussion section fails to identify any concerns which warrant consideration in this proceedir,g. ,

s (Continued) _

("SER") and its numerous attachments and appendices; Licensee's i

" Assessment of TMI-1 Plant Safety For Return To Service After Steam Generator Repair," Topical Report 008 (Rev. 3)

("TR-008"); and Licensee's Technical' Data Report No. 341, "TMI-l OTSG Failure Analysis Report"'(July, 1982) ("TDR-341").

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Proposed Contention 2 Joint retitioners' second proposed contention is that there is no assurance the steam generator tube repairs "will maintain their integrity under the environmental conditions at-tendant to operation." Petitioners' discussion section, as best we understand it, sets forth five independent sub-contentions to this general proposed contention:

First, the conditions necessary for initiation of Intergranular Stress Corro-sion Cracking (IGSCC) are present in the steam generator system.

Second, there is nothing to suggest the tubes have not suffered significant microstructural, or " morphological" changes apart from the stress cracks.

Third, the effect of dynamic stresses on the repair areas of the tubes was not ana-lyzed.

Fourth, the possible effects of chemical stress cracking agents other than sulfur were not predicted.

Fifth, the past operational history of the steam generator tubes has not been analyzed as a function of expected resistance to IGSCC.

Joint Petitioners, in apparent recognition of their obli-gation to address relevant documentation in the public domain, reference the NRC Staff's SER in support of their first sub-contention; for the remaining four, they rely on their belief that the SER fails to address the cited factor. In both cases, their reliance is misplaced. Neither the SER, nor the

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l other safety analyses which have been performed, support their contentions. i h

By Procosed Contention 2 (First Sub-Contention), Joint  !

Petitioners assert that, when the TMI-l steam generators recommence operations, the three following conditions which must be present to trigger IGSCC will once again exist: (1) "a highly sensitized metalurgical (sic) state" (i.e., a suscepti-ble alloy microstructure), (2) " dynamic stresses" caused by operation, and (3) the presence of "polysulfites [ sic), very labile compounds" in the Reactor Coolant System ("RCS") (i.e.,

an aggressive environment).

Licensee concedes that Inconel 600, the metal alloy used i i

to form TMI's steam generator tubes, is in "a highly sensitized state" known to be susceptible to IGSCC. (SER Att. 4, (

j at 2.) )

But as Petitioners are well aware, this was, and still is, true  :

of all Babcock & Wilcox ("B&W") steam generators, since they are all made of the same material and heat-treated in the same manner; neither the occurrence of IGSCC, or the subsequent repair of the tubes, had any affect on the susceptibility of b the alloy microstructure. We similarly acknowledge that ten-fj sile stresses, including those attendant to operation of TMI's -

steam generators, enhance initiation of IGSCC. Again, the rel-evancy of this assertion here is questionable at best, since it -

is true of all other steam generators ac well, and was not a 5

' result of the IGSCC or its repair.

Joint Petitioners' assertion that polysulfides are present in the RCS and provide the aggressive environment necessary for IGSCC, is materially different from their first two statements in one crucial respect: it is not even supported by the refer-ence on which they rely. Dr. Digby MacDonald's Technical Eval-uation Report (SER Att. 4, at 20-25',, cited by Joint Petition-ers in support of their assertion, does suggest that hydrogen polysulfides (a volatile polysulfur species that is very labile, that is, readily undergoes rearrangement) most likely acted as the source of sulfur in areas of the RCS, other than the steam generator tubes, which exhibited corrosion.2/ But the conclusion Dr. MacDonald draws from this fact is that it is necessary to clean, i.e., desulfurize, the RCS to ensure the existing polysulfides and thiosulfate (from which the polysulfides are formed) are removed or reduced in quantity, or that their corrosive potential is neutralized by oxidation.

(SER Att. 4, at 25. )

Licensee has done just that. All tanks, components and piping of the RCS which could have significant sulfur deposits were flushed with an alkaline solution of hydrogen peroxide.

2/ Thiosulfate was the likely form of sulfur in the tubes themselves. The other regions of the RCS where corrosion was found (e.g., the Power Operated Relief Valve ("PORV") and a weld in the waste gas system piping) were not exposed to a liquid environment. Consequently, thiosulfate, which can only exist in a dissolved state, could not be the corrosive agent in these areas. (SER Att. 4, at 23.)

And to provide added assurance that the potential for the corrosion had been eliminated, Licensee performed laboratory corrosion tests on representative samples of material in the RCS which had been subjected to a simulated hydrogen peroxide cleaning process. No intergranular attack was observed.

(TR-008 at 27.) The SER concludes that the desulfurization process and the laboratory tests, together with administrative controls designed to prevent further introduction of contaminants, provide reasonable assurance that when operations are restarted, the sulfur concentration will remain below the level required to initiate IGSCC. (SER $$3.5-3.7, at 27-33.)3/

Petitioners totally ignore Licensee's and the NRC Staff's extensive presentation on the impact of the cleaning process on the polysulfides. This wholesale failure to address, or even reference, the detailed documentation available on the issue of whether a chemical environment suitable for IGSCC exists, ren-ders the proposed sub-contention fatally flawed under the Commission's decision in Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), CLI-83-19, N.R.C. (June 30, 3/ Included in the information ignored by Joint Petitioners are (a) the fact that the sulfur need not be completely removed to prevent IGSCC, since low levels of reduced sulfur species in solution do not have a significant corrosive effect; indeed there is evidence to suggest the existence of a corrosion .

threshold in the order of 1.0 ppm (TR-OO8 at 24; see SER 93.5, at 27); and (b) the fact that after cleaning, the concentration of sulfur compounds in solution of the TMI-1 RCS was less than 0.1 ppm sulfate. (SER 63.6.2, at 30.)

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1983). The First Proposed Sub-Contention accordingly must be rejected as lacking in specificity and basis.4/

Proposed Contention 2 (Second Sub-Contention) states that the SER has not shown that the tubes have not suffered signifi-cant " morphological" changes other than IGSCC. Licensee does not contest that a microstructural evaluation of the tubing is appropriate. Contrary to Joint Petitioners' suggestion, howev-er, such an analysis was performed here; in fact, a series of metallurgical tests were performed on tubing removed from the TMI-l steam generators.5/ The subsequent evaluation of the data and analysis, demonstrated that the microstructure "is representative of that normally expected for steam generator tubing," and that "no secondary mode of failure (such as low or high cycle fatigue] is associated with the intergranular corro-sion." (TR-OO8 at 1, items b & c; see also id. at 13, item b.)

These tests, moreover, were discussed with approval by the NRC Staff's consultants (SER Att. 3 at 2-4; Att. 4 at 2-3.)

4/

purposesTheofTMI pH Technical control, Specifications already require that, for coolant be kept between 0.2 and 2.0 ppmlithium concentrations in the primary -

VI-1).) (TR-OO8 at 31 (Table i Licensee's increase in the minimum lithium concentra-tion to 1.0 ppm is simply intended as additional assurance that  ?

d sulfur-induced IGSCC will not recur. (See TR-DOS at 23 (Lithi-um added because it "could possibly be an inhibitor").) )

5/ Fourteen tests, including sodium azide spot tests and scanning addition, transmission electron microscopy, were performed. In eddy-current examination was performed on the complete length of the tubes in service.  ?

(See TR-OO8 at 8-9.) 5 u

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Petitioners do not in any manner attempt to show how Licensee's analysis is inadequate. In fact, they totally ignore that analysis and provide no basis for their bald assertion to the contrary.

, The Board should therefore reject the proposed sub-contention.

a Proposed Contention 2 (Third Sub-Contention) asserts that i there is no assurance the steam generator tube repairs will maintain their integrity during operation because the SER does l

not analyze the effect of " dynamic stress", i.e., stresses at-tendant to operations,6/ on the tubes in the repair area. Li-censee again agrees that such an analysis is necessary. For that reason, it instituted a multiphase test and analysis pro-gram to demonstrate the repaired tubes' load carrying and leak-tight capabilities when exposed to both " normal" steady state stresses such as tensile loading, and " transient" stresses such as heatup and cooldown thermal loading.7/ Licensee also tested 6/

stress" Although in this Joint Petitioners do not define the term " dynamic sub-contention, have the same meaning here as we assume it was givenitinisthe intended First to Sub-Contention, namely, stresses caused by operation.

7/ (See SER 53.4.2.a & b, at 18-20; TR-008 at 37-39 (load-carrying and leak-tight capabilities of the repaired joint);

see also SER 63.4.2.d at 21; TR-008 at 82-85 (capabilities of the free-span).)

The first phase of the test program involved qualification first five years.

testing to show capability to operate for the The second phase included extended confirmatory tests to verify that the repaired tubes will maintain their design-life capabilities. (See TR-008 at q 35-36.) s C

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and analyzed the capability of the tubes to withstand the maximum loads which would be experienced during an accident --

those attendant to a Main Steam Line Break (MSLB).g/ Based upon these tests and the accompanying calculations, Licensee concluded that the repaired tubes will maintain their structur-al and leak-tight integrity during steady-state operations, transient conditions and design-basis accidents. (TR-008 at 88-89.)9/

The testo performed by Licensee were examined in detail by the NRC Staff. (See $3.4 of the SER.) Based on their review of Licensee's tests, as well as independent tests performed by a Staff consultant, the Staff concurred in each of Licensee's findings.

Joint Petitioners do not explain in their Third Sub-Contention what they perceive to be the inadequacies in the evaluations by Licensee and the NRC Staff of tube integrity under stress, or why they otherwise disagree with the conclu-sions reached in the evaluations. Indeed, Joint Petitioners fail to even reference the relevant sections of the SER and g/ (See SER S3.4.2.a, at 18-19; TR-008 at 39 (the repaired i joint); SER S3. 4. 2.d, at 21-22; TR-OO8 at 84-85 (the free-l span).) A MSLB is the most limiting accident scenario for tube (See TR-008 ct 84.)

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integrity considerations.

9/ With respect to the MSLB, the analysis showed that through-wall defects can be detected well below the threshold size that could fail during such an occurrence. (TR-008 at 85-87; SER S3.4.2.d, at 22.)

Topical Report. For these reasons, Joint Petitioners' proposed sub-contention must be rejected on the ground that they failed to supply any bases for their allegation.

Joint Petitioners next assert, in Proposed Contention 2 (Fourth Sub-Contention), that the tubes might not maintain their integrity because the effect of chemical stress cracking agents other than sulfur has not been predicted. The conten-tion is simply Unsupported speculation. As we discussed in de-tail in Licensee's Response to TMIA (at 25-26), Licensee examined the potentially corrosive elements present in the RCS.

On the basis of that examination, the safety analyses unani-mously concluded that sulfur, in its various forms, was the causative agent of the IGSCC in the TMI-l steam generators.

Petitioners give no indication that they have even read the relevant documents, much less identify any deficiencies in these analyses. Nor do they provide an explanation as to why the effect of other corrosive agents on future operations i

should be predicted, given the fact that sulfur was the only corrosive agent present in the system in significant quantities. The proposed sub-contention thus lacks any bases, and should be rejected.

Proposed Contention 2 (Fifth Sub-Contention) asserts that the SER does not analyze the past operational historf of the steam generator tubes as a function of expected resistance to IGSCC. Joint Petitioners have once more overlooked or ignored 1

the discussion in the various safety analyses on the issue they raise. Both TDR-341 and TR-OO8 describe in detail Licensee's review and analysis of the operational history of the TMI-1 steam generatore from April, 1978 to November, 1981, which was

undertaken in order to determine whether instances of excessive

tube stress or chemical contamination could have contributed to f

the tube failure.10/ The evaluation revenled "that the tubes were not subjected to excessive stress." (TR-OO8 at 7.) On j the other hand, Licensee found that there were a handful of in-stances where chemical contaminants entered the RCS. Licensee

- concluded that the contamination of the RCS with sodium thiosulfate during several of these instances which was then present during Hot Functional Testing ("HFT"), combined with oxygen introduction and changes in the water level of the RCS following HFT to provide the aggressive environment necessary for IGSCC. (TR-OO8 at 7-8, 13-15; TDR-341 at I-3.) The NRC Staff concurred in this evaluation of the relationship between the tubes' operational history and the onset of IGSCC. (SER 53.1, at 5-7.)

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t 10/ Licensee also analyzed the fabrication history of the steam generator tubes. (See TR-OO8 at 10, item b; 11, items c

. & d; 12-13, SD.) The report found that the heat treatment of the tubes following assembly increased their sensitization. As noted supra p. 5, this is true of all B&W steam generators; there is nothing to indicate the fabrication or installation of the TMI-1 tubes was at all extraordinary, much less that the l prior heat treatment is tied in any way to the subject matter of this proceeding -- the repair. (TR-OO8 at 13.)

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Joint Petitioners have not identified any inadequacies in the consideration of operational history in the current safety analyses. As a consequence, their Fifth Sub-Contention should be disallowed.

Proposed Contention 3 Joint Petitioners' third proposed contention is that Li-censee has provided no assurance that elements or compounds other than sulfur did not significantly contribute to the IGSCC. The reasons why this proposed contention should be rejected are discussed in Licensee's Response to TMIA at 25-26.

See also the discussion of their similar assertion in Proposed Contention 2 (Fourth Sub-Contention), p. 11, supra.

Proposed Contention 4 Joint Petitioners assert in Proposed Contention 4 that there is no assurance that beyond-design compressive f atigue or stress did not predispose TMI's steam generators to IGSCC. Pe-titioners have given no indication, however, why or how compressive stress could possibly have been a factor in the onset of IGSCC. There is simply no reason to believe that it was. To the contrary, by definition, IGSCC requires a tensile stress across grain boundaries to initiate cracking. The con-sistent circumferential orientation of the cracks, moreover, compels the conclusion that axial tension stress was the cause of the observed IGSCC (along with the metallurgical and environmental factors). Axial compressive stress could thus not be a factor because, again by definition, such a loading could not apply a tensile stress across circumferentially-oriented grain boundaries. (TDR-341 at II-2, II-3; see SER 53.1, at 4; TR-008 at 10, item d.) Similarly, compressive fa-tigue was demonstrated not to be a factor here; indeed, exami-nation of the fracture surfaces showed no evidence of any fa-tigue whatsoever. (TR-008 at 10.)

In light of Petitioners' failure to address -- or even reference -- the above discussions, or to reference contrary authority for this assertion, or even to proffer a credible ex-planation for their concern that compressive fatigue or stress could potentially predispose the steam generators to IGSCC, the proposed contention should be rejected as lacking specificity and basis.

Proposed Contention 5 Proposed Contention 5 seeks to inject in this proceeding an issue of management competence and integrity having nothing to do with the adequacy of the steam generator repair program; it should be addressed, if at all, to the Atomic Safety and Li-1

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censing Board which has been charged, in connection with man-agement issues in the TMI-1 Restart Proceeding, to hold a reopened hearing on the allegations of falsification of leak t

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rate tests at TMI-2. One of the Joint Petitioners (Norman Aamodt) has in fact been invited by that Licensing Board to propose appropriate sub-issues for consideration in that hear-ing. (Memorandum and Order, September 14, 1983, Docket No.

50-289 (Restart).) Further, the NRC Staff has already notified the Commission and the affected Boards and parties in the Restart Proceeding that, in connection with the revalidation of its position in the restart hearing on management issues, the Staff has under investigation the matter of pre-accident leak rate testing practices at TMI-1 as well as TMI-2. (BN-83-183, September 2, 1983, and BN-83-183A, September 23, 1983.) The proposed contention should thus be dismissed on the ground that it is beyond the scope of this proceeding.

Proposed Contention 6 Joint Petitioners' Proposed Contention 6 claims there is a lack of assurance that the repaired steam generator tubes will maintain their integrity under transient conditions in that the SER fails to present an " adequate analysis" of tube integrity during transients. The analyses by Licensee and the NRC Staff of tube integrity during transients has been discussed in the context of Petitioner's generic assertion, in their Third Sub-Contention of Proposed Contention 2, that operational stresses have not been adequately assessed. See pp. 9-11, supra. For the reasons set forth therein, Proposed Contention 6 fails to meet the basis-with-requisite-specificity requirement of 10 C.F.R. 52.714(b), and should be rejected.

CONCLUSION For the foregoing reasons, none of Joint Petitioners' pro-posed contentions should be admitted for litigation. Joint Petitioners should therefore not be permitted to participate as parties to the instant proceeding. 10 C.F.R. 52.714(b).

Respectfully submitted, fY $ r .

George F. Trowbridge, P.C.

Ernest L. Blake, Jr., P.C.

Delissa A. Ridgway Diane E. Burkley SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202)822-1000 Counsel for Licensee Dated: October 6, 1983 DOCKETED usunc Octgr 001 -196'N UNITED STATES OF AMERIEdl?' 5 iU NUCLEAR REGULATORY COMMIS&fbkgAHCM BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON CO., ET AL. ) Docket No. 50-289-OLA

) ASLBP 83-491-04-OLA (Three Mile Island Nuclear ) (Steam Generator Repair)

Station, Unit No. 1) )

l CERTIFICATE OF SERVICE i

I hereby certify that copies of " Licensee's Response to Proposed Contentions of Joint Petitioners Lee et al.," dated October 6, 1983, were served this 6th day of October, 1983, by deposit in the United States mail, first class, postage prepaid, to those persons on the attached service list.

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Diane E. Burkley h October 6, 1983 4

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. _ m .  : 0.:..:.n In the Matter of )

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METROPOLITAN EDISON CO., ET AL ) Docket No. 5 0 - 2 8 9-oLA

) ASLUP 8S-491-04-OLA (Three Mile Island Nuclear ) (Steam Generator Repair)

Station, Un_t No. 1) )

SERVICE LIST C Sheldon J. Wolfe, Chairran Joanne Dorcshcw/Icuise Bradford Atcmic Safety and Licensing Beard Three Mile Island Alert, Inc.

.U.S. Nuclear Regulatcry Comnission 315 Peffer Street Washingten, D.C. 20555 Harrisburg, Perr.sylvania 17102 Dr. David L. Eetrick Jane Lee Prcfessor of Nuclear Engineering 153 Valley Fcad University of Arizona Etters, Pennsylvania 17319 Tucson, Arizora 85721

' Bruce Molholt, PhD.

Dr. James C. Lamb, III Haverford College Decartrent of EnvircnmenM Sciences Haverford, Perr.sylvania 19041 and Engineering University of North Carolina Nornan Aamodt Chapel Hill, North Carolina 27514 R. D. 5, Box 428 Coatesville, Pennsylvania 19320 0 Mary E. Wagner, Esquire Office of Executive Legal Director Atcmic Safety and Licensing Appeal U.S. Nuclear Pegu1~atory Comission Board Panel Washington, D.C. 20555 U.S. Nuclear Begulatcry Ccmrissicn Washington, D.C. 20555

• Docketing and Service Section (3)

Office of the Secretary U.S. Nuclear Begulatory Comission Washingten, D.C. 20555 Ataric Safety arri Licensing Scard Panel U.S. Nuclear Pagulatory Ccanission Washingten, D.C. 20555

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