ML20138B222

Demand for Full Adjudicatory Hearing on Licensee 860204 Request for Amend to License DPR-50,identified as Tech Spec Change 153,to Relax Tube Plugging Criteria.Served on 860318

ML20138B222
Person / Time
Site:	Three Mile Island
Issue date:	03/10/1986
From:	Doroshow J THREE MILE ISLAND ALERT
To:	NRC COMMISSION (OCM)
Shared Package
ML20138B227	List: ML20138B222 ML20138B241
References
CON-#186-445 OLA-2, NUDOCS 8603200304
Download: ML20138B222 (3)

Text

4 gRVED MAR 181986 ,

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S UNITED STATES OF AMERICA S-

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NUCLEAR REGULATORY COMMISSION. ggb 2 ] Jggy I

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Before the Commission 4f ___

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In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289 -dd/93g

) (Steam Generators)

(Three Mile Island Nuclear )

Station, Unit 1) )

THREE MILE ISLAND ALERT'S FORMAL DEMAND FOR ADJUDICATORY HEARING ON AMENDMENT TO TMI-l OPERATING LICENSE TO CHANGE TUBE PLUGGING CRITERIA Three Mile Island Alert hereby formally demands. a full adjudicatory hearing on the requested amendment to the TMI-1 Facility Operating License, No. DPR-50, submitted to the Commission on February 4, 1986, as Technical Specification Change Request No.

153.

TMIA requests a f ull hearing on the granting of this amendment, or any part thereof, which would alter TMI-l's current steam generator tube plugging criteria to allow TMI-1 to operate with a defective tube having a crack or imperfection with a depth equal to or greater than 40% of the tube wall thickness. The amendment as currently proposed would allow TMI-l to operate with a defective tube having a crack or imperfection with a depth up to 50% throughwall, and .55 inches in length.

Aspects which TMIA seeks to litigate include those which the Licensing Board has already found sufficient regarding Tech. Spec.

Change Request 148, in its Memoradum and Order of February 12, 1986, and which apply equally to the instant proposed amendment.

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4 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 form and rate of new tube 4

degradation has not been determined.

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

assurance that TMI-1 can operate without endangering the public j

l health and safety, because the testing technique relied upon to f

s 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 j the requirements of GDC 32.

4. Neither the Licensee nor the NRC Staff have demonstrated 4

l that allowing degraded tubes to remain in service under the proposed revised plugging criteria, is consistent with the J

, requirements of GDC 31, in that the criteria does not take into j account environmental ef fects, ; Acluding possible environmental f corrosion even in the absence of active corrosion mechanisms.

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5. Neither the Licensee nor the NRC Staff have demonstrated 1

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that allowing degraded tubes to remain 'in service under the proposed revised plugging criteria is' consistent with Reg. Guide.

i -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: b oanne Doroshow Dated: March 10, 1986 4

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