ML20087J496

Response to Both Licensee & Staff Motion for Summary Disposition of Joint Intervenors Contentions & Motion to Stay Hearing.Certificate of Svc Encl

ML20087J496
Person / Time
Site:	Three Mile Island
Issue date:	03/19/1984
From:	Aamodt N, Jun Lee AAMODTS, JOINT PETITIONERS - TMI
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8403220242
Download: ML20087J496 (9)

Text

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JOINT - 3/19/64 l l

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UNITED STAES OF AMERICA f NUCI. EAR REGUIATORY CODiISSION OgEfED i

BEFORE EE A TOFIC SAFITY AND IICENSDIG BOARD

'84 MAR 22 A10:05 In the Matter of hETROFOLITAN EDISON CpiY, ET A1. Docke tMO- 289s u (Steam $beIN hIrs)

('lbree Nile Island Nuclea Generating Station, Unit 1 JOINT INTERVENORS' RESPONSE TO 305 IICENSEE'S, STAFF'S MOTIONS FOR

SUMMARY

LISPOSITION OF J0DiT INTERVENORS' CONTENTIONS, AND MOTION TO STAY EE HEARING 1.0 _IN TRODUC TION 4

Both the Staff and licensee have failed to demonstrate that there is no genuine issue of material fact to be heard with respect to the Joint Intervenors' contentions. Both licensee and the Staff have failed to address the principle thrust of the contentions. 'lhey have failed to recognize, even after discovery, that the Joint Intervenors do not take issue with the clear fact j that sulfur contamination was immediately causative of the extensive tube failures observed in the TMI-l steam generator tubes; or tbat the kinetic expansion process is acceptable as a method to re-seal the tubes in the tube plates; or that the sulfur removal program is, in itself, acceptable. The Joint Intervenors simply argue that the steam generator tubes have experienced a substantial operational history which can reasonable be expected l to enhance intergranular attack (.I.,GA,G hereafter) and susceptability to cracking under conditions attendant to resumed plant operation.

In this context, neither the Staff nor Licensee has so much as attempted to describe -metalurgical, morphological and chemical-changes which have occurred within the bulk tube material over.the 1 life of ThI-1. Neither have they justified an averment that, under 4

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the influence of the range of tem'perature, galvanic, chemical and stress conditions likely to be encountered in operation, these changes will not enhance IGA and the susceptibility of the tubes to cracking. .

ARGUMEN TS  !

2.0 I

2.1 General  !

We would first note some conclusions from the Ginna study j (EPRI NP-2877, Feb.1982, Pg.4-11):

Inconell Alloy 600 tubing, originally in the " mill annealed" condition, appears to undergo changes in its microstructure when in PWR service for greater than 10,000 hrs...

Impurity elements such as N, S, F or B may be diffusing to the grain boundaries during servie.e and may lead to perferential IGA when exposed to aggressive chemicals. ..

Hydrogen embrittlement...might occur through the interaction of hydrogen and a segregated impurity element such as sulfur in the alloy grain boundaries... g Furthermore, the tubing is galvanically coupled to the tube sheet which would probably act as a cathodic polarizer.

Neither Licensee norithe Staff considered these effects.

he would further note that Hydrogen was added routinely to Unit 1 during operation and may not be excluded in future operation.

Babcock & Wilcox OTSG Corrosion Test Program - Final Report (Eay 9,1983) also states that among "other factors that may have contributed to the extent of tatergranular attack" was " metal-lurgical conditioning of the tubing during approximately 5 years of plant operation at 605 F".

The EPRI and B&W conclusions, as .well as the industry experience of an- increasing rate of tube failures strongly suggest that we t

are grappling with a generic issue of great significance. . licensee's statement that ".. . (Af ter) approximately one-hundred OTGS operating t

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years of experience at ThI-1 and other plants.. .no cerrosion occurs" (Giacobbe Affidavit, pg.22 at 61) does not mitigate this observation. It is akin to concluding that if 10C0 persons smoked two packs of cigarett'es a day for a year and no lung cancers developed (after 1000 person years of smoking two packs a day),

cigarette smoking is demonstrated to not be harmful to ones health. We are dealing with a problem where " length o.f exposure" is a dominant, real factor.

2.2 Contention 1(2)

Contention 1(2) states, in essence, that " active forms of sulfur can be regenerated" during plant operation. Discussions regarding reinitiation of cracking durine cleanine are not relevant. Rather, licensee and the Staff clearly acknowledge the nossibility of reinitiation of sulfur induced stress cracking curing operation by their reliance on " lead" tests. We contend, I as do they, that reinitiation is vossible. However, we hold that simple reliance on lead tests is an inadequate control procedure. We also contend that Licensee's effort to define potential mechanisms for reinitiation have been inadequate.

It is suggested that copper may function akin to a synergist (EPRI NP-2877, Pg4-9, 4-3, S-2). Further, one or more of a host of system contaminants, including sulfur, may ,

drive the electrochemical potential of the alloy into a corrosion susceptible region (EPRI NP-2877, Pg.4-6-8).

Licensee states that "The perioxide cleaning process was to remove the sulfides most likely to dissolve from the tube surfaces, so that active, harmful forms of sulfur yill not be generated and cause reinitiation of the cracking mechanism." (Giacobbe Affidavit Pg. 113 at 191) This is an absurdity. Only 50-E0% of the sulfur L

4-was removed. Reinitiation is to be controlled by lithium addition. But Ph. can range from 4.6 to 8.5, allowing S-2 to be generated.

, 2.3 Contention 1(3)

Contention 1(3) states, in essence, that " morphological changes" anywhere along the tube length "could reasonably be presumed to be precursors of IGSCC." IGA islands were cited as obvious examples. licensee, after arguing that IGA "cannot be considered a precursor og IGSAC (Pg. 58,59),

capitulates ia the next paragraph (Pg. 59) with the statement, "Although IGA is not strictly a precursor of IGSAC..." and proceeds to fall back on its ultimate argument, "because licensee has taken adequate measures to insure that corrosive levels of contaminants will not be present, IGA will not propagate into IGSAC." 1 The Staff's argument is essentially the same. Both~go on i

to cite the absence of laboratory failures at IGA sites as the foundation for asserting that the IGA islands will not mature to IGSAC. It is noteworthy, however, that- the Staff felt compelled to place reliance on the lead tests, which have not 121, presumably, demonstrated progression to a failure mode.

The fact of the matter is that " metallurgical conditioning of the tubing" bg.s soccurred which even Babcock -& Wilcox believes

. "may have contributed - to the extent of intergranular attack".

(B&W Final Report, suura.) To hold that these changes .in l microstructure will not be of a continuing nature defies reason.

The fact that to this day the functional scope of knowledge surrounding this phenomenon can be summarized by the speculation,  ;

1 "may have contributed", firmly establishes the tenuous ground

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-5 upon which licensee and the Staff stand.

2.4 Contention 1(5)

Contention 1(5) addresses the simple fact that substances )

other than active forms of sulfur, acting singly or in concert with others, might be expected to cause future significant failure scenarios. We simply contend that the enormous gap of knowledge concerning the actual role played by various suspect substances be defined before the aged tubes at TMI-1 be given a clean bill of health.

Clearly, licensee acknowledged lack of understanding of even the sulfur-induced cracking:

"It was apparent that we were primarily dealing with an intergranular stress assisted failure mechanism.

(Giocobbe, Pg. 3(7)). Licensee discusses no secondary mechanisms.

- Whereas licensee asserts that " stress assisted cracking alwavs produces cracks perpendicular to the tensile stress",

the cracking was found to be "almost exclusively circum-ferential". (Giocobbe, Pg. 7(19)). Can Ideensee explain these anomolies?

".. sulfur, verhaus coupled with chloride, were rossible causitive agents (Giocobbe, Pg. 9(24)). The Ginna report (5?RI UP-2877) suggests "a link between enhanced chlorine l levels on IGA crack surfaces and extensive. IGA. . . " ('Pg,4-5), l I

Beyond this, a reading of the several studies of tube cracking at other plants,provided in discovery by Licensee', demonstrates clearly that enormous gaps in knowledge concerning SCC resistance still exist. Clearly, an adequate understanding of potential failure mechanisms is of increasing importance when tubes which w

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have both " aged" and suffered severe chemical attack are to remain in service. Following are a few of the questions raisen in other studies .which we assert cannot be overlooked at TMI-1:

. " Electrochemical potential plays an important role in the SCC resistance of alloy 600. . .the change from intergranular to transgranular SCC at cathodic potentials...need to be clarified, especially the role of hydrogen on failure mode." (EPRI N2-2114-SR, Pg. S-2).

. " Future research to explain SCC failures of alley 600 should concentrate on grain boundaries. ..ezamining the influence of minor elements and microstructural aspects...

(and)...the effect of cyclic stresses superimposed on residual stresses. . . . "(Id. , Pg. S-4 ) . 6

. " Copper. ..is a possible polarizing agent which could alter corrosive response." (EPRI NP-2877, Pg. 4-3). (

. "Storadic traces of copper may be associated with severe IGA cracking. " (Id. , Fg. S-2 ) .

. "The tubing is galvanically coupled to the tubesheet which would probably act as a galvanic polarizer.

(Id . , Pg . 4 -12 ) .

. "Relatively large grain sizes appeared to contribute to severe IGA. . . (EFRI NP-3070-ID, Abstrac t) .

. "We conducted tests with different heats of the-alloy, but the most susceptible material tested was a tube removed from one of the (TMI) Unit No.1 -steam generators.

If this tube is representative. . . " (ORN1/TM 8544, Abstract).

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3.0 Conclusions 3.1 Regarding Summary Disuosition Both licensee and the Staff have failed, with regard to all the Joint Intervenors' contentions, to demonstrate that there is no genuine issue to be heard.

3.2 Recardinc Future Action In light of the obvious lack of understa'. ling of many parameters which influence intergranular attack on the steam generator tubes at TMI-1, and the general nature of. the issue, we would urge the Staff to coordinate an industry effort to resolve the most pertinent questions raised by industry investigators. 21s should be a prerequisite to any proceeding judging adequacy of the '34I-1 OTSG's. We, therefore, motion the Board as follows:

b stay the Steam Generator Repairs proceding until an j industry concensus can be developed regarding the likelihood of the recurrence of intergranular rcracking of the steam generator tubes at TFC-1. -

Respectfully submitted,

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No an O. Aamodt v' Ab ~

k .a. r ddelee Farch 19, 1984 (Note : All underlining was added to quotations to provide emphasis.) .

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- Joint - 3/20/84 -

'Ihis is to certify that the document JOINT INTERVENORS' RESPONSE TO BOTH IICENSEE'S, STAFF'S MOTIONS FOR

SUMMARY

DISPOSITION OF JOINT INTERVENORS' CONTENTIONS AND M0 TION TO STAY THE HEARING was served by deposit in U. S. Mail, First Class on March 20. 1984 on the following Service list.

Service List Joanne Doroshow Sheldon J. Wolfe Iouise Bradford Administrative Judge Three Mile Island Alert, Inc.

Chairman, Atomic Safety

& Licensing Board 315 Feffer Street U.S. Nuclear Regulatory Harrisburg, PA 17102 Commiscion Bruce Churchill, Esq.

Washington, D. C. 20555 William Washington, Esq.

Lr. David 1. Hetrick .Shaw, Pittman, Potts &

Administrative Judge Trowbridge Atomic Safety & licensing 1800 M Stree, N.W.

Board hashington, D. C. 20036 Professor of Nuclear Fagineering Chairman University of Arizona Nunzio U.S. Nuclear J. Palladino, Regulato iy Tuscon, Arizona 85271 Commission Washington, D. C.

Dr. James C. Iamb, III Aaministrative Judge Victor Gilinsky, Commissioner t Atomic Safety & Licensing U.S. Nuclear Regulatory Board Commission 313 koodhaven Road Washington, D. C.

Chapel Hill, North Carolina 27514 lhomas Roberts, Commissioner U.S. Nuclear Regulatory Richard J. Rawson,'Esq. Commission Kary E. Wagner, Esq. Washington, D. C. 20555 Office of 1xecutive legal Director James Asselstine, Commissioner U.S. Nuclear Regulatory ,

U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety & licensing Frederick 3ernthal, Commissioner Appeal Board lanel U.S. Nuclear Regulatory U.S. Nuclear Regulatcry Commission Commission Washington, D. C. 20555 hashington, D. C. 20555 Dauphin County Commissioners l Docketing & Service Section Dauphin County Courthouse Office of the Secretary Front and harket Streets U.S. Nuclear Regulatory Harrisburg, PA 17101 Commission Washington', D. C. 20555 Robert Pollard Union of Concerned Scientists

-1346 Connecticut Avenue, N.W.

Dupont Washington, Circle L. 3uildingE C. 2003 Suitel101 -

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. .. 4 IhI PIRC Senator Arlen Specter 1037 Maclay Street U. S. Senate Harrisburg, PA 17103 Washington, D. C. 20515 Soard of Directors Senator John Heinz PANE U. S. Senate Sox 268 Washington, D. C. 20515 hiddletown, PA 17057 Henry Myers, Science Advisor Marvin I. Iewis Committee on Interior & Insular 6504 Bradford Terrace Affairs Philadelphia, PA 19149 U. S. House of Representatives Wash gton, D. C. 20515 Ms. Virginia Southard, Chairman Citizens for a Safe Environment / #

264 Walton Street Me44/ (Aw?b Iemoyne, PA 17043 Norman O. Aamodt Regional Radiation Representative March 20,1984 EPA Region III Curtis Building (Sixth Ploor) 6th & Walnut Streets

! Philadelphia, PA 19106 Karin W. Carter, Esq.

505 Executive House P. O. Box 2357 Harrisburg, PA 17120 f Bruce Molholt Haverford College -

Haverford, PA 19041 Mr. 2homas M. Gerusky, Director Bureau of Radiation Protection Pennsylvania De7artment of Environmental 3esources P. O. Box 2063 Harrisburg, PA 17120 Robert Edgar, Congressman 2352 Rayburn House Office Building Washington, D. C. 20515 Edward J. Markey, Chairman Oversights & Investigations 205 Cannon House Office .

Building Washington, D. C. 20515

.Att: Richard D. Udell

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