ML20080A419

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Followup Appeal Re Denial of FOIA Request for Documents Characterized as Proprietary or Commercial Trade Secrets Re Repairs to Steam Generator Tubes
ML20080A419
Person / Time
Site: Crane 
Issue date: 08/04/1983
From: Doroshow J
THREE MILE ISLAND ALERT
To: Reed C
NRC OFFICE OF ADMINISTRATION (ADM)
References
FOIA-83-243, FOIA-83-A-18 NUDOCS 8402060025
Download: ML20080A419 (1)


Text

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a THREE MILE ISLAND ALERT, INC.

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315 Peffor St Harrisburg. Naa.17102 (717)233 7897 August 4, 1983 Executive Director for Operations Attention:

Carol Ann Reed Division of Rules of Records FOIA Office U.S.

Nuclear Regulatory Commission Washington, D.C.

Dear Sir:

Re: Appeal from an Initial FOIA Decision FOIA-83-243 Docket No. 50-289

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This letter is to folllow-up on a telephone conversation concerning records which TMIA has located in the PDR concerning FOIA-83-243 which were not listed in Appendix A submitted in response to this reque.._

TMIA has appealed certain aspects of this response by letter dated July 30, 1983.

TMIA has included in its appeal a challenge to the denial of production of documents which have been characterized as " proprietary" I

or " commercial trade secrets" regarding the repairs of the steam generator tubes.

References to documents which have been withheld from public disclosure on this basis can be found in the public document room. (See below).

None of these documents were listed in Appendix A of the response.

We have also come to learn that a number of other documents which were properly the subject of FOIA-83-243 can be located in the PDR, but were not listed on Appendix A.

This raises the issue of ' inadequacy of search."

Thus, 'IMI A requests to amend its letter of appeal dated July 30, 1983 to include the additional issue of "inadequcy of search."

Those documents which TMIA has so far been able to identify in the PDR which have been withheld from public disclosure on the basis that they contain " proprietary information," are as follows:

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-- 8304130437, dated March 31, 1983 /~~'- "W>

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-- 8301250622, dated January 20, 1983f' A

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-- 8212150110, dated December 10,

-- 8210280230, dated December 25, 1983.

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Thank you for your prompt attention to this matter.

Sincerely, i

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Joanne Doroshow TMIA 9402060025 830804 f 2 DR FOIA DDROSH83-A-18 PDR

a TunEE MILE ISLAND ALERT, MC.

TMIm 315 Peffor St., Harrisbury. Penna.17102 (717)233 7897 July 30, 1983 S, ;", T. \\ ' V Executive Director for Operations U.S.

Nuclear Regulatory Commission l

Washington, D.C.

AP9 CAL OF INITIAL FotA DECISION

Dear Sir:

h'O ~ NN O EO I

Re: Appeal from an Initial FOIA Decision LC g / o2 - 8,3 1

FOIA-83-243 Docket No. 50-289 This letter is to appeal the withholding of certain documents requested in TMIA's May 7, 1983 request for documents under the Freedom of Information Act, which were denied by letter dated June 29, 1983 by J.M.

Felton and Harold R.

Denton.

TMIA received this letter on July 2, 1983.

TMIA first appeals the denial of documents 1 through 5 listed on Appendix B of said letter, under FOIA exemption 5.

The issue of steam generator tube repairs at mI-l is clearly a matter of immediate public concern, and in light of decisions now being made internally by the staff and Commission concerning whether significant safety hazard considerations are involved which would impact upon whether the public is granted a prior hearing in this case, it can not be legitimately asserted that production of these documents would be contrary to the public interest.

Futher, there is no legal basis to withhold these documents in their entirety.

Any # actual or other information which can be segregated must be disclosed, and we request that it be done immediately.

Second, TMIA appeals withholding of information which has been characterized as " proprietary" or " commercial trade secrets" regarding the repairs of the steam generator tubes.

Again, the issue of steam generator tube repairs at mI-l is a matter of tremendous and immediate public concern, and in light of decisions now being made internally by the staff and Commission concerning whether significant safety hazard considerations are involved which would impact upon whether the public is granted a prior hearing in this case, it can not be legitimately asserted that production of these documents would be contrary to the public interest.

Also, any factual or other information which can be segregated must be disclosed, and we request that it be done immediately.

Thank you for your prompt attention to this matter.

Sincerely, k

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Joanne Doroshow v d i A. d u u j ')

TMIA

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a TunEE MILE ISLAND ALERT, INC, 315 Peffor St Harrisburg. Penna.17102 (717) 233 ~,...

May 7, 1983 Mr. Joseph Felton FREEDOM OF INFORMATON Division of Rules and Records ACT REQUEST FOIA Office U.S.

Nuclear Regulatory Comission

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Washington, D.C.

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Dear Mr. Felton:

Pursuant to the Freedom of Information Act, 5 USC 59 (subpart A), Three Mile Island Alert, Inc. hereby requests copies of the following:

Any and all studies, memoranda, reports, letters or other documents, including but not limited to :

- internal memoranda between NRC staff

- SECY papers

- memoranda or briefing papers for the NRC Commissioners

- draft Congressional testimony

- minutes from meetings which discuss, evaluate, analyze or explain the causes or repair of steam generator problems at TMI 1.

Additionally, this request is intended to cover the aforementioned I

documents written by, sent to, or routed through any of the following offices and divisions:

- NRC Commissioners and Commissioners' staffs i

- ACRS members, staff, and fellows

- NRR

- OR branch

- AEOD

- EDO

- OPE i

- OGC

- Nuclear Regulatory Research

- OIE

- OIA

- OI Only documents not supplied in response to TMIA'a FOIA request of November 3, 1982, FOIA-82-552, are being requested.

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Docket No. 50-289 l

Ms. Joanne Doroshow Three Mile Island Alert, Inc.

315 Peffer Street IN RESPONSE REFER Harrisburg, PA 17102 TO F01A-83-243

Dear Ms. Dornshow:

This is;in partial response to your letter dated May.7,1983, in which l

you requested, pursuant to the Freedom of Information Act, copies of any and all documents which ~ discuss, evaluate, analyze or explain the causes or repair of steam generator problems at TMI-1.

You requested only documents not supplied in' response to TMIA's F0IA request of November 3, 1982, F01 A-82-552.

In partial response to your request, we are providing you with copies of the documents listed on Appendix A.

Please note that in addition to the documents listed on Appendix A, numerous other documents pertinent to the subject of steam generator repairs at TMI-l have been placed in the NRC's Local Public Document Room (LPDR) for the TMI-l facility located a t the State Library of Pennsylvania, Forum Building, Cormionwealth &

Walnut, Harrisburg, PA 17109.

Mr. John Geschwindt, Head, Government Publications Section, is in charge of the LPDR collection. These documents are available for public inspection and copying.

l Documents 1 through 5 listed on Appendix B are preliminary documents l

containing advice, opinions, and recommendations of the staff which have been provided for preparation of a Safety Evaluation Report (SER) on the Steam Generator Repairs at TMI-1.

The SER is currently being prepared.

These Appendix B documents are predecisional documents exempt from mandatory disclosure and are being withheld in their entirety pursuant to Exemption 5 of the Freedom of Information Act (5 U.S.C. 552(b)(5))

and 10 CFR 9.5(a)(5) of the Commission's regulations.

Pursuant to 10 CFR 9.9 cf the commission's regulations, it has been determined that the information withheld is exempt from production or l

disclosure, and that its production or disclosure is contrary to the public interest. The pt.r;ons responsible for this denial are the undersigned and Mr. Harold R. Denton, Director, Office of Nuclear Reactor Regulation.

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.Ms. Joanne Doroshow s l

This denial may be appealed to the Commission's Executive Director for Operations within 30 days from the receipt of this letter. As provided in 10 CFR 9.11, any such appeal must be in writing, addressed to the Executive Director for Operations, U.S. Nuclear Regulatory Commission.

Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial FOIf. Decision".

A few additional documents are under review and we will communicate with you agiin concerning their dispositio.

. M. Felton, Director Division of Rules and Records Office of Administration

Enclosures:

As stated O

.c The requested documents will be used for public education purposes, and will therefore be used in the general public interest.

Therefore, we request a complete waiver of all costs you might incur in processing this information or in providing us access to it under provisions at 10 CFR 59, 14a and the Freedom of 'Information Act.

Notning in this request should be interpreted as a request for the private

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records of a specific individual.

Hence no provisions of the Privacy Act should be deemed applicable.

If all or any part of this request is denied, please cite the specific exemption (s) which you think justifies your refusal to release the information and inform us of the appeal procedures available to us under law.

E We will expect to hear from you within ten days.

1 Thank you for your attention to this matter,

inceroly, Joanne Doroshow i

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Re:

F01A-83-243 I

APPENDIX A 1.

6/18/82 Memo to D. G. Eisenhut (NRC) from J. F. Stolz (NRC)

Subject:

THI-l Steam Generator Repair Independent Third Party Review.

(1 page)

  • 2.

6/18/82 Memo to V. Benaroya (NRC) from C. McCrackin (NRC)

Subject:

Status Update for TMI No.1 S. G. Corrosion / Repair.

(3pages) l Accession No. 8206290475 3.

7/23/82 Memo te various NRC addressees from R. Jacobs (NRC)

Subject:

Daily Highlight re: IM1-1 Steam Generator Repair Technique.

(1 page) 4.

9/15/82 Memo for NRC Commissioners from J. E. Zerbe,

Subject:

Follow-up to September 10, 1982 Commission Meeting on TMI-l Restart.

(1 page) 5.

10/28/82 Trip Report to TMI-1 by FRC Personnel:

L. Leonard and C. Davey.

(2 pages) 6.

10/29/82 Memo to various NRC addressees from R. Jacobs (NRC)

Subject:

Daily Highlight re: TMI-l 0TSG Repair Status.

(1 page) 7.

11/18/82 Informal Technical Communications to J. Rajan/R. Jacobs (NRC) from F. Shook (Franklin Research Center), re: Trip Report / Meeting at NRC concerning presentation of TMI-l OTSG reoair process updste and retunn to service overview.

(3pages)

  • 8.

11/18/82 Memo to V. Benarova (NRC) from C. McCrackin (NRC)

Subject:

TnI-l OTSG Status Update with copies of consultants; C. Dodd a'id D. MacDonald, trip reports from 10/18-19/82 meetinq in Bethesda.

(62 pages) Accession No. 8211300009 (only 3 pages) 9.

1/14/83 Memo to P. Shewmon & D. Moeller from R. Major,

Subject:

Tentative Schedule for the Jcnuary 28, 1983 Combined Meeting of ACRS Subcommittees On Metal Components /Three Mile Island Nuclear Station, Unit 1.

(4 pages) 10.

1/14/83 Memo to P. Shewmon & D. Moeller from R. Major

Subject:

Status Report for the January 28, 1983 Combined Meetino of ACRS Subcomittees On Metal Components /Three Mile Island, Unit 1, Washinoton, D.C.

(7 pages)

  • 11.

1/28/83 Memo to J. Stolz (NRC) from V. Benaroya (NRC)

Subject:

Evaluation of TMI-1 Plant Safety Subsequent to Recovery from OTSG Corrosion Problems.

(12 pages) Accession No. 8302090037 (only 5 pages)

12. 2/18/83 Memo to D. G. Eisenhut (NRC) from J. A. VanVliet (NRC)

Subject:

TMI-l Steam Generator Repair License Amendment Request.

(5 pages)

  • This document can be located in the NRC Public Document Room by the identified Accession number.

Re:

F01A-83-243 APPENDIX A-13.

4/5/83 NRC Presentation by GPU Nuclear, "TMI-l OTSG Repair and Return to Service" with list of attendees.

(51 paaes) 14 4/21/83

' Memo to various NRC addressees from J. Stolz (NRC)

Subject:

Daily Highlight re: License amendment on the TMI-l Steam Generators.

(1 page)

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e Re: FOIA-83-243 l

APPENDIX B (WITHHELD DOCUMENTS PURSUANT TO FOIA EXEMPTION 5) 1.

9/2/82 Memo to G. C. Lainas (NRC) from R. W. Houston (NRC)

Subject:

Safety Evaluation Report Input for the Proposed Steam Generator Repair Work at TMI-1.

(4pages)AccessionNo. 8210050458 2.

9/29/82 Memo to G. C. Lainas (NRC) from W. V. Johnston (NRC)

Subject:

Safety Evaluation for Repair of TMI-l Steam Generators.

(12 pages)

Accession No. 8210150661 3.

10/7/82 Memo to G. C. Lainas (NRC) from R. W. Houston (NRC)

Subject:

Environmental Impact Appraisal Input for Three Mile Island Unit 1 Once-Through Steam Generator Tube Repair Project.

(17 pages)

Accession No. 8211010514 4.

4/25/83 Memo to G. C. Lainas (NRC) from R. W. Houston (NRC)

Subject:

Three Mile Island Unit 1 Steam Generator P,epair SER.

(7 pages) l Accession No. 8305050291 l

5.

5/10/83 Memo to G. C. Lainas (NRC) from D. R. Muller (NRC)

Subject:

Safety Evaluation Report Input for Return to Service of TMI-l Steam Generators.

(5 pages) Accession No. 8305200689 1

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o UNITED STATES b

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E WASHINGTON, D. C. 20555 OCT 2 7183 Docket No. 50-289 Ms. Joanne Doroshow Three Mile Island Alert, Inc.

IN RESPONSE REFER 315 Peffer Street TO F0IA-83-A-18 Harrisburg, PA 17102 (F01A-83-243)

Dear Ms. Doroshow:

This is a further response to your letters dated July 30 and August 4, 1983, appealing Mr. J. M. Felton's letter of June 29, 1983 which denicd-in-part your Freedom of Information Act (F0IA) request for documents which discuss, evaluate, analyze, or explain the causes or repair of steam generator problems at TMI-1. You specifically appealed the withholding of five documents identified in Mr. Felton's June 29, 1983 letter; the withholding of documents characterized as proprietary for which only transmittal letters can be located in the Local Public Document Room (LPDR) and which werc not specifically identified or denied under the Freedom of Information Act; and the fact that all documents subject to your request were not identified although certain documents could be located in the LPDR.

The first and third part of your appeal was handled in my letter to you dated October 3, 1983.

In that letter, I stated that approximately 60 documents were being located and reviewed to determine if they were subject to your request and whether or not they could be released. The search and review process has now been completed and we have determined that 52 documents are subject to your request. The 45 documents listed on Appendix A to this letter are enclosed.

Portions of the 7 documents listed on Appendix B are being withheld from public disclosure pursuant to exemption (4) of the Freedom of Information Act (5 U.S.C. 552(b)(4)) and 10 CFR 9.5(a)(4) of the Commission's regulations.

The nonexempt portions are enclosed.

Babcock ano Wilcox considers the withheld information to be company confidential (proprietary) information the release of which would cause substantial harm to their competitive position.

Babcock and Wilcox has submitted affidavits to substantiate this position.

The 7 documents and the affidavits have been reviewed by the NRC staff and it has been determined that the denied portions of these documents clearly fall within exemption (4) of the F0IA.

e402060028 831027 PDR FOIA DDROSHB3-A-18 PDR

Ms. Joanne Doroshow Since I have made the above determinations, this letter represents the final agency action on your F0IA request. Judicial review of this decision is available in a district court of the United States in either the district in which you reside, have your principal place of business or in the District of Columbia.

Sincerely,

(

W liam'U. Dircks Executive Director for Operations

Enclosures:

As stated t

Re:

F0!A-83-A-18 APPENDIX A 1.

12/29/82 POLICY ISSUE - STATUS OF CERTAIN NON-HEARING ISSUES ON TMI-l - SECY-82-502 (3 pages) 2.

8/6/82 Letter to D. D. Macdonald, Ph.D from V. Benaroya re: SULFUR REMOVAL FROM REACTOR COOLANT SYSTEM SURFACES AT THI-l (2 pages) 3.

7/6/82 Letter to Conrad McCracken from M. J. Graham re: OTSGs (1 page) 4.

3/24/83 Letter to B. Turovlin from C. Auerbach re: DRAFT TECHNICAL EVALUATION REPORT w/er. closure (16 pages) 5.

8/30/82 Letter to V. Benaroya from D. D. Macdonald re: REVIEW 0F B&W DOCUMENT NO.,,.135.517, " EVALUATION OF TUBE SAMPLES FROM THI-1" (4 pages) 6.

10/5/82 Letter to J. Lee from H. R. Denton re: CORROSION PROBLEMS IN THE THI-1 STEAM GENERATORS (3 pages) 7.

8/3/82 Memo for H. McVeagh from V. Benaroya re: PRINTING COSTS FOR TMI-l STEAM GENERATOP TUBES DESTRUCTIVE EXAMINATION REPORT (1 page) 8.

9/10/82 Memo for V. Benaroya from C. McCracken re: STATUS UPDATE FOR TMI-l STEAM GENERATOR REPAIRS W/ Attachments (11 pages) 9.

9/17/82 Memo for D. Eisenhut frun R. Vollmer re: REPAIR OF TMI-l

~

STEAM GENERATOR TUBES (1 page) 10.

10/26/82 Memo for R. H. Vollmer from P. Wu re: EXTENSION OF PNL TECHNICAL ASSISTANCE TO THE DIVISION OF ENGINEERING

" EVALUATION OF TMI-l STEAM GENERATOR CORROSION" (1 page) 11.

10/27/82 Memo for V. Benaroya from C. McCracken re: THI-l S.G.

CORR 0SION/ REPAIR EXAMINATION OF REMOVED TUBES (1 page) 12.

5/20/82 Memo to J. E. Matheson from W. A. McInteer et. al. re:

TMI-l RECOVERY - RNS RETAINER EXAMINATION (22 pages) 13.

6/30/82 FINAL REPORT ON FAILURE ANALYSIS OF INCONEL 600 TUBES FROM OTSG A AND B 0F THREE MILE TSLAND UNIT-1 by A. K. Agrawal, et. al. (136 pages) 14.

11/18/82 Note to V. Benaroya from C. McCracken re: TMI-l OTSG STATUS UPDATE w/ enclosure (63 pages) 15.

1/24/83 Memo for D. G. Eisenhut from R. H. Vollmer re: SIGNIFICANT HAZARDS DETERMINATION PERTAINING TO RESTART OF TMI-l SUBSEQUENT TO OTSG REPAIRS w/ enclosure (13 pages)

Re:

F01A-83-A-18 APPENDIX A 16.

1/25/83 Memo for D. Vassallo from F. J. Congel re: QUESTIONS PERTAINING TO RETURN TO SERVICE OF 3MI-l STEAM GENERATORS w/ attachment (3 pages) 17.

3/8/83 Memo for L. Frank et. al. from C. McCracken re: PREPARATION OF TMI-l SER FOR RESTART SUBSEQUENT TO THE OTSG REPAIRS w/ attachments (25 pages) 18.

3/25/83 Memo for R. H. Vollmer from P. Wu re: EXTENSION OF PNL TECHNICAL ASSISTANCE TO THE DIVISION OF ENGINEERING " EVALUATION OF THREE MILE ISLAND U.ilT NO. 1 STEAM GENERATOR CORROSION" w/ attached memo (2 pages) 19, 4/4/83 Memo for D. Eisenhut from R. Vollmer re: SCHEDULE FOR SER SUBMITTAL ON TMI-l STEAM GENERATOR (2 pages)

20. 4/20/83 Memo for V. Benaroya from B. D. Liaw re: TMI-l - SER FOR RESTART SUBSEQUENT TO ONCE-THROUGH-STEAM GENERATOR REPAIRS w/ attachment (7 pages)
21. 4/21/83 Note to L. Frank et. al. from C. McCracken re: SCHEDULE FOR TMI-l RESTART SER (1 page) 22.

5/19/83 Memo for D. G. Eisenhut from H. L. Thompson, Jr., re: TMI-l STEAM GENERATOR REPAIR REVIEW STATUS (1 page) 23.

5/23/83 Memo for G. Lainas from W. V. Johnstcn re: SAFETY EVALUATION OF POST ACCIDENT SAMPLING SYSTEM 0F THREE MILE ISLAND UNIT N0. I w/ enclosure (11 pages) 24.

5/23/83 Memo for D. G. Eisenhut from R. H. Vollmer re: TMI-l STEAM GENERATOR REPAIR SAFETY EVALUATION (1 page) 25.

5/24/83 Memo for G. C. Lainas from W. V. Johnsten re: SAFETY EVALUATION l

OF THREE MILE ISLAND UNIT N0. 1 FOR RETURN TO SERVICE AFTER REPAIR l

OF OTSG CORROSION w/ enclosure (61 pages) l

26. 8/17/82 Memo for V. Benaroya from C. McCracken re: STATUS UPDATE FOR TMI-l S.G. REPAIRS (3 pages)
27. 4/21/83 Memo for W. V. Johnston from V. Benaroya re: TMI-l THIRD PARTY REVIEW MEETING

SUMMARY

(2 pages)

28. 6/14/82 Letter to S. Pandy from S. S. Bajwa re: TENTATIVE WORK ASSIGNMENT "J" w/ enclosure (4 pages)
23. 6/17/82 Letter to S. S. Bajwa from S. Pandey re: PROPOSED PROGRAM, SCHEDULE, AND LEVEL OF TECHNICAL EFFORT REQUIRED FOR ACCOMPLISHING TENTATIVE WORK ASSIGNMENT "J",

EVALUATION OF TP.I-1, STEAM GENERATOR TUBE SEALING PROGRAM (5 pages) 5

Re:

FOI A-83-A-18 APPENDIX A 30.

5/9/83 Memo for J. F. Stolz from H. Brent Clayton re: TMI-l l

STEAM GENERATOR TUBE RUPTURE GUIDELINES AND PROCEDURE REVIEW (1 page) 31.

6/28/82 Memo for R. Bosnak from J. Rajan re: TMI-1 STEAM GENERATOR TUBE TUBESHEET REPAIP. - MEETING

SUMMARY

w/ attachments (7 pages) 32.

7/27/82 Handwritten Letter to H. Denton from J. H. White, III, re:

INFORMATION SENT TO MR. LEWIS (1 page) l 33.

5/7/82 Letter to H. Denton from M. I. Lewis re: TMI-l REACTOR TEST PROGRAM (3 pages) 34.

10/25/82 Handwritten Letter to D. G. Eisenhut from A. Rosenberg re:

LETTER TO M. LEWIS w/ enclosure (2 pages) 35.

4/1/83 Letter to H. Denton from J. Lee re: LETTER TO COMMISSIONER GILINSKY (1 page) 36, 3/31/83 Letter to V. Gilinsky from J. Lee re: PUBLIC FORUM ON NUCLEAR POWER (2 pages) l 37.

4/24/83 Letter to J. E. Stolz from D. E. Hossler re: REGULATORY CONNECTION TO THI-l w/ enclosures (8 pages) 38.

5/16/83 Letter to H. Denton from D. E. Hossler re: LETTER SENT TO JOHN STOLZ (1 page) 39.

7/9/82 Memo for D. Eisenhut from R. Jacobs re: TMI-l STEAM GENERATOR REPAIR PROGRAM (1 page) 40.

3/25/83 Memo for R. Vollmer from D. Eisenbut re: SCHEDULE FOR SER SUBMITTAL ON TMI-l STEAM GENERATOR (1 page) 41.

4/11/83 Memo for B. H. Clayton from J. F. Stolz re: REQUEST FOR TMI-l STEAM GENERATOR TUBE RUPTURE PROCEDURES AND GUIDELINES REVIEW w/ enclosure (12 pages) 42.

5/17/83 Memo for R. Vollmer et. al. from D. Eisenhut re: TMI-l STEAM GENERATOR REPAIR REVIEW STATUS (2 pages) 43.

5/9/83 REQUEST FOR TECHNICAL SPECIFICATION CHANGE TO PERMIT STEAM GENERATOR REPAIRS w/ attachment (15 pages) 44.

12/29/82 Memo for The Connissioners from W. J. Dircks re: STATUS OF CERTAIN NON-HEARING ISSUES ON TNI-l (3 pages)

Re: F01A-83-A-18 APPENDIX A

45. 12/20/82 Memo for D. MacDonald et. al from C. McCracken re:

REVIEW 0F GPUNC TOPICAL REPORT 008 (RETURN TO SERVICE AFTER STEAM GENERATOR REPAIR) (2 pages)

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Re:

FOIA-83-A-18 APPENDIX B 1.

1/20/83 Letter to J. F. Stolz from H. D. Hukill re: OTSG REPAIR KINETIC EXPANSION TECHNICAL REPORT w/ attachment - Three-Mile Island Unit i ONCE-THROUGH STEAM GENERATOR REPAIR-Kinetic Expansion Technical Report by J. P. Moore, et. al.

(GPUN-TDR-007 - BAW-1760) (104 pages) 2.

3/31/83 Letter to J. F. Stolz from H. D. Hukill re: STEAM GENERATOR REPAIR w/ attachments 1) Topical Report 008, Rev. 2 and

2) Affidavit --Transmitting: 3/29/83 ASSESSMENT OF TMI-l PLANT SAFETY FOR RETURN TO SERVICE AFTER STEAM GENERATOR REPAIR TOPICAL REPORT 008, Rev. 2 by T. M.'Moran - Project No. 500 51712 (166 pages) 3.

8/20/82 Letter to D. G. Eisenhut from H. D. Hukill re: OTSG TUBE REPAIR PROGRAM w/ enclosures 1) Affidavit and 2) TMI-l Once Through Steam Generator Repair Safety Analysis - Transmitting:

8/20/82 TMI-l ONCE TRHOUGH STEAM GENERATOR REPAIR SAFETY ANALYSIS - ATTACHMENT TO 5211-82-200 (42 pages) 1 4.

10/5/82 Letter to D. G. Eisenhut from H. D. Hukill re: 0TSG TUBE

?.EFAIR w/ enclosures.TMI-l Steam Generator Repair Safety Evaluation, Rev. 1 - Project No. 5000 51712 by M. J. Graham, et. al. dated 9/30/82 (39 pages) 5.

12/10/82 Letter to D. G. Eisenhut from P. R. Clark re: TMI-1 OTSGs -

Transmitting: 12/7/82 Assessment ot TMI-1 Plant Safety for Return to Service After Steam Generator Repair Topical Report 008, Rev. 1 - Project No. 5000 51712 by T. M. Moran (114 pages) 6.

4/20/83 Letter to J. F. Stolz from H. D. Hukill re: TMI-l Steam Generator Repair ~ Report w/ enclosures - Transmitting: Three-Mile Island Unit 1 Once-Through Steam Generator Repair -

Kinetic Expansion Technical Report (122 pages) 7.

10/25/82 Letter to J. F. Stolz from H. D. Hukill re: THI-l GTSG Repair Drawings v/ enclosures (10 pages) 1 s

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U December 29. 1982

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SECY-82-502 POLICY ISSUE

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For:

The Commissioners From:

William J. Dircks Exe'cutive Director for Operations Su bj ec_t,:

Status of Certain Non-Hearing Issues on TMI-l Purcose:

To inform the Commission of the status of staff review for TMI-l on the auxiliary feedwater. header problen and the make-up nozzle cracking problem that occurred on several B&W plants; and the steam generator tube problem on TMI-1 as directed by the Commission in its Order dated July 16, 1982 (CLI-82-12).

Background:

By Order dated June 30, 1982, the Atomic Safety and Licensing Appeal Board for the TMI-l restart proceeding requested authorization from the Commission to hear three issues sua sponte.

Those issues relate to:

(1) the pos-sible distorting of the auxiliary feedwater header, (2) whether there has been any cracking in high pressure injection or make-up system nozzles or thermai sleeves and (3) the repair of the corroded steam generator tubes.

By Order dated July 16, 1932 (CLI-82-12), the Commission denied the Appeal Board's request but directed the staff to thoroughly examine these i; sues and provide its analyses and fin:'ings to the Commission prior to the time the Commis-sion is to make its decision on the restart of TMI-1. The follcwing is the current status of the three issues.

The requested staff findings with respect to the first two issues are reported below.

The staff review and findings regarding repair of steam generator tubes will be c:mpleted after hot functional testing, now scheduled for late April 1983.

Contact:

R. Jacobs, NRR X27a71

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Discussion: The auxiliary feedwater header problem identified by the Appeal Board refers to distortion of the internal auxiliary feedwater header experienced at Davis-Besse, Oconee 3 and Rancho Seco. The internal header, which is installed in Davis-Besse, Rancho Seco, Oconee 3, Midland 1 and 2 and TMI-2, is rectangular and encircles the tubs bundle. The rest of the B&W plants including TMI-1 use an external feedring with seven nozzles penetrating the steam generator snell and shroud.

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Hence, this problem is not applicable to TMI-1. The corrective action completed at the affected B&W plants involved stabilizing the internal header and installing an external feedring similar to that used at TMI-1.

The make-up nozzle problem in B&W plants refers to cracking that occurred in the makeup nozzles to the reactor coolant system cold legs of four of the B&W plants. The Commission was informed of the status of this problem in SECY-82-186 dated May 7, 1982 and SECY-82-186A dated July 23,1982. The problem appeared to be related to the condition of the nozzle thermal sleeve.

In each instance where nozzle cracks were detected, the associated thermal sleeve had been loose or in the case of Rancho Seco, the sleeve was missing.

All four HPI nozzles were inspected at TMI-l and no degradation was detected. Additionally, it was confirmed that the themal sleeves were in place.

Hence, no additional short term action is considered necessary for TMI-l prior to restart. A G&W Owners Group task force is pursuing whether any additional generic action is necessary for the B&W plants.

The task force final report is due to be completed in January 1983.

It is expected to recommend augmented in-service inspection in B&W plants to provide long term assurance against further degradation.

The staff agrees with this recommendation and will be reviewing each licensee's submittal when received.

With respect to the steam generator problem, the staff's

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review is continuing.

On October 13, 1982, the staff issued a safety evaluation supporting our finding that GPU may proceed with repairs of the steam generators, but that NRC approval was necessary before any subsequent operation.

GPU is approximately midway through the kinetic expansion program with cleanup of' debris, plugging of approximately 800 tubes (354. tubes previously plugged) and steam generator testing required to complete the repairs.

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i GPU plans to mill off the top end of the tubes where they l

protrude through the upper tubesheet since a number of these tube ends have been breaking off from the expansions due to defects in the heat affected zone of the seal weld.

GPU anticipates completing the above repairs and cold testing by mid March 1983.

Following the repairs, GPU may conduct desulfurization of the reactor coolant system, if determined to be necessary, to be followed by hot functional testing which GPU has targeted for completion by late April 1983.

Or. December 10, 1982, GPU submitted their safety evaluation concluding that TMI-1 can be safely returned to service once the repairs and associated activities have been completed satisfactorily.

The staff position as stated in SECY-82-35A

'~ dated July 19, 1982 is that unreviewed safety questions are.

involved and a license amendment is needed to-modify the Technical Specifications before the steam generators can be declared "ooerable". The staff intends to complete its review and issue its final safety evaluation after completion of steam generator hot testing.

Sg kAh Willtam J.. Dircks Executive Director for Operations 9

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