ML20112A091
| ML20112A091 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/15/1985 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP), Atomic Safety and Licensing Board Panel, NRC COMMISSION (OCM) |
| References | |
| CON-#185-067, CON-#185-67 OLA, NUDOCS 8503180157 | |
| Download: ML20112A091 (6) | |
Text
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UNITED STATES OF AMERICA'-
NUCLEAR REGULATORY COMMISSION, N((gE3 25 rAR ;5 P3:14 In the Matter of
)
)
0FFICE ar "CI" METROPOLITAN EDISON COMPANY
)
Docke'ENof hW
)
(Steam Generator (Three Mile Island Nuclear
)
Repair)
Station, Unit 1)
)
NOTICE TO COMMISSION, APPEAL BOARD, LICENSING BOARD AND PARTIES AND REQUEST FOR INVESTIGATION AND CLARIFICATION On March 11, 1985, it came to TMIA's attention through sources entirely outside the NRC, that Licensee had submitted to the NRC Staff a request to revise its technical specification requirement that all tubes with 40% through-wall cracks be plugged.
I was later informed that the source of this information was the enclosed interrogatory response submitted to the Pennsylvania Consumer Advocate by Metropolitan Edison Company and the Pennsylvania Electric Company in rate proceedings before the Pennsylvania Public Utilities Commission.
After making several inquiries with the NRC Staf f, TMIA learned the following:
1). Licensee had submitted two requests to the NRC Staff for changes in the plugging criteria.
The latest request, dated e
March 1, asks that the Staff approve modifying the plugging criteria in stages, the first stage extending f rom the time of Unit l's restart until the first shutdown for eddy current testing of the steam generators.
2). The tech spec change would allow tubes with up to 70%
8503180157 850315 PDR ADOCK 05000289 G
PDR through-wall cracks to remain in service if the cracks are small in circumferential length.
The 40% criteria would be unchanged for very large cracks.
The through-wall limit would be gradually increased as the circumferential length of the crack decreased.
3). The Staff is currently conducting a technical review of the request, and has not yet decided if a license amendment will be necessary.
The current tech specs provide that the plugging criteria shall be 40% unless another limit is approved by the NRC.
4). Licensee met with the Staff to discuss the proposal on February 19.
No other party attended this meeting.
TMIA received notice that the Staff intended to meet with the Licensee to discuss the steam generators, but TMIA had not at that time any_ idea that the tech spec change request had been made.
5). There are currently 224 tubes which require' plugging under Licensee's tech specs.
With this request, Licensee is attempting to avoid plugging these tubes.
The Staff learned from my conversation on March 15 that Licensee had f ailed to noti fy the other parties of -the tech spec i
change request.
The Staff indicated that they would be making a full Board Notification shortly.
It is TMI A's understanding that the new cracks disclosed by the latest round of ECT, necessitating this additional plugging, are not located in the area where kinetic expansion was performed.
These new cracks indicate that the steam generator tubes are continuing to corrode, as has been alleged in TMIA's Brief on Appeal From Initial Decision, (December 10, 1984) at 9-
11.
Licensee's ) 7hly unusual request seems to demonstrate that Licensee is -seriously concerned that its plugging limit may be reached either before'or soon after plant start-up, due to continuing cracking.
In-light of these events, TMIA respectfully requests the following:
1). The Commission order an investigation into whether Licensee has made a material false statement by omission by failing to notify the Commission and the Appeal and Licensing Boards of-this request to change the tech specs, in light of TMIA's appeal and upcoming oral argument before the Appeal Board on this matter.
2). The Appeal Board direct the Licensee to provide a full written explanation as to what necessitated this request for change, before the upcoming April 3 oral argu ment.
Respectfully submitted,
/
pJoanneDoroshow
~
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DATED: March 15, 1985 TMIA in
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A % ctt h m e &
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Response to Consumer Advocate Interrogatory No. 4, Set I (ME/PN)
Witness:
P. R. Clark METROPOLITAN EDISON COMPANY Docket No. 842770 PENNSYLVANIA ELECTRIC COMPANY Docket No. 842771 Consumar Advocato Interrogatory No. 4 Set I (Mot-Ed): No. 4, Sct I (Ponolec)
" Reference ME/PN Statomont G, P. 8.
As a result of the cur-rent oddy current test, how many tubos, although not leaking, have detectabic indications of material degradation greater than 40% through-wall and will require plugging?"
Responne:
l As a result of the current oddy current testing, a total of 327 tubos have been found to have greater than 40% through-wall indications of material degradation. Under the current Technical Specifications, all l
of these tubes require plugging, unless a revised technically justified plugging criteria is proposed by the company and approved by the NRC. The l
company has technically evaluated the type of defect and has asked that the l
NRC approvo a revised plugging critoria which considers the combined extent of through wall and circumferential dofoces. Under this modified critoria, a total of 103 tubes will require plugging.
l l
l l
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. I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
METROPOLITAN EDISION COMPANY
)
Docket No. 50-289
)
(Restart-Management
.(Three Mile Island Nuclear
)
Phase)
Station, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of NOTICE TO THE COMMISSION, APPEAL BOARD, LICENSING BOARD AND PARTIES AND REQUEST FOR INVESTIGATION AND CLARIFICATION, was served this 15th day of March, 1985, by deposit in the U.S.
mail, first class, postage prepaid, or hand-delivered where possible, to all parties on the attached service list.
vna DA
/
jJoanne Doroshow L.
o J
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t
Y I
Service List Nunz.to J. Palladino, Chairman Frederick Bernthal, Commissioner i
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissior Washington, D.C.
20555 Washington, D.C.
20555 4
Thomas M. Roberts, Commissioner Lando W.
Zech, Jr., Commissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 James K. Asselstine, Commissioner U.S. Nuclear Regulatory Commission L
. Washington, D.C.
20555 Gary J. Edles Dr. James C. Lamb, III Administrative Judge Administrative Judge Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Board U.S. Nuclear Regulatory 313 Woodhaven Road Commission Chapel Hill, N.C.
27514 Washington, D.C.
20555 Mary E. Wagner, Esq.
Dr. W. Reed Johnson Office of Executive Legal Director Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Appeal Board
. Washington, D.C.-
20555 U.S. Nuclear Regulatory Commission Dr. David L. Hetrick Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Board Dr. Reginald L. Gotchy College of Engineering Administrative Judge Dept. of Nuclear and Energy Engr.
Atomic Safety and Licensing The University of Arizona Appeal Board Tucson, Arizona 85721
]
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas Y. Au Assistant Counsel a
Sheldon J. Wolfe Commonwealth of Pennsylvania Administrative Judge Department of Environmental Chairman, Atomic Safety and Resources Licensing Board Bureau of Regulatory Counsel U.S. Nuclear Regulatory Room 505 Executive House Commission P. O. Box 2357 Washincton, D.C.
20555 N=""4ah"""
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