10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9

Ms. Doane,
Attached is Three Mile Island Alert's petition for enforcement action regarding the replacement steam generators. A fluttering behavior of the steam tubes to the point of damage was not predicted by design analysis. The behavior could cause steam tube rupturing during reactor transient conditions. Although analysis has been performed on steam tube loads under transient conditions, the fluttering and damage mechanism has not been analyzed.
The aggressive design, an admission that "the margin to buckling was not conservative," geometric changes from the previous steam generators, in addition to a design flaw and a manufacturing flaw, means that the steam generators are in violation of  regulation §50.59 in 10 CFR "Changes, tests and experiments." 
Our request for enforcement action and supporting facts are stated in the petition.
Scott D. Portzline
Security Consultant to TMI Alert
3715 N. 3rd Street
Harrisburg, PA 17110
Eric Epstein
Chairman of Three Mile Island Alert
4100 Hillsdale Road
Harrisburg, PA 17112