ML20079J116
| ML20079J116 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/20/1984 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8401240215 | |
| Download: ML20079J116 (11) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARU%RC In the Matter of
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'84 dM 23 m2 de METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
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(Steam Generater e.Repsir.,)
(Three Mile Island Nuclear
)
fiCh C i[ G frj Station, Unit 1)
)
' 4.'
TMIA RESPONSE TO LICENSEE MOTION TO DISMISS TMIA CONTENTIONS la, lb,_1c, ano 2bl and SUPPLEMENTAL INTERROGATORY RESPONSES TO LICENSEE In response to Licensee's Motion to Dismiss Contentions and Motion to Compel Discovery, both dated January 9, 1984, TMIA hereby submits this consolidated response.
The interrogatory responses are attacheo.
Due to the lateness of the hour, TMIA was unable to attach en affidavit affirming the truthfulness of these interrogatory responses.
Thus, it does so without an accompanying afficavit.
In a sharp accusation, Licensee claims that TMIA has been " unable to provide any basis" for contention la, lb, lc, and 2bl," and thus moves f or an order dismissing these contentions.
To the extent that this is based upon a complaint that documentary referer.ces were not previously supplied to Licensee for TMIA's contentions, which are based in substantial part upon the failure of both the Licensee and the NRC Staff to provide sufficient data to demonstrate that operation with the as-repaired TMI-1 steam generators would be consistent with safety, the attachea supplemental interrogatory responses should satisf y Licensee's concerns.
8401240215 840120 DRADOCK05000g 1 503
. To the extent that Licensee's position is based upon its
. disagreement.with TMIA's position that both the Licensee and the NRC Staff,have f ailed to provide suf ficient data to demonatrate that operation with the as-repaired TMI-1 steam generators would be consistent with safety, TMIA simply states that it is Licensee's
-burden to prove the statutory and regulatory requirements for safety regarding this license amendment have been met.
That~they have not yet met this burden in light of the public information available is a view' shared not merely by the Intervenors in this case.
It is a view
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which has been expressed by members of Congress, such as Congressman William Goodling (R-PA) who explicitly asked that hearings be held on this license amendment.
In addition, an NRC Commissioner recently expressed concern over some of the substantive issues in this case.
In his recent opinion
.regarding the Staff's "no significant hazard" recommendation, Commissioner Asselstine noted his own lack of information regarding the safety of these repairs, asking for an explanation as to why certain substantive issues were not considered "significant new or unreviewed safety issues."
See, VIEWS OF COMMISSIONER J AMES K.
'ASSELSTINE ON THE NRC STAFF'S NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION ON THE THREE MILE ISLAND UNIT 1 ( TMI-1 ) LICENSE AMENDMENT APPLICATION FOR STEAM GENERATOR REPAIRS, Page 15-16, (January 10, 1984).
Commissioner Asslestine asked for "a convincing explanation, including a documented supporting analysis."
As does Commissioner Asslestine, TMIA believes that such has not yet been provided.
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, Moreover, TMIA believes it has a responsibility to all those who have expressed concern with the efficacy of these repairs, and the course being proposed by the Licensee and the NRC Staff regarding these nearly destroyed TMI-l steam generators, to assist in resolving these concerns.
With regard to Contentions lb and Ic (as revised), the Board has appropriately dealt with Licensee's attempts to have these contentiens dismissed once before.
TMIA stands by the Board's analysis.
Contention lc has now been supplemented with additional documentation.
With regara to Contention 2bl, additional documentation has also been provided.
In addition, Licensee would have this Contention oismissed on the basis of its assurances that its own testing proves that the very serious questions raised by Mr. Dillon are no longer relevant.
There is no more reason to do that than there is to avoid hearings altogether simply by accepting Licensee's assurances that the entire repair process ensures safe plant operation.
Licensee's position is obviously untenable.
Respectfully submitted,
/
By:
M J anne Doroshow ouise Bradford
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January 20, 198$
TMI Alert
B.
Suppirmental Re7ponsn to Licensee Interrogatories 1.a-4: The areas where TMIA believes the data is inadequate to demonstrate reasonable assuranance that the ruptures can be detected in time and preventeo, can presently be fdhd in the following documents:
TDR 008, Rev. 3, PP. 11-33: Regarding thefailure analysis, the Corrosion Test Prgram, and evaluation of crack arrest,verifcation of the corrosion scenario, and ef fectiveness of the cleaning program.
TDR 008, Rev. 3, PP. 37-43.
Qualifigatigg,, Program.
TDR 008, Rev. 3, PP. 43-47.
Repair Testing.
TDR 008, Rev. 3, PP. 47-48.
Post repair te sting.
TDR 008, Rev. 3, PP. 49-55, Ef fects of the Expansion Hepair.
TDR 008, Rev. 3, PP. 60-61. Verification of Plug Intergrity.
TDR 008, Rev. 3, PP. 62-73. Tdting of proposed 1500 plugged tubes.
TDR 008, Rev. 3, PP.
74-89. Evaluation of tubes lef t in service.
TDR 008, Rev. 3 PP. 100-103. Environmental Impact Predictions.
TDR 008, Rev. 3, Appendix A.
TDR 417, Rev. 2.
This entire document we believe is relevant to our contenten.
At this point in time, we find the following areas seem particularly important to an evaluation of safety:
P.
5: heat-up/cooldown cycles; P.
7-8 and 24: tube /shell differential;use of thbMSLB as the limiting condition for evaluation of highest tube loads; P.
19: effects of various tube loads; PP. 19-21; evaluation of ECT unevaluated cracks; PP. 21-24; leak predictions from thruwall cracks; PP. 24-26; leak predictions during cooldowns; p.
26, Par. 3; conservative assuptions regarding crack size.
'hhefollowbg Refer-ences have not been supplied to TMIA: Documents in Reference 2, 4, 6,
8, 9, 10, 12, 14, 16, aw} one could reasonably conclude that these documents contain highly material evidence regarding Licensee's assurances, l
d In addition, the following references in TDR 388, Rev. 3, refer to documents wuch have not beensupplied to TMIA: Reference la, Ib,
'2, 3, Sa, 6, 11, 14, 15, so thc at this point in time, this document can not be independently evaluated to determine its credi-bility.
The same problempxists regarding BAW 007,
References:
3, 10, 14, 17, 18, 19, 24, 25, 30, 31, 32, 33, 34, 51.
In addition, this document has been provided to TMIA with the following material pages missing in their entirety, so that it is impossible to even know what the document % conclusits are based upon:
2-28, 29, 36-39, 49-52, 54, 57-61, 63-69, 73-77, 79-80, 82-89, 93-96, 98, 100, 129-130; 3-1, 2.
In addition, thL following pages contain
, proprietary information which has been omitted: 2-31; 2-56; 6-2.
Within the SER, the entire document, is merely a summary of conclusinns and findings based on Licensee testing and analysis as repo rted in documents which we hae already described above as being insufficient, no indLpendent verification having being done.
We find the fo13 king findings and conclusions particularly unsupported P.
3, regarding testing to demonstrate leak tightness and load carrying capabilities of the 6" transition zone; P.
14, regarding the' fracture mechanics analysis of circumferential cracks; P.
16, regarding thermal and pressure cycle loadhg tests; P.
17 regarding mechanical tests to qualify the repair process; P.
18, regarding the axial load tests P.
19, regarding residual stresses in the transition zone; P.
19, regardhg ef fects of expansion on tubes; P.
22, regarding the effect of expansion on existing plugs:
P.
24, regarding the plugging method;. P.
27, regarding the clean up of the contaminant; P.
26, retarding tests to verify plug integrity; P.
27, regarding stress corrosion tests; P.
28, regarding tests to demonstrate peroxide treatment; P.
36, regarding the transient and accident analysis.
Also, Attachment
3.
1 to the SER, which the Staff relies heavily upon for a nuiaber of its findings and conclusion % has not been provided to TMIA, making'it further impossible to verify the Staff's conclusions.
Also, the follow-ing statements in the Third Party Reports form thtbasis for our contenti cn: (for clarity sake, TMIA refers to these statements by Eidentifying them with particular interrogatories served on Licensee)
See Interrogatories T-8, 9, 11, 12, 14, 15, 16, 17, 19, 20, 22, 23, 24, 25, 27, 30, 34, 38, 39, 43, 44, 46, 50, 51.
In addition, the following references in TDR 010, refer to documents w&ch have not been supplied to TMIA: References 1-4.
Also, since
the pages are not number ~ed, it is virtually impossible to determine if entire pages are also missing from this document.
In addit 6n, no data has been provided in support of the document's Appendix A, which explains the test program.
9 m
k 1.a-8. License corditions are listed at P. 46 of the SER.
TMIA is most concdhed about Condithns 3 and 4, because of the failure of the documents listed in the response to Interrogatory 1.a-4, to provide sufficient data to assess the adequacy of the license-conditions prophed.
Of particular note is problems with the ability of ECT to detect certain cracks (008, Rev. 3, at P. 44; 417, Rev. 2, at P.
19-21); and 417 in its entirety regarding
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cracking predictability through leakgae detection, the basis for l
license condition 4.
For paticulars, see above response, i
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1.a-ll. See response to 1.a-4.
1 1.a-20. See reponse to 1.a-4.
1.b-4. See response to 1.a-4.
s
.l.c-5.
See response to 1.a-4.
Of particularnote is TDR 008, p.
16, first full paragraph; TDR 007, 2-14.
These sections concern tube dannage after expansion repeir.
1.d-2.
See references to the SER and TDR in 1.a-4.
1.d-5.
Tnere is notcing TMIA can add here. The answers already supplied to Licensee describe the inconsistencies TMIA has so far been able to identify.
1.d-24, 1.d-25, 1.d-29. In September of 1983, TMIA representatives spoke to Dr. George Sih, Director, Institute of Fracture and Solid Mechanics, Lehigh University.
Dr. Sih st ated that under thermal
.g i stress, small cracks are more likely to propagate than large cracks because small cracks store more energy proportionate to their size than large cracks.
In none of the sections listed in 1.a-4 regarding TDR 008, or in the sections listed in 1.a-4 regarding the SER, was i
this criteria mentioned, or was any perceivable analysis done which takes crack size into account.
2.a-7. TDR 008, Rev. 3, PP. 11-33.
SER, PP. 4-8; and Attachment 3 at P.
12, and at PP.18-24t Attachment 6, P.
9.
Also, 008, Rev. 3, PP. 74-89, 2.a-14.
See above response.
In addition, SER Attachment 3 at 12-14; TDR 007, at 2-14.
With regard to the adequacy of Licensee's stress analysis regarding when cracking could reoccur, all da*a and analyses which TMIA has already identified in 1.a-4 as being inadequate to provide reasonable assurance that testing is adequate, are necessarily relevant.
Regarding the lithium addition, TD2 008, P30, (C)(1), in particular.
Also, SER Attachment 6, P.
4, Comment (C)(1);P.5, Comment (C)(4).
2.h-19. See response to 2.a-7.
2.a-24. TMIA can do no more at this time, other than to idehify questions raised by Licensee and Staf f consultants regarding the possibility of other contaminants, in particular, Attchment 4 to the SER at P2c 18-24, and Attachment 6 at P.
9.; 12-14 (D), Finding 2.
'2.b.1-8.
The documents which TMIA detects no consideration of Mr. Dillon's concerns, can be found in response to 1.a-4, in. par-ticular, TDR 008, PP., 47-55: 60-893 all references to TDR 417 in response to 1.a-4; the SER at PP. 27-36; and Attachment 6, P. 6, par. 2.
2.b.1-14.
See above response, as relates to the general clean up.
2.b.2-ll.
See response to 2.b.1-8, as relates to the risk of reinitiation, and 2.a-24.
Also, Attachment 6, P. 11 (Comment 4).
2.b.2-15.
- SER, P. 32, 3.6-1 (e), and Respose to 2.a-24.
2.c-9.
See references to to the SER and the TPR in response 2.a-24, in addition to those already identified in 2.a-6.
2.c-15.
TMIA now objects to this Interrogatory on grounds of relevancy, in that the Board, by Order dated January 9, 1984, has frised Contention 2.c to eliminate the " axial symmetric stress analysis" issue from this contention.
2.c-21.
See response to above Interrogatory.
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2.c-31.
TMIA now objects to this Interrogatory on the grounds of i
L relevancy, in that the Board, by Order dated January 9, 1984, has revised Contention 2.c to eliminate the " toughness v. hardness" issue from this contention.
2.c-40. See response to 2.d-24-29.
UNIT 8D STATES OF AMERICA NUCLEAR REGULATORY COMMISSION COLHETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD UW'O W M 23 M209 In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50 tSM9E OF SECRLin
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00CKEimG a SEfiViu (Three Mile Island Nuclear
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isRANCH Station, Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of the attached TMIA RESPONSE TO LICENSEE MOTION TO DISMISS TMIA CONTENTIONS la, lb, lc, and 2bl, AND SUPPLEMENTAL INTRROGATORY RESPONSES TO LICENSEE dated. January 20, 1984, were served this 20th day of January, 1984, by deposit in the U.S. Mail, first class, postage prepaid, or, BY AGREEMENT WITd LICENSEE'S COUNSEL, hand delivered on January 23, 1984, to those on the attached service list.
i Ot ANNE DOROSHOW l
I
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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i
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METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
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ASLBP 83-491-04-OLA J
(Three Mile Island Nuclear
)
(Steam Generator Repair) i Station, Unit No. 1)
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I SERVICE LIST Sheldon J. Wolfe $
l Administrative Judge Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C.
20555 Office of the Secretary U.S. Nuclear Regulatory Commission l
Dr. David L. Hetrick Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Board Professor of Nuclear Engineering George F. Trowbridge, Esq.
i University of Arizona Shaw, Pittman, Potts & Trowbridge Tucson, Arizona 85271 1900 M St.,
N.W.
Washington, D.C.
20036 Dr. James C.
Lamb, III Administrative Judge Jane Lee Atomic Safety and Licensing Board 183 Valley Road 313 Woodhaven Road Etters, Pennsylvania 17319 Chapel Hill, North Carolina 27514 i
Norman Aamodt Richard J. Rawson, Esq.
R.
D.
5, Box 428 i
Mary E. Wagner, Esq.
Coatesville, Pennsylvania 19320 Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 m
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