ML20081A507

Restatement of Proposed Contentions 1,2 & 3 Re Physical & Chemical Processes Employed to Return Tubes to Design Basis. Certificate of Svc Encl

ML20081A507
Person / Time
Site:	Three Mile Island
Issue date:	10/22/1983
From:	Aamodt N AAMODTS
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8310260294
Download: ML20081A507 (4)

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AAM-10/22/ 8 3

,3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CXEric L"i'!R C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of . ) CFF:CEnr :-- .

) 00CKE7Ts373gg.

METROPOLITAN EDISON COMPANY Docket No. b b SP

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(Three Mile Nuclear Generating

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Station, Unit 1)

RESTATEMENT CF CONTENTIONS OF LEE et al.

I At the first prehearing ccnference October 17, 1983 the Board instructed Licensee and ourselves to attampt to reach agreertent upon a restatement of'our contentions 1 and 2. Licensee, as in " Licensee's l

Response to Proposed Contentions of Joint Petitioners Lee et al.",.-dated l C T October 6, 1983, interpreted the " tube repairs" of Proposed Contention 1 i

to apply only to the integrity of the joints whereas we intended this

. term to mean all of the physical and chemical processes employed to

! return the tuoes to design basis. In addition, in defining Contention 2

1. in terms cif subcontentions derived from Discussion 1 and 2 of our i

contentions as amended on September 21, 1983, Licensee mischaracterized the elements of Discussion 1 and 2. We agreed that restatement of Contentions 1 and 2 as a single contention with subcententions along the lines suggested by Licensee had merit. We expected that such a

! restatement would enhance litigability of the issues. We also noted

( that one of the subcontentions could obviate the need fer Contention 3.

l We discussed these matters with counsel for-Licensee this past I

week. We could not reach agreement with regard to restatement of the l

contentions. Nevertheless, we feel that our suggested restatement of Proposed Contentions 1 and 2 has merit and present it as follows 8310260294 831022 PDR ADOCK 05000289 o eda

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in lieu of Proposed Contentions 1, 2 and 3:

Contention 1 (replacing Proppsed Contentions 1, 2 and 3) ,

There is no assurance that the steam generator tube repair. program can assure the integrity of the tubes and their joints under the environmental conditions attendant to operation. TMI-l shall not be permitted to restart before such assurance is provided. The

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following elements of the repair program are deficient:

(1) The efficacy of lithium addition is not adeq'2ately est.?blished to warrant reliance on this method to prevent sulfur induced intergranular stress corrosion cracking (IGSCC).

- Attachment 4 to SER Fg. 6(IV) "...The mechanism by which this occurs is not fully understood, nor is the pher.onenon firmly established."

(2) Active forms of sulfur can be generated from presumably

. benign sulfur rehaining on the tubes after cleaning.

- Attachement 3 to SER, Pg. 6, 3rd Para "If it has not been shown that SCC does occur in low I

temperature soluticns, neither has it been shown that it does not."

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- Third Party Review, May 16, 1983, Pg. 5, last sentence 2nd para. " ...There was (and is) no quantitative measure of the potential for reactivation."

f (3) Morphological changes in the ir.ner tube surface, l remote from the expanded joints, could reasonably

! be presumed to be precursers of IGSCC.

- Pg. 81 of GPUN Topical Report 008 "Most extensive IGA is in the vicinity of majcr cracks."

,' 1/ Brief bases are also given, derived soley from our arguments of Octcber 17, with appropriate document citatiuns.

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(4a) The effect of dynamic stress on less than 40%

t 4 thru wall cracks has only been demonstrated empirically with no experimental verification.

- Attachment 3 to SER Pg. 7, last sentence

... Fracture mechanics calculation of recidual tube properties in circumferentially cracked ,

tubes are presently unsupported by experimental' datc."

(4b) E. O. testing, thuugh highly reproducible, cannot be relied upon to accurately assess depth of t

penetration.

.]

} - SER, pg. 13. last para. " E. C. measurements

.. (indicated) greater than 40% thru wall ...

all exceeded 50% with the majority 100% thru wall."

(4c) The effect of creep has not been evaluated in the expanded joint laboratory qualification tests.

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(5) The possible effects of potential stress cracking agents other than active forms of sulfur have not f

j been studied in relation to the initiation of IGSCC.

- Synergistic effects have not been considered.

- Third Party Review, February 18, 1983, pg. 9 y Recommendation i "Carbcnates in the presence of

) ex:dants at hi;h temperature can prcduce 00A ar.d ICSCO of INCONEL 600. Other contaminants (lead, mercury, phosphorus) can also induce IGSCC."

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- Third Party Review, May 16, 1953, pg. 3 "Further Comments" "

... carbonaceous material was found to be the major impurity near tube failure, and may have l l' played a role in the failure which, in our ignorance, we do not understand."

Bespectfully su mitted, 6

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October 22, 1983

. . Norman O. Aamodt'for Lee et al.

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UNITFD STATES OF RMERICA

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NUCLEAR REGULATORY COMMISSION 00; ~ ~.

DEFCRE THE ATOMIC CAFETY AND LICENSING BOAD.D -

l:

This is to certify that the document RESTATEMENT OF CGh~yNT v  : i' OF LEE et al. was served by deposit in U. S. Mail first clasY on 4 R2:06 October 22, 1983 on the following Service Li ,. -

wAA <:.A t. 0 Q i

Service List Sheldon J. Wolfe, Chairman j Atomic Safety and Licensing Board U. S. Nuclear. Regulatory Commission I Washington, D. C. 20555 Mr. David L. Hetrick Professor of Nuclear Engineering i University of Arizona Tucson, Arizona 85271 Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Mary E. Wagner, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 -

Docketing and Service Section Office o1 the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ALomic Safely and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission 1 Washington, D. C. 20555 George F. Trowbridge, Esq.

Shaw, Pittman, potts & Trowbridge 1 I

1800 M Street N. W.

Washington, D. C. 20036 1

Jane Lee 1 183 Valley Road f I

Etters, Pennsylvania 17319 Dr. Bruce Molholt Haverford College j Haverford, Pennsylvania 19041 Three Mile Island Alert, Inc.

315 Peffer Street

.Harrisburg, Pennsylvania 17102 l

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