ML20138A263

Demand for Adjudicatory Hearing Re Gpu 860204 Tech Spec Change Request 153,revising Tube Plugging Criteria for Steam Generators

ML20138A263
Person / Time
Site:	Three Mile Island
Issue date:	03/10/1986
From:	Doroshow J THREE MILE ISLAND ALERT
To:	NRC COMMISSION (OCM)
Shared Package
ML20138A268	List: ML20138A263 ML20138A269 ML20138A650
References
CON-#186-377, RTR-REGGD-01.121, RTR-REGGD-1.121 OLA, NUDOCS 8603140166
Download: ML20138A263 (3)

Text

311 UNITED STATES OF AMERICA /'

NUCI, EAR llEGUI,AToltY COMMISSIO C l,!.19 E l'un -~ i\:^j, Defore the Comminnion jt

. M, csM In the Matter of )

gp

M [IM METit0 POI,ITAN EDISON COMPAt1Y

)

) Docket No. 50-209 M O (Throo Mile Inland Nuclear ) (Steam Generatorn)

Station, Unit 1) )

Tiliti:E MII.E ISI,Af1D AI,ERT 'S FORMAI, DEMAND FOlt ADJUDICAToltY

!.lCENSE TO CilANGl: llEARING ON AMENDMEllT TO TMI-l OPERATING TURE PI,UGGif1G CRITERIA Three Milo Inland Alert hereby formally demands a full adjudicatory hearing on the requented amendment to the THI-l Facility Operating I,1cenno, No. DPR-50, nubmitted to the Comminnion on February 4, 1986, an Technical Specification Change lloquent No.

153.

TMI A requentn a f ull hearing on the granting of thin amendment, or any part thereof, which would niter THI-l'n current ntonm generator tubo plugging critoria to allow TM1-1 to operate with a defectivo tube having a crack or imperfection with a depth equal to or greater than 40% of the tube wall thicknenn. The amendment an currently proponed would allow THI-l to opornton with defective tube having a crack or imperfection with n depth u p to 50% throughwall, and .55 inchen in length.

Anpectn which TMIA neckn to litigato include thone which the 1,1cenning Donrd han already found nurficient regarding Tech. Spec.

Chango itequent 140, in itn Memorndum and Order of February 12, 1906, nad which apply equn t ly to the inntant proponed amendment .

l oso a nt>o314o166 PDR ogDAoocn o Mn9 0 Fon

These aspects, which also are hereby are submitted as contentions, are the following:

1. Neither the Licensee nor the NRC Staff have demonstrated that allowing degraded tubes to remain in service under the proposed revised plugging criteria will provide reasonable assurance that TMI-1 can operate without endangering the public health and safety, because the f orm and rate of new tube degradation has not been determined.

l l 2. Neither the Licensee nor the NRC Staff have demonstrated that allowing degraded tubes to remain in service under the proposed revised plugging criteria will provide reasonabic l ,

! assurance that THI-1 can operate without endangering the public l

l health and safety, because the testing technique relied upon to define degraded tubes in inaccurate and inconclusive, in light of

the particular method of degradation, is uncertain.

3. Neither the Licensee nor the NRC Staf f have demonstrated that allowing degraded tubes to remain in service under the proposed revised plugging criteria, which could contribute to the f requency of leakage during plant operations, is consistent with the requirements of GDC 32.

4. Neither the Licensee nor the NRC ."taff have demonstrated that allowing degraded tubes to remain in service under the proposed revised plugging criteria, is consistent with the requirements of GDC 31, in that the critoria does not take into account environmental ef fects, including possibic environmental corrosion even in the absence of active corrosion mechanisms.

5. Neither the Licensco nor the NRC Staff have demonstrated that allowing degraded tubes to remain in service under the proposed revised plugging criteria is consistent with Reg. Guide 1.121, which requires that plugging criteria take into account variations in tube thickness due to possible corrosion.

Respectfully submitted, THREE MILE ISLAND ALERT, INC.

By: __

anne Doroshow Dated: March 10, 1986 0

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