ML20079S069
| ML20079S069 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/31/1984 |
| From: | Burkley D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | AAMODTS |
| Shared Package | |
| ML20079S058 | List: |
| References | |
| 83-491-04-OLA, 83-491-4-OLA, ISSUANCES-OLA, NUDOCS 8402030187 | |
| Download: ML20079S069 (41) | |
Text
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COCKETED usuRC January _31 1984,,
UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL.
)
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Three Mile Island Nuclear Station,
)
(Steam Generator Repair)
~ Unit No. 1)
)
LICENSEE'S RESPONSE TO JOINT INTERVENORS' INTERROGATORIES (SET 1)
Licensee hereby submits its response to the Interrogator-ies (Set 1) of Lee et al.
(" Joint Intervenors") which were served on Licensee on January 16, 1984.
Some of Joint Intervenor's interrogatories may be beyond the scope of the contentions as admitted by the Board, and hence beyond the proper scope of discovery.
See 10 C.F.R. 5 2.740(b)(1), which requires that discovery ".
shall re-late only to those matters in controversy which have been iden-tified by.
the presiding officer In answering 4
such interrogatories, Licensee is not waiving its right to ob-ject to the consideration of such subject matter during the course of these proceedings on the grounds that it is immaterial and irrelevant.
8402030187 840131 PDR ADOCK 05000289 g
PDR 1
m Where the response to a given interrogatory is set out in existing documentation, Licensee frequently has referenced such material rather than repeating the information here.
Where possible, references to documents contain section or page num-
~
bers.
If none appear, the reference is to all of the informa-tion in'the document.
The referenced documents are being pro-vided herewith, provided, however, that where they contain information proprietary to The Babcock & Wilcox Company and/or Licensee, the proprietary information will be provided to Joint Intervenors subject to an appropriate proprietary information agreement sagned by Licensee and Joint Intervenors'and a Pro-tective' Order entered by the Board.
Documents containing pro-prietary information are indicated by an asterisk in the docu-ment list herein.
.I.
INTERROGATORIES Interrogatory 1 What is the composition of the tubes in the steam genera-tors at TMI (1) (hereafter referred to as " tubes")?
l (a)
Give range of content of each element.
l (b)
Give range of content of each sulphur compound.
l I
l
Response
The range of elemental contents of the tubes, deter-l mined by analysis, are as follows:
r.
f f
Nickel 72.36-77.71 weight percent Chromium 14.22-16.06 Iron 6.25-9.85 Carbon 0.018-0.058 Copper 0.01-0.20 Manganese 0.21-0.44 Sulfur 0.001-0.0094 Silicon 0.020-0.050 I
Phosphorus 0.005-0.010 Aluminum 0.09-0.20 l-Niobium 0.026-0.030 Titanium 0.16-0.29 Boron 0.019-0.043 Magnesium 0.010-0.025 Cobalt 0.01-0.045 Molybdenum 0.01-0.08 Lead 0.001-0.005 The analysis were performed for elements only.
The range of content of each sulfur compound was therefore not de-termined.
Interrogatory 2 What contaminants were present in tube material "as re-ceived"?
Response
A contaminant is any foreign or unwanted element which would render the material unfit for service.
There were no contaminants present in the tube material.
Interrogatory 3 What is the range of the content of the contaminants described in answer to 1(2)27
Response
See response to Interrogatory 2. -
s
(
9 Interrogatory 4 What precipitates were found within or on the flanks of tube cracks generated in the plant?
Response
The following precipitates were detected on the sur-faces of cracks on tubes removed from the TMI-1 OTSG's:
Nio, Feo, Cr203, Ni(OH)2, FeOOH, CrOOH, Ni203, NiS, coo.
Interrogatory 5 What precipitates were found within or on the flanks of cracks generated in laboratory tests?
Response
No surface analysis was performed on laboratory-generated cracks.
4 Interrogatory 6 Gire composition of tubes of 1(2)4.
Response
The following table gives the reported analysis of tubes on which surface analysis was performed on cracked sur-faces: - _ _ _ _ - _ _ _ _ _ _ _ _ - _ _
f f
Tube Numbers B8-25 B11-23 A71-126 A146-6 A78-32 A11-66 A133-74 B10-29 B111-62 A112-7 Element Concentration, weight percent Nickel 75.75 74.16 74.66 76.59 77.'53 73.18 75.06 Chromium 15.42 15.29 14.94 15.13 14.92 15.60 15.53 Iron 7.68 9.18 9.30 6.94 6.50 9.80 8.25 Carbon 0.039 0.055 U.027 0.045 0.029 0.032 0.035 Manganese 0.35 0.38 0.30 0.35 0.28 0.39 0.35 Silicon 0.26 0.40 0.33 0.47 0.24 0.50 0.25 Sulfur 0.0025 0.006 0.002 0.001 0.0048 0.0041 0.0029 Copper 0.02 0.06 0.01 0.02 0.02 0.02 0.04 Aluminum NR 0.14 0.13 0.16 0.16 0.10 0.19 Titanium 0.24 NR O.19 0.21 0.25 NR O.21 Boron 0.0039 NR 0.0027 0.0031 0.0027 0.0028 0.0027 Magnesium 0.019 NR NR O.20 0.016 NR O.022 Cobalt 0.01 NR 0.01 0.028 0.01 NR NR Lead 0.001 NR NR 0.001 NR 0.005 0.05 Molybdenum NR O.05 0.08 NR NR NR NR Phosphorus NR O.006 0.006 NR 0.005 NR 0.0063 NR - Not Reported Interrogatory 7 Regarding samples of 1(2)S:
(a) provide composition of samples; (b) provide sample preparation method (s), including heat treatment; (c) provide test description, including test envi-ronment; (d) provide method whereby crack composition was evaluated; (e) provide all test procedures; and (f) provide all test data. l-
e e
i
Response
Two test programs were performed to generate sulfur-induced intergranular stress-assisted crachs.
Details of the l
programs are contained in References 1 and 2.
Interrogatory 8
~
Describe in full the mechanism (s) licensee relies upon to describe IGSCC generation in the. tubes of the OTSG.
Response
Cracking of the steam generator tubes was a result of sulfur-induced intergranular attack at low temperatures.
The mechanism of this attack is as described in the GPUN Topical Report 008, Rev. 3,Section II.
See also References 3 and 4 (Appendix X).
Interrogatory 9 Describe all programs conducted by or for licensee to de-termine whether agents other than sulfur contributed to IGSCC.
Response
To determine and verify the cause of the tube cracking, GPU Nuclear undertook a multi-faceted program.
This program included analysis of the RCS water chemistry, RCS oper-ational history, plant procedures, and in-depth failure analy-sis of tube samples removed from the steam generators.
(Refer-ence 3.)
Preliminary evaluation of tube samples removed from the steam generators indicated that the failure mode was intergranular cracking.
With this knowledge, an extensive - - - -
.c search was begun to identify the specific parameters of envi-ronment, stress and material condition which would have been responsible for producing this cracking.
Concurrent with this, an extensive non-destructive examination program was begun in the steam generators to identify the extent and location of the cracking:(TR-008, section IX. B).
In order to assess the environment responsible for cracking an evaluation of the plant water chemistry prior to and during hot functional testing was conducted.
(Reference 3.)
After hot functional testing an extensive analysis was also made of reactor coolant samples taken from other primary systems.
(Reference 3.)
Analysis of the failed tubing was conducted by two independent laboratories.
(References 10-13.)
These analysis included failure mode characterization, surface analysis of de-posits and films present on the crack faces and ID tube sur-faces, microstructural characterization and many other analyses as described in the failure analysis reports.
Independent of the failure analysis work, GPUN com-missioned a review of the literature on SCC of Inconel 600 to identify potential causative agents which could be responsible for the cracking observed. (Reference 4.)
Additional reports were also reviewed.
(See References 31-35).
The identified causative agents which can be respon-sible for producing or influencing cracking in Inconel 600, were evaluated in conjunction with the detailed metallurgical --
O investigation, the stress analysis to define residual and stress in the tubing, the evaluation of the piant operational history as well as the OTSG fabrication history.
As the analy-ses'proceded, it became evident that matastable sulfur was the causative agent of the IGSAC observed.
Using all.the elements of the failure analysis investigation, the failure scenario was determined.
A screening test program and corrosion testing were performed to test this failure scenario and to verify that cor-rective actions taken based on that failure scenario were ade-quate.
(References.1, 5, 6, 8 and 15.)
Both the short and long term corrosion tests used simulated primary system water containing sulfate, chloride and fluoride, and used as-removed tubes with any contaminants which had been present (e.g. car-bon) left intact.
These tests corroborated the failure scenar-io.
An additional literature search further corroborated that other corrodants were not involved.
(See. References 25-30).
j Interrogatory 10 Provide all results obtained from the programs described l
in answer to 9.
Response
The results obtained from the above programs to date l
l are contained in References 1, 4 (Appendix II),
5, and 8.
Interrogatory 11 l
l Describe all programs conducted by or for licensee to de-termine whether agents other than sulfur caused IGSCC.
' l l
l
'O O'
Response
See Response to Interrogatory 9.
Interrogatory 12 Provide all results obtained from the programs described in answer-to 11.
Response
See Responst to Interrogatory 10.
Interrogatory 13 What significance does licensee place on IGA isi ads re-mote from expansion area?
Response
In the absence of an aggressive environment, the IGA islands in the TMI-1 OTSG tubes are not a significant concern from either a corrosion or a mechanical propagation standpoint.
Interrogatory 14 What progression of morphological change does licensee rely upon to describe IGA islands over the projected life of the OTSG's?
Response
Under established operational and chemistry limits, no morphological change to IGA islands is anticipated.
Interrogatory 15 Provide list of all elements, compounds, and other contaminants and their concentrations which could be expected to be found in the water passing through the tubes of the OTSG's over their expected lifetime.._.
}
e
Response
The elements, compounds and contaminants expected to be found in OTSG water are detailed in Reference 7.
The pres-ence of other components not identified in this specification is unlikely, but would be detected by routinely scheduled measurements of pH and specific conductivity.
Interrogatory 16 In the following questions, reference is made to Report of the Third Party Review of Three Mile Island, Unit 1, Steam Gen-erator Repair, Supplement 1, May 16, 1983.
(a)
Has Licensee obtained a Total Organic Carbon (TOC) analyzer?
(b)
If not, when does Licensee expect to obtain one?
.(c)
Has Licensee in its employ personnel who are trained to use and/or interpret the data obtained from a TOC?
(d)
Identify these personnel.
(e)
Describe the technical specifications of Licen-see's TOC, if existent, relative to PPM.
(See page 3, "Further Comment 3").
Response
l (a)
Yes.
l (b)
Not applicable.
l (c)
Yes.
(d)
Robert M. Glass, Senior Chemist, GPU Nuclear j
Chemistry and Materials Department; Denise B.
Smith, Chemistry Technician, GPU Nuclear Chemis-try and Materials Department; Roger B. Gill, L
Plant Staff Chemist; and A. P.
Sumallo, Chemical l
o
(
Engineer, GPU Nuclear Chemistry and Materials Department, are trained to use and/or interpret data from the TDC.
Interrogatory 17 Has Licensee determined the nominal or "ba'kground" sodium as recommended at page 4, "Further Comment 6."
Response
Yes.
The " background" sodium levels under power op-erating conditions are less than 0.01 ppm based upon measured levels of Na-24.
Interrogatory 18 (a)
As discussed at page 4, "C.
Materials Applica-tion, Comment 1," have any small cracks, not detected at the time of the repair of the tubes been detected since that time?
(b)
Have any further inspections been conducted since the repairs until the present time?
(c)
If so, provide the results of these inspections (and dates), names of GPU or contractor personnel who made the inspections.
Response
The TPR's Comment 1 under Section C,
" Materials Application," does not pertain to the steam generator tubes.
Interrogatory 19 Concerning the recommendation at page 5 " Comments 2 and 3," what plans has Licensee made and/or implemented to make corrosion tests?
Response
" Comments 2 and 3" at page 5 of the May 16, 1983 TPR Supplement refer to Licensee's long-term corrosion test pro-gram, which is in progress.
The long-term corrosion test pro-gram is described.in Licensee's TR-008,Section III.D at pages 25-27.
Interrogatory 20 Provide Licensee's assessment of the effectiveness of re-moval of sulfur from steam generators.
Response
Licensee's assessment is stated at page 33 of TR-008.
Interrogatory 21 2.
'Has Licensee observed any harm to the plant, in any way, shape or form, as a result of the flushing of the plant?
If so, describe observations with specificity including dates and personnel involved.
Response
No.
Interrogatory 22 Relative to page 5 " Comment 4 and Recommendation 1,"
last para., provide the opinions of other experts, including the identity of these experts, known to Licensee, concerning the desirability or necessity for sulfur removal to be completed.
l
Response
A recommendation for removing sulfur from the RCS was l
provided by Dr. D. D. Macdonald.
GPUN Third Party Review l
l 1 l
~,. _ _ _ _. ~..
concluded that the peroxide cleaning was not essential for re-turn of the plant to power operation.
GPUN has also solicited the below listed reactor plant chemistry and corrosion experts to review the GPUN test program for the peroxide cleaning.
No attempt was made to identify individual opinions.
The concensus was that the cleaning should be performed.
Experts consulted:
Name Organization R.
F. Wilson GPUN G.
E. Von Nieda GPUN F.
S. Giacobbe GPUN A.
G.
Pard Rockwell International W. N. Stiegelmeyer Battelle Columbus Labs A. Wensky Battelle Columbus Labs P. Miller Battelle Columbus Labs J.
R. Sipp GPUN F. W. Pement Westinghouse R. G. Aspden Westinghouse K. H. Frederick GPUN A.
K. Agrawal Battelle Columbus Labs J. Hicks Babcock & Wilcox G.
J. Theus Babcock & Wilcox M. McKown Battelle Columbus Labs W.
E. Berry Battelle Columbus Labs D.-D. MacDonald (obeerver)
Ohio State /NRC Consultant W. R. Greenaway NUS W.
T.
Lindsay Westinghouse R&D B. Hindin Battelle Columbus Labs R. Barnes Battelle Columbus Labs C. E. McCracken (observer)
NRC Interrogatory 23 Provide the analysis of the cause of the anomalous data from the beaker test which would allow data to be set aside.
(Ref. page 6, first para.).. - -,
Response
The anomalous beaker test data which was referenced by the Third Party Review was sulfate data from beakers which had been exposed to the atmosphere.
It was subsequently deter-mined that alkaline peroxide mixtures are effective in trapping and concentrating small and variable amounts of sulfur com-pounds which are normally present in the atmosphere.
Since the increase in sulfate levels observed in certain series of beaker tests was subject to this intarference, the results were ren-dered suspect and subsequent test series were performed under Argon blankets to elimate interference.
Interrogatory 24 How does Licensee explain the uncertainty concerning per-centage of residual sulfur, estimated between 20 and 50% at page 6?
Response
The residual sulfur referred to was the removal efficiencies based upon tubes from beaker tests.
Variability and scatter of data are expected in tests of this nature.
Pos-sible explanations are (a) variation of sulfur levels in dif-ferent sections of any given tube, (b) variations in coating thickness and (c) normal statistical variation in analytical l
measurements.
Some combination of all of these explanations is likely.
!- l
.w._
Interrogatory 25 (a)
How will Licensee manage the " complicated pro-cess" of control of sulfur residues?
(b)
What Licensee personnel have been assigned to this function?
(c)
Provide identity and qualifications of these personnel.
(d)
Provide job assignment of these personnel if primary assignment is other than sulfur control and percent of job time estimated to be assigned to sulfur control.
Fasponse The TPR's mention of the " complicated process" (May 16, 1983 TPR Supplement, p.
- 6) refers to the peroxide cleaning process which has been completed with no loss of " control".
Interrogatory 26 What " upsets" in the chemical control of sulfur residue have been identified as possible and defined by the third party review committee, its members individually, or other experts?
Response
There was no " upsets" during the peroxide cleaning process.
Interrogatory 27A Provide the procedure which will address the sampling of the process control of peroxide flush based on the skeletal proposal of Table B-1, TR-010.
(See page 6, Further Comment 1, Report, May 16, 1983).
Response
The TPR comments refer to the peroxide cleaning --
process which has already been completed.
(See TPR May 16, 1983 Supp., p. 6.)
Interrogatory 27B Has Licensee evaluated the potential for chloride throw from the sulfate removal resin?
If so, proviG evaluations.
If not, why not? ~(See page 7, para. one).
Response
There was no chloride throw experienced during the sulfur removal process.
Interrogatory 28 Provide any documentation and/or information, verbal or written, that addresses the issue of agents other than sulfur as being the cause or a potential contributing factor towards corrosion in the steam generator tubes.
Response
See Responses to Interrogatories 9, 10, and 32.
Interrogatory 29 Provide any documentation and/or information, verbal or written, concerning the action of synergists in the chemical and/or metallurgical processes leading to IGA of nickel base austentic and/or other alloys.
Response
See Responses to Interrogatories 9, 10, and 32.
Interrogatory 30 Describe all studies conducted for or by Licensee to eval-uate the effect of the following parameters on intergranular crack initiation and/or growth:
4.
E (1)
Carbon content of alloy;
-(2)
Titanium content of alloy; (3)
Sulfur content of alloy; (4)
Water temperature; (5)
PH of water; (6)
Boron content of water; (7)
Radionuclide content of water; (8)
Sodium content of water; and (9)
Chlorine content of water.
Response
30(1).
Carbon and its relationship to sensitization of Inconel 600 has been thoroughly studied by the Nuclear In-dustry (Reference 9).
The degree of sensitization of the TMI-1 OTSG tubes has been evaluated by several investigations (Refer-ences 10,11).
30(2).
No studies have been specifically conducted for or by the Licensee.
However, the literature recognizes that titanium has an influence on the degree of sensitization (Reference 9).
30(3).
No studies have been specifically conducted for or by Licensee.
However, review of the literature indi-cates that the sulfur content of the alloy at the levels pres-ent in the TMI-1 tubes has not been shown to be detrimental in reactor coolant environments (Reference 9). _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
30(4).
The long term corrosion testing program sub-jects actual TMI tubing to the entire temperature spectrum ex-perienced by the reactor coolant system.
No evidence of cracking has been observed in this test program (References 6, 8).
30(5).
In addition to testing by other industry ina vestigators, GPtni had corrosion tests performed at various pH levels (Reference 1).
30(6).
The long term corrosion test program (Refer-ence-6) was well as the B&W corrosion tests (Reference 1) uti-lized variable boron concentrations within~the specified RCS chemistry limits.
No effect on cracking susceptibility was ob-served.
30(7).
None.
30(8).
The influer.ce of NaOH on stress corrosion cracking of Inconel 600 has been extensively studied in the in-dustry.
A review of_this data is included in Reference 4 (Ap-pendix II).
No evidence exists that sodium was a contributor to the IGSAC of the TMI-1 OTSG tubes.
30(9).
Chloride contamination was included in the long term corrosion test program to assure that worst case con-ditions within GPUN specified chemistry limits were evaluated (Reference 6).
Interrogatory 31 Describe all studies conducted by or for Licensee to eval-uate the interrelationships of the effects of the parameters listed in (18) on intergranular crack initiation and growth.
[
2 -.
Response
It is assumed that the parameters referred to above are as listed in question 30.
Except for the radionuclide content of the water, all parameters listed in question 30 as they apply specifically to
.13(I are addressed in the long term corrosion test program (Ref-erence 6).
Interrogatory 32 Provide all documents generated by or for Licensee or relied upon by Licensee ~in the studies (both laboratory and literature-based) described in response to questions (30) and (31).
Response
Documents referenced in Interrogatories 30 and 31 and major documents relied upon by Licensee are listed in Refer-ences 1, 3, 4, 5, 8-23, 25-35.
Interrogatory 33 Describe all cases of intergranular attack observed in plant piping and the tubes cf the steam generators prior to 1982.
Response
All intergranular attack of the steam generator tubes is described in References 10, 11, 12, and 13.
Interrogatory 34 For each case described in your answer to Question 33, provide.the following data: _ ____ ____.__
(a)
Description of morphological changes noted, including depth and circumferential arc of any cracks; (b)
Analysis of pipe or tube alloy; and (c)
Analysis of water.(estimated if measurements were not saade) which contacted these pipes and tubes over their lifetime prior to observed morphological changes.
Response
34(a).
The morphology, depth and circumferential arc of the cracks analyzed from the TMI OTSG tubes is described in the failure analysis reports prepared by Babcock & Wilcox (Ref-erences 11 and 12) and Battelle Columbus Laboratories (Refer-ences 10 and 13).
34(b).
See response to Interrogatory 1.
34(c).
Reactor coolant chemistry has been maintained in accordance with the operating license technical specifica-tions.
An analysis of the water chemistry records was per-formed for the cooldown in April 1979 and the identification of leakage in November 1981.
This analysis is contained in the GPUN failure analysis (Reference 3,Section IV).
Interrogatory 35 For each case described in your answer to Question 33, de-scribe the mechanism upon which Licensee relied to describe the cause of morphological change.
Response
See Response to Interrogatory 8. __
= _ _.
Interrogatory 36
' Provide all information concerning the repair process used in repair of the steam generator tubes.
Include all propri-etary informaticn, chemicals used and their intended function, the flushing process, and all other processes.
J I'-
Objection By requiring "all information concerning the repair pro-u cess", this interrogatory is overly broad, too vague, and far beyond the scope of Joint Invervenors' contentions.
Licensee objects to Interrogatory 36 on the grounds of vagueness, ambiguity, relevance, overbreadth, annoyance, harassment, unfair burden and expense, and on the ground that information relevant to Joint Intervenor's conten-tions is provided in response to other interrogatories.
Interrogatory 37 Provide all information concerning problems encountered with the repair process, including all verbal and written com-munications between any or all of the following:
Licensee per-sonnel, contractor personnel, Licensee experts / consultants, NRC Staff, Third Party Review Group or any of its members, NRC Staff experts / consultants, Babcock and Wilcox personnel or con-sultants.
Objection By requesting "all information concerning problems encoun-tered with the repair process", this interrogartory is overly t-broad, vague, and far beyond the scope of Joint Intervenors' contentions.
Licensee objects to t.
Interrogatory 37 on the grounds of vagueness, ambiguity, rele-vance, overbreadth, annoyance, harassment, unfair burden and i
- o expense, and on the ground that information relevant to Joint Intervenor's contentions is provided in response to other in-terrogatories.
Interrogatory 38 Describe, in full, Licensee's administrative program for the detection of breaks in the steam generator tubes.
Objection Licensee objects to Interrogatory 38 on the grounds of relevance.
The subject matter of this interrogatory--
Licensee's administrative program for the detection of breaks in the steam generator tubes--is unrelated to any of the Joint Intervenor's contentions.
This interrogatory, therefore, is beyond the scope of permissible discovery.
See 10 C.F.R. 5 2.740(b)(1).
Interrogatory 39 Describe any past relationship (s) between Licensee and any member of the Third Party Review Group.
Response
See SER, Attachment 6 (February 18 TPR Report), Appendix B, Attachment 2 (Resumes).
The resume of E. J. Wagner indicates that he served as a member of the TMI-2 Technical Assistance and Advisory Group.
Also, in his capacity ac Director of Engineering and Design at Burns and Roe, Mr. Wagner supervised individuals which were in-volved in engineering contracts with GPU.
The resume of W. H. ;
i
Layman shows that he was employed by the Pennsylvania Electric Company from 1961 to 1968.
Licensee is not aware of any other past business, consulting or contractual relationships with any member of the Third Party Review Group.
It should be noted, however, that members could have contributed to work contracted by Licensco with their past or present employers without Li-censee's knowledge.
Interrogatory 40 Did Licensee provide or promise any renumeration of any kind to any member of the Third Party Review Group?
Response
Licensee contracted with the employing organizations of A.
Kannins and E. J. Wagner for service time and expenses.
Meals were provided to members during working sessions at Licensee's facilities.
No other renumeration of any kind was provided or promised to members of the TPR or to their employing organiza-tions.
Interrogatory 41 Did Licensee participate in the NRC Staff's selection of the members of the Third Party Review Group?
Response
The NRC Staff did not select the membera of the Licensee's Third Party Review Group.._
o.
Interrogatory 42 The following questions pertain to NRC Inspection Report 50-289/83-26.
Concerning the release of Krypton gas on August 29, 1983, was the tracer gas being used to test the integrity of the steam generator tubes?
Interrogatory 43 Has Licensee determined whether any gas was released be-cause of a failure, or multiple failures, in the tube (s)?
Interrogatory 44 Describe the identified paths of leakage.
Interrogatory 45 At any time during the review of this event by Licensee canagement or plant personnel was it believed that there was any release of Krypton through the steam generator tube (s)?
(a)
If so, by whom?
Interrogatory 46 In Plant Incident Report (PIR) No. 1-83-14, there was un-certainty concerning the path of leakage which was resolved in a revision (Revision 1) to this report.
Explain the uncertain-ty, how it was resolved, and provide the identity of all the persons involved.
L Interrogatory 47 Were any inspections, repairs, or adjustments made to the steam generator tubes between 3:30 p.m. on August 29, 1983, and August 30, 1983?
If there were any such inspections, repairs, or adjustments, describe them.
Response to Interrogatories 42 through 47 Interrogatories 42-47 refer to an accidental release l i
I
of krypton gas on August 29, 1983, which was evaluated in NRC Inspection Report 50-289/83-26.
The krypton gas escaped through an open drain valve in the system intended to pipe the gas to the steam generator for testing.
The krypton released never reached the steam generator, and therefore was not re-leased through the steam generator tubes.
Interrogatory 48 Referring to ACRS Meeting of January 28,.1983, provide en-swers to the following questions:
Explain Licensee's identified inadequacy of present emer-gency action levels re condition of steam tubes as discussed at page 211.
Interrogatory 49 Explain how the emergency use of the condensate storage tank at TMI-2 in the event of steam tube rupture at TMI-1 (as discussed at page 199) is consistent with the separation of waste handling of Units 1 and 2.
Interrogatory 50 Describe staffing that Licensee has committed to moni-toring of leak rates from steam generator tubes (see page 214).
Interrogatory 51 Provide the procedures which administer the monitoring of leak rates from steam generator tubes (see page 214).
Interrogatory 52 Provide the ATOG procedures that have been modified or created to deal with the steam generator tube problem.
i Interrogatory 53 Provide documentation concerning proposed change of 20 degrees in subcooling temperature as discussed at page 222. '
Objection to Interrogatories 48 through 53 Licensee objects to Interrogatories 48 through 53 on the grounds of relevance.
The ACRS meeting of January 28, 1983 which in the subject matter of these interrogatories solely concerned Licensee's emergency procedures in the event of breaks in the steam generator tubes.
This subject matter is wholly unrelated to any of Joint Intervenor's contentions and is, therefore, beyond the scope of permissible discovery.
See 10 C.F.R. 5 2.740(b)(1).
Interrogatory 54 Provide GPU Nuclear presentations made at April 12 and 13, 1983 meetings with Third Party Review Group.
Response
GPU Nuclear's presentations at the April 12 meeting of the Third Party Review Group centered on written responses to the TPR's February 18, 1983 findings, supplied to the TPR in l
i Licensee's letter of April 7, 1983.
(Reference 24.)
All pre-sentations were. oral and transcripts were taken.
GPU Nuclear made no presentations at the April 13 meeting.
Dated: January 31, 1984.
~
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE sw [.
Mk' George F. Trowbridge, M.,
P.C.
Bruce W. Churchill, P.C.
Diane E. Burkley Wilbert Washington, II Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 _ _ _ _ _ _
J
o Master List of References 1.
J.V. Monter and G.J. Theus, "TMI-1 OTSG Corrosion Test Program-Final Report", B&W Report RDD:83:5433-01-01:01, May 9, 1983.
2.
J.V. Monter, "TMI-1 Eddy Current Specimens", B&W Report RDD:83:5214-01-01:01, May 3, 1983.
- 3.
.GPUN TDR-341, Rev. 1, " Failure Analysis Report".
4.
EPRI Memorandum Report "EPRI Activities in Support of TMI-1 Steam Generator Recovery," April 1982.
- 5.
A.K.-
Agrawal, W.N.
Stiegelmeyer and W.E. Berry, " Final Report on Short. Term Corrosion Evaluation of Kinetically Expanded Tubes in Mockup Tube Sheets", Battelle Columbus Laboratories, November 21, 1983.
- 6.
GPUN Specification S.P.
1101-22-008, Rev.
2, "Long Term
. Corrosion Testing".
7.
GPUN Specification SP-1101-28-001, Rev. 2, "Three Mile Is-land - Unit 1 Primary Water Chemistry," July 19, 1982.
- 8.
Westinghouse Electric Corporation, "Long-Term Corrosion Test Program of Nuclear Steam Generator Tubing Samples from Three Mile Island Unit 1",
First Interim Report, l
October 1983.-
9.
EPRI Report NP-2114-SR " Stress Corrosion Cracking of Alloy l
600", November 1981.
10.
A.K. Agrawal, W.N.
Stiegelmeyer, W.E.
Berry " Final Report on Failure Analysis of Inconel 600 Tubes from OTSG A and B of TMI-1", June 30, 1982.
11.
M. Rigdon and E. Pardue, B&W Lynchburg Research Center,
" Evaluation of Tube Samples from TMI-1", B&W Document No.
77-1135317, July 7, 1982.
12.
S.C.
Inman, Babcock & Wilcox, " Examination of OTSG Tubes from TMI-1 Third Pulling Sequence Final Report", Report No. RDD:83:5068-03:03, December 1982.
13.
W.N. Stiegelmeyer, A.K. Agrawal, W.E. Berry, Battelle Columbus Laboratories, " Final Report on Examination of Inconel 600 Tubes Removed in the Third Pulling Operation from OTSG's A and B of Three Mile Island-1", May 26, 1983.
-i-
e g
i 14.
EPRI Progress Report RP-311-1, " Corrosion and Corrosion Cracking of Materials for Water Cooled Reactors",
January-June 1977.
15.
J.C. Griess, J.H. DeVan, Oak Ridge National Laboratory,
'" Behavior of Inconel 600 in Sulfur Sulfur-Contaminated Boric Acid Solutions", Report No. ORNL/TM-8544, March, 1983.
16.
H.S.
- Isaacs, B. Vyas, and M.W. Kendig, Brookhaven National Laboratory, "The Stress Corrosion Cracking of Sensitized Stainless Steel by Sulfur Containing Compounds", Corrosion i
81.
17.
S. Ahmad, M.L. Mehta, S.K.
Saraf, and I.P.
- Saraswat,
" Stress Corrosion Cracking of Sensitized 304 Austenitic Stainless Steel in Petroleum Refinery Environment,"
Corrosion, Volume 38, No.
6, June 15'32.
18.
G.P. Airey, A.R. Vaia, N. Pessall, and R.G. Aspden, Westinghouse Electric Corp., " Detecting Grain-Boundary Chromium Depletion in Inconel 600", Journal of Metals, Volume 33, No. 11, November 1981, Pages 28-35.
19.
G. Cragnolino, L.F.
Lin, and Z.
Szklarska-Smialowska,
" Stress Corrosion Cracking of Sensitized Type 304 Stain-less Steel in Sulfate and Chloride Solutions at 250HC and 100HC, Corrosion, Volume 37, No.
6, June 1981.
20.
R.
Bandy and D. VanRooyen, Brookhaven National Laboratory, "Effect of Thermal Stabilization on the Low Temperature Stress Corrosion Cracking of Inconel 600", Corrosion 83.
21.
R.C. Newman, R. Roberge, and R. Bandy, Brookhaven National Laboratory, " Environmental Variables in a Low Temperature Stress Corrosion Cracking of Inconel 600,' manuscript sub-mitted to Corrosion Journal, July 1982.
22.
R.C. Newman, R. Roberge, and R. Bandy, Brookhaven National Laboratory, " Evaluation of SCC [ Stress Corrosion Cracking]
Test Methods for Inconel 600 in Low Temperature Aqueous Solutions", cymposium held at National Bureau of Stan-dards, Gaithersburg, Maryland, April 26-28, 1982.
23.
A.R. McIlree, H.T. Michels and P.E. Morris, " Effects of Variations of Carbon, Sulfur and Phosphorus on the Corro-sion Behavior of Alloy 600", Corrosion, December, 1975.
24.
Letter from GPUN to TPR re TPR Recommendations and Com-ments, dated April 7, 1983.
-ii-
,_,,,n-,
--,,~ a
a 7
~
" Evaluation of Steam. Generator Tube 85-127 from 25.
02 6.'
EPRI, " Examination of.Three Steam Generator Tubes From the Ginna Nuclear Power Plant",.EPRI Report No. NP-2534-LD, August 1982.
27.
EPRI,. " Examination of Tube Samples 21-46 and 28-45-from the Ginna Nuclear Plant for Intergranular Attack", EPRI Report NP-2877, February 1983.
'28.
EPRI, " Evaluation of Steam Generator Tubes R12C66 from Indian Point No.
3," EPRI Report NP-3029, 1983.
29.
EPRI, " Evaluation of Steam' Generator Tubes R7C45 and
~
R21C46 from the Ginna Nuclear Power Plant", EPRI Report No. NP-3070-LD, May 1983.
'30.
C.-R. Wolfe, E. P. Morgan, and M. J. Wooten, " Crevice Cor-rosion of Inconel~600", Proceedings of the Symposium on High Temperature Materials Chemistry, The Electrochemical Society, New Jersey,--1982.
31.
G.
J. Theus, " Caustic Stress Corrosion Cracking of Inconel-600,-Incoloy-800, and Type 304 Stainless Steel,"
Nuclear Technology, Vol. 28, September-1976.
32.
H. Domian, R. H. Emanuelson, L. Katz, L. W.
Sarver, and G.
J. Theis, "Effect of Microstructure on Stress Corrosion Cracking of Alloy 600 in High Purity Water", Corrosion, Vol. 33, January 1977.
33.
G. J. Theus, " Relationship Between Acid Intergranular Cor-rosion and Caustic Stress Corrosion Cracking of Alloy 600", Corrosion, Vol. 33,' January 1977.
34.
R. H. Emanuelson, D.
F. Levstek, K. E. Moore, and G.
J.
Theus, " Materials Model Boiler Tests for the Babcock &
Wilcox Once-Through. Steam-Generators", Nuclear Technology, Vol. 55,.1981.
i 35.
G.
J. Theus, " Stress Corrosion Cracking Tests of Alloy 600", EPRI WS-80-136 Proceedings, June 1981.
J
-iii-u.
. ~..
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
I have prepared or assisted in the preparation of the answers to Interrogatories 18, 19, 39 through 47, and 54.
Said answers are true and correct to the best of my knowledge and belief.
Gk+
GML F o
W Mary Gratiain Subscribed and sworn to me this l '~) I "
day of January, 1984.
[7Y fL f' u Notary Public v
My Commissicn Expires:
?.fy Commission Expirca August 14,1987
[ Seal]
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
I have prepared or assisted in the preparation of the answers to Interrogatories 1 through 17 and 20 through 35.
Said answers are true and correct to the best of my knowledge and belief.
7
, fl '.-
- Q. -
f.
/y' ~ "
-./
ET. Scott Giacobbe Sqscribed and sworn to me this d ') ' " day of January, 19 8 4.
"Y / f
'f ( -
No'tary Public
(/
My Commission Expires:
.'.1 Commission Expires August 7
14 1987 (Seal]
.., a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL.)
Docket No. 50-289-OLA
--)
ALSBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE This is to certify that copies of " Licensee's Responses to Joint Intervenors' First Set of Interrogatories" are being served to all those on the attached Service List by deposit in the United States mail, first class, postage prepaid, this 31st day of January, 1984.
O 1_ J$li Bruce W. Churchill, P.C.
g Dated:
January 31, 1984 l
l I
. * 'e*4 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
SERVICE LIST Sheldon J. Wolfe Atomic Safety and Licensing Administrative Judge Board Panel Chairman, Atomic Safety and U.S. Nuclear Regulatory Commissior.
Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Docketing and Service Section (3)
Washington, D.C.
20555 office of the Secretary U.S. Nuclear Regulatory Commissior' Dr. David L.
Hetrick Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Board Joanne Doroshow, Esq.
Professor of Nuclear Engineering Louise Bradford University of Arizona Three Mile Island Alert, Inc.
Tucson, Arizona 85271 315 Peffer Street Harrisburg, Pennsylvania 17102 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 Norman Aamod,t Richard J.
Rawson, Esq.
R.
D.
5, Bok 428 Mary E. Wagner, Esq.
Coatesville, Pennsylvania 19320 l
Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20$55
=
Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.
20555 l
l'
.. ~.. -.
J~
CDCKETED UPiRC UNITED STATES OF AMERICA
,84 FEB -2 Pl2 :39 NUCLEAR REGULATORY COMMISSION STIE E CT SELEfi/L BEFORE THE ATOMIC SAFETY AND LICENSING BOARDTJU3 a set"/; -
un; tiCH In the Matter of ASLBP 83-491-04-OLA METROPOLITAN EDISON COMPANY (NRC Docket No. 50-289)
(Three Mile Island Nuclear (Steam Generator Repair)
Station, Unit No. 1)
PROTECTIVE ORDER It is hereby ORDERED that for the duration of these pro-ceedings all parties signatory to the attached Protective Agreement will be bound thereby and subject thereto.
Upon final termination of the proceedings, Intervenors shall immedi-ately return to Licensee all data regarded as proprietary, including all extracts, summaries, transcriptions and copies thereof.
FOR THE ATOMIC SAFETY AND LICENSING BOARD Sheldon J. Wolfe, Chairman ADMINISTRATIVE JUDGE Dated this day of February, 1984.
't COLKETED UNITED STATES OF AMERICA NUCLEAR PJr.:GULATORY COMMISSION
'84 FEB -2 R2 :39 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
,m a dt.i u-s 000:'Eipj3 a SL ennNCH In the Matter of ASLBP 83-491-04-OLA METROPOLITAN EDISON COMPANY (NRC Docket No. 50-289)
(Three Mile Island Nuclear (Steam Generator Repair)
Station, Unit No. 1)
PROPRIETARY INFORMATION AGREEMENT In consideration of the disclosure by the Eabcock & Wilcox Company ("B&W") and GPU Nuclear Corporation (" Licensee") to Jane Lee and Norman Aamodt (" Recipients") of technical informa-tion which B&W or Licensee owns and considers to be proprietary or which B&W or Licensee is under an obligation to a third party to maintain proprietary and treats as secret or confiden-tial, to the extent Recipients are authorized to use such pro-prietary information as set forth below, Recipients accept and receive such information regarded as proprietary by B&W and Li-censee in confidence and trust, subject to the following terms and conditions:
1.
The proprietary information to be disclosed to Recipients under this Agreement is that which B&W or Licensee regard as proprietary and so designate. -.-
s 2.
Recipients shall employ all reasonable ef-fortJ to maintain proprietary information disclosed to them under this Agreement se-cret and confidential.
3.
Recipients shall not use the proprietary information for any purpose except as nec-essary for Recipients' participation in the above-captioned proceeding in connection with contentions involving repair of steam generator tubes at Three Mile Island Nucle-ar Station Unit 1 admitted therein.
The information regarded as proprietary by B&W or Licensee shall be subject to paragraphs 4 and 5 below.
4.
Recipients shall not transmit or further disclose proprietary information furnished hereunder to any other person, including parent organizations of Recipients, sister organizations of Recipients, subsidiaries l
of Recipients, consultants of Recipients, I
or subcontractors of Recipients, without first obtaining the prior written approval of B&W and Licensee, which approval will j
not be unreasonably withheld.
In the event B&W and Licensee approve of such disclosure
[
or transmittal by specific written consent, 1 l
Recipients shall first obtain the written commitment from said other person to abide by the terms of this Agreement and shall thereafter disclose or transmit such pro-prietary information to such other person only on a prcprietary and confidential basis.
5.
Recipients shall not make any copy or in any way reproduce, excerpt, transcribe or disclose the proprietary information to be held in confidence hereunder without the prior written consent of B&W.
6.
Recipients may not assign this Agreement.
7.
B&W and Licensee retain exclusive rights, title, and interest in and to the propri-etary information transmitted under this Agreement.
B&W shall retain exclusive con-trol over the proprietary information in accordance with the terms and conditions stated herein, and in no event shall the l
proprietary information be or become sub-ject to the free disposition of any other person or agency.
Notwithstanding any l
other provisions of law or of this Agree-i ment, Recipients shall return such propri-I etary information, including any and all i
\\.
f copies thereof, to B&W or Licensee upon the written request of B&W or Licensee.
8.
Nothing herein contained shall apply to any information:
a.
which is now generally known or avail-able on an unrestricted basis to the trade or public or which becomes so known or available on an unrestricted basis without the fault of Recipients; b.
which is already possessed by Recipi-ents in writing without restriction to disclosure or use prior to its receipt from B&W or Licensee; c.
which is disclosed in any issued pat-ent, publication, or other source from and after the time it cecomes general-ly available to the public; or d.
which is acquired on an unrestricted basis from any third party, provided that Recipients do not know or have reason to know and are not informed, subsequent to disclosure by such third party and prior to further unrestricted disclosure by Recipients, that such information was acquired under an obligation of confidentiality.
n -_.
J
9.
It is mutually understood that nothing herein shall be construed as granting or implying any right to Recipients under any Letters-Patent or to use any information covered thereby or as permitting Recipients to unfairly obtain the right to use infor-mation which becomes publicly known through an improper act or omission on their part.
10.
This Agreement shall enure to the full ben-efit of B&W and Licensee and shall be en-forceable by either.
Neither B&W nor Li-censee nor their suppliers or subcontractors of any tier shall be liable with respect to or resulting from the use (or the results of such use) or misuse of any information furnished hereunder.
11.
In the event that it becomes necessary to use, introduce, or present the proprietary information in evidentiary hearings in the above captioned proceeding, the Recipients will provide reasonable notice of their in-tent to the Licensee and B&W, and the signatories to this agreement shall seek a protective order from the ASLB which con-forms to the terms of this agreement and which requires that the proprietary.
l
4 information be heard in in camera hearing sessions.
AS WITNESS HEREOF, the parties hereto set forth their sig-natures to this Agreement.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 Counsel for Licensee Dated:
Jane Lee 183 Valley Road Etters, Pennsylvania 17319 Dated:
Norman Aamodt R.D.
5, Box 428 Coatesville, Pennsylvania 19320 Dated: