ML20090H775

Forwards Analysis of Basis for Final NSHC Determination in Connection W/Proposed Amend to License DPR-50,approving Method of Repair of Steam Generator Tubes.Analysis Emphasizes Narrow Scope of Actual Amend Involved

ML20090H775
Person / Time
Site:	Three Mile Island
Issue date:	07/25/1984
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Plaine H NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
OLA, NUDOCS 8407270164
Download: ML20090H775 (11)

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July 25, 1984 HAND DELIVERY Herzel H. E. Plaine, Esquire General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. F14ine:

I am enclosing our analysis of the basis for a final no significant hazards consideration determinaGon in connec . ion with the proposed amendment to the TMI-l operating license approving the method of repair of the steam generator tubes.

The analysis emphasizes the narrow scope of the actual amendment involved. I believe the analysis to be sound. I want t point out, however, that we did not oppose a broader scope of issues in the ongoing steam generator repair hearing and that at the prehearing conference on October 17, 1983, I in fact supported intervenors' position that contentions as to the cause of tube damage were within the scope of the hear-ing. This was partly to remove the potential for delay, 8407270164 840725 PDR ADOCK 05000289 0 PDR

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SHAw, PITTMAN. PoTTs & TROWERIDGE A PARTNEngwep OF WEDOFCSSIONAL ComeOmATIONS Herzel H. E. Plaine, Esquire July 25, 1984 Page Two including appeals on legal grounds, and because of our con-viction that we would prevail on the merits without unduly prolonging the hearing. The contentions in question were in fact decided by ' summary disposition in licensee's favor.

N Sin rely,

,,,,J,L eor e F. Trowbridge, P.C.

Counsel for GPU Nuclear Corporation cc w/ encl:

Attached Service List l

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SERVICE LIST i

Chairman Nunzio J. Palladino U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Commissioner Thomas M. Roberts U.S. . Nuclear Regulatory Commission Washington, D.C. 20555 Commissioner James K. Asselstine U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Commissioner Frederick Bernthal U.S. Nucibar Regulatory Commission Washington,.D.C. 20555

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Commissioner Lando W. Zeck, Jr.

U.S.-Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge Sheldon J.~Wolfe Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. David L. Hetrick

Professor of Nuclear Engineering University of Arizona Tucson, Arizona 85271 Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina. 27514 Richard J. Rawson, Esquire Mary E. Wagner, Esquire Office of Executive Legal Director U.S.~ Nuclear. Regulatory Commission Washington, D.C. 20555 Joanne Doroshow, Esquire Louise Bradford ~

Three Mile: Island Alert, Inc.

315 Peffer Street Harrisburg, Pennsylvania 17102

-Norman Aamodt R. D. 5,'. Box 428 Coatesville, Pennsylvania 19041

• , Hand' Delivery-E #

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i. y Jane Lee-

-183 Valley Road-Etters, Pennsylvania 17319, Bruce Molholt, PhD.-

- Haverford College Haverford, Pennsylvania 19041 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.. 20555 Atomic. Safety and Licensing' Appeal Board Panel U.S. Nuclear Regulatory Commission

' Washington, D.C. 20555 Docketing and Service Section Office of-the Secretary i U.S. Nuclear Regulatory Commission

, Washington, D.C. 20555 J

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a- O July 25, 1984 9'

4 OCMETTMI-l Steam Generator Repair Amendment UW, 5

Basis for Determination of h Ugnificant Hazards Consideration 0 '

- Th s(memorandum has:been prepared in support of the NRC Staff's recommendation to the Commission of a final determin-ation of no significant hazards consideration in connection with an_amendmen,t to the TMI-l operating license approving the method of repa\ir of the steam generator tubes.

It is critical to the analysis of the question of signif-icant hazards consideration to focus on the scope of the license amendment. In particular, it is necessary to' focus on the difference between (1) the investigation of'the cause of the tube damage and assurance that it will not recurzand (2) the license amendment itself. The investigation-of the cause and_ potent'ial for recurrence did require extensive analysis by GPU and review by the NRC Staff. But'this is.

wholly independent of the repair process or any associated license amendment.

As the NRC Staff interprets the present TMI-l Technical Specifications,_an amendment to the' Technical Specifications is required to permit operation of the TMI-1 steam generators where tubes have'been repaired.by any means other than~ plugging.

The amendment. requested-by licensee and_ proposed _by._the Staff-'

would_ simply 1 add the kinetic : expansion technique 1 employed'uy--

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licensee'as an additional approved methdd of repair.- -This is the entire scope of'the proposed. amendment.

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-1 This is not to say that GPU's and NRC's interest in the return of the steam generators to service was limited to

-whether the steam generators have been properly repaired by the kinetic expansion process. Both'were concerned with the cause of the tube damage and with assurance that the damage would not recur. Evaluation of the cause and its possible-recurrence was in fact the main element.in GPU's research and investigations ahd in NRC's review. The point is, however, N

that NRC's concern about the causation of'the tube damage and the possibility of recurrence was wholly independent of its review of the repair process. Once NRC was satisfied that the cause of tube damage had been identified and corrected no license amendment or other affirmative licensing action was necessary on that account. NRC simply recorded.its satisfac-tion wit.h. licensee 's conclusions, as-it conventionally does, in a Safety Evaluation Report.

As to the license amendment which is. required, i.e. to approve tube repair by kinetic expansion, the Staff. correctly concluded.that no "significant hazards consideration" was in-volved.- The conclusion was correct even:taking the view that the Commission's Sholly regulations should be interprete'd in terms of'significant new or unreviewed safety questions rather than degree of risk.

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Licensee's approach to satisfying both;itself and-the NRC as to .the suitability of the kinetic expansion' process -was -tct demonstrateithat, as so(repaired, the steam generators would 2

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meet all of the NRC's already established structural accept-ance criteria for the steam generators as originally licensed.

No new or relaxed acceptance criteria were proposed. The NRC Staff accepted this licensing basis for the steam generator repair and was satisfied with the confirmatory test program provided by licensee. This is what the Staff attempted to explain to che Ccmmission at the Commission meeting on Decem-ber 7, 1983. ('Er . 3 3 , 44, 46-49, 57, 59, 72.)

\s The views expressed by Commissioner Asselstine* on the question of no significant hazards consideration, and more particularly the four questions which he suggests involve significant new or unreviewed safety issues, do not properly take into account either the scope of the license amendment or the focus of the licensee and Staff review of the tube repair technique. Commissioner Asselstine's four questions are restated and discussed below:

Question (1) The nature and extent of the corro-sion mechanism are unique. Has the corrosion mechanism been arrested? Has it affected other primary system components?

Discussion of Question (1) The nature and extent of the corrosion mechanism and the questions as

• Views of Commissioner James K. Asselstine on the NRC Staff's No Significant Hazards Consideration Determination on the Three Mile Island Unit 1 (TMI-1) License Amendment Applica-

tion for Steam Generator Repairs (undated).

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-t to whether corrosion has'been arrested and whether it affected other primary system com-ponents were all extensively investigated by licensee and reviewed by the NRC Staff. Even assuming, however, that the investigations and review involved significant safety. issues, they are not issues which are germane to the proposed li' cense amendment,.which has sol.ely

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to do with the_ approval of kinetic expansion as a repair technique.

4 Question (2) -The use of the kinetic expansion

. repair process has never before been applied

, to used, sensitized steam generator tubes.

What acceptance criteria should the staff apply to the repair?.

Discussion of Question (2) This does not in-volve a nes or unreviewed safety issue. The licensee and Staff applied already established

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acceptance criteria for the original steam generators in evaluating the use and results of the kinetic expansion repair process.

In its submission to the Staff (Topical

. Report 008) licensee stated:

, Based on a qualification program, the kinetic 1 joint: meets;or exceedscthe de-sign basesLof the original joint, in- ,

s cluding the following factors: u j

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a. Load-carrying capability.

b. Tube preload.

c. Minimization of residual stresses.

The qualification program demonstrates kinetic expansion in.the upper tube-sheet is a safe and reliable method of repair for all tubes'that will remain in service in the TMI-l steam gener-ators._ The tube joints will remain structurally sound and essentially leak tight during all design conditions.

(TR-688.at 48; see id. at 34-55.)

In its Safety Evaluation Report the Staff stated:

To establish acceptability of the're-paired OTSG for return to service, the licensee instituted a test program to demonstrate.that the repaired joint would meet the original design basis.

The kinetic joint meets the qualification requirements in. terms of lond carrying capability, tube preload and residual stresses. . .. ._There fore ,

the kinetically expanded joint is with-in the original licensing basisEfor-the plant. (SER at 16, 23; see id. at 16-23, 45.)

Question (3) Do the. residues of the kinetic expan-sion process result-in a potential for new corrosion phenomena?

Discussion 13f Question (3) Residues-of the kinetic expansion process do not' introduce a significant safety question because they were removed from the; l

tubes by cleaning-after the repair to previously-i l- .r 5-u;

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.. 1-accepted industry standards, and therefore this does not' involve.a new or unreviewed safety issue.

In its Safety Evaluatirn_ Report the Staff stated:

To ensure that fragments of cartridges do not remain trapped or wedged in tubes, free flow air tests were con-

ducted for each tube after expansion.

The final l cleaning involved blowing felt plugs through-each individual tube. The head and the tubesheet were manualJy wiped down and then the gen-erator.wqs flushed to remove any rem-nants of the repair. (SER at 20.)

4 Question (4) Whether and to what extent the cor-rosion and subsequent' repair lead to a~need to change: (a) license conditions, (b) emergency procedures, and (c) analyses of loss of main feed-water transients.

4 Discussion of Question (4) Two of the.three-areas of possible change identified in this question have nothing to do with approval of the kinetic expan-sion repair _ process. Changes in emergency' procedures referenced in_the Staff's Safety Evaluation Report

'(SER at 38-44) ' are an outgrowth' of an independent licensee review of emergency; procedures and not of the repair program. Loss of mainefeedwater tran-sient analyses'were evalunted by the-licensee and NRC Staff, but only to take into account the addi-

-tional tubes that-have been plugged and-not the' tubes 6

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~ by kinetic expansion. (SER at 35-38)

The NRC Staff does plan to add new license con-citions (e.g. acceptable leak rates and frequency of eddy current testing). These conditions simply impose license requirements reflecting commitments already.made by~ licensee which will provide further confirmation of the adequacy of the repair' program. They were not relied on by N

the Staff as the basis for' approval of the repair technique. Thus the Staff has stated: .

[The] license conditions are used only to verify and monitor that the repaired steam generators are performing as anticipated. They are not relied upon-as the basis for' determining that the kinetic expansion repair technique per-taining~to tube rupture is adequate to provide sufficient assurance that tube ruptures will be detected in time and prevented to avoid endangering the health and safety of the public through release of radiation into the environ-ment beyond permissible limits. (Affi-davit of Conrad E.'McCracken ind Jai Raj N. Rajan in' Support of [NRC Staff's Motion for] Summary Disposition of TMIA Contention 1.a at 1 3 (uaphasis' added), dated February 24, 1984.).

Thus none of Commissioner Asselstine's questions involve significant new or unreviewed safety questions with respect to the limited scope of the proposed license amendment..

SHAW, PITTMAN, POTTS & TROWBRIDGE By k d'

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