ML19262A664

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Transcript of 791128 Public Meeting in Washington,Dc. Pp 1-94
ML19262A664
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Site: Point Beach  NextEra Energy icon.png
Issue date: 11/28/1979
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ML19262A665 List:
References
REF-10CFR9.7 NUDOCS 7912100210
Download: ML19262A664 (95)


Text

.

l. '

NdCLEAR REGULATORY COMMISSION F

IN THE MATTER OF:

PUBLIC MEETING BRIEFING ON POINT BEACH 2.206 PETITION

(

Place - Washington, D. C.

Date. Wednesday, 28 November 1979 Pages 1-94

(~

1527 032

/

(202)347-3700 ACE -FEDERAL REPORTERS,INC.

Q OfficzalRepcrters 444 North Capitol Street 791 o 1 p () & O Washington, D.C. 20001 NATIONWIDE COVERAGE. DAILY 7'

CR8532 1

DISCLAIMER This is an unofficial transcript of a meeting of the United States in the Nuclear Regulatory Commission held onwganneav, _ 99 umromwo.

,o,n Commissions's offices at 1717 H Street, N. W. ', Washington,~~ D'.~ C'.

The.

meeting was open to public attendance and observation.

This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracias.

The transcript is intended solely for general informational purposes.

As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.

Expressions of opinion in this transcriot do not necessarily reflect final determinations or beliefs.

Na pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Commission may authorize.

6 1527 033

5 32 2

fr i

UNITED STATES OF AMERICA l

2 NUCLEAR REGULATORY COMMISSION 3

PUBLIC MEETING 4

BRIEFING ON POINT BEACH 2.206 PETITION 5

6 Room 1130 7

1717 H Street, N. W.

Washington, D.

C.

8 Wedne,sday, 28 November 1979 9

The Commission met, pursuant to notice, at 2:52 p.m.

10 BEFORE:

11 VICTOR GILINSKY, Acting Chairman 12 RICHARD T. KENNEDY, Commissioner 13 PETER A. BRADFORD, Commissioner 14 JOHN F. AHEARNE, Commissioner 15 PRESENT:

16 Messrs. Shapar, Eisenhut, Case, Hanrahan, Bickwit, Reis, 17 Noonan, Malsch, Shao, Charnof f, and Barth.

18 Ms. Falk.

19 20 21 s

22 23 24 co-Federal Reporters, Inc.

1527 034 25 I

3

~2 01 01 ca pano i

C0;t4ISS10aER GILIN6KY :

Le t's vate to nold this 2

mee ting while we are daiting for Commissior er Kennedy.

Is 3

the Secretary here?

4 MR. H0YLE:

Yes.

?

COA 14ISSIONEH GILIN5KY :

Commissioner Kennedy is o

here, anyway.

71e are required to vote to hold today's 7

mee ting on snort notice.

It is a briefing on the pe tition J

e of Poin.

Eea c h-l.

Me need a vote to holu it on less than one weekf s no tice.

All in favor?

v

\\1 10

\\ (Chorus of ayes. )

COMMISSIONER GILINSKY:

The Commi ssion requested 11 12 this briefing today in oroer to a sse ss the current situation 13 a t Point Beach, and to consider whe'cher Unit I should 14 restart without f urther Commi ssion ac tion.

Wisconsin 15 Environmental Decaoe nas petitioned the Commission and asked to t ha t the plant no t start up, again, penuing an investigation 17 ano hearing on the steam generator degradation p2 051 ems at to Point Eeach, whicn have been particularly severe recontly.

19 I understand tha the staff has met with Wisconsin Electric 20 Power Company, Westinghouse and the petitioners to discuss 21 their concerns and are prepared to give us their evaluation 22 of the steam genera tor tube degradation.

23 The petition from the Environmental Decade has j

24 been ref erred to the staff unoer 10 CFR 2.206.

We pro pose 25 the following schedule for the briefings today, a staff 1527 035

4 2 Q1 J2

/. 7 3 H i

?resintation to take approxinately one-nslf houri a

a ra soonse f rom disconsin Electric do ver

'o mpa ny, the a

licensee; u? proximately 10 minutes rer.ponse from 4

dis:onsin's Environmental Decade In c o rpo ra te d, the a

pe ti t ione rs -- also aporoximately 13 minutes; and questions a

f rom commissioners af ter thet, and of course, during the i

presentatio.is.

3

fr. Case, you may proceed.

9

.tl. CA52:

Thank you, Mr. Chairman.

I woula like 10 to make a orief stacement, and mak? the record cle ar.

fne 11 staff's int 3nt is to deny tne petition tnat you 12 discussed.

.t r. Eisenhut will lead off with a presentation as 13 the oasis for our conclusion.

11 MR. EISEdHUT:

Thenk you.

As in way of osckground la for discussion today, ! would like to go osct through, very la oriefly, the Point Beach reactors, what they look like, and Il t he ni s to ry, cecause you really need to understand it and 13 s ee how it looks to put it into persoective.

1/

(51 ice.)

2J dirst, the Point Seach Unit I reactor, which 15 21 primarily wnat we are talking aoout today, nas oeen shut 22 down for refueling for some time.

That plant is in a 23 holding pattern.

It is ready to return tn power on November 24 the 21st.

It is since being held up and being held at zero 2;

power, at my request a few aays back, and t.iey are doing s

1527 036

5 32 pl b3 k ap i.",

I cricicality tests end this :ind of thing.

2 It nas oeen held up since iovember the 213 t.

This 3

slio3 is basically e summary of tne Point 3eech Units I and 2 reactors, end some of the critic el paremeters in the 3

plant.

Point Beech Unit I has oeen operating since December 3

1973.

It is e two-loop '!estingnouse plent with 262 steen

/

generator tuces.

The thickne ss of the valls is aoout.J3 3

incnes.

The tuces Inconel 500.

The tuae saeet, which w?

will be tal cing scout also, is made o f caroon steel.

v Is (311de.)

11 I won't celacor the de tails here.

Me can refer 12 oec4 to them if we need to.

13 CO't:4ISS IONER KENNEDY:

Can you ex,alain the 14 difference in the secondary water?

la l4R. EISEN'iUT:

The time at which the plant la converted from phosphate to AVT vcried somewhat, but it elso Ie is effective full power month of time, er.d tnat time -- they 15 wer3 converted over just about the s ame time.

You can see 19 the 36 effective f ull power months versus 33. 7.

One has 23 ceen operating longer than the other.

That is why /ou see a 21 dit!)rence.

22 On the next slide, this is a schematic of a U-cuoe 23 recirculating type lastinghouse steem generator.

fne 24 critical portions we will be referring to here to::3y is the 25 lower part of the steam generator.

You till see a very 1527 037

6 32 pl -)4

.:apl/H I

unic( portian which is a 23-inch tnic k steel pl ate re f errea 2

to es a tuo3 sheet.

The tuo33 pass tnrough tnat tunesnaet.

2 (ou will see each of the suoport plates.

Iney fold over in a > s ha,

r Tae next slide is a simple senematic of wnat tne a

lower piece of the tubesneet looks like, or the lovar piece of tne staan generator.

There is e caroon steel tucesneet

?

icout 23 in:he s tnick.

The steem generator tubes all come throuah that tucesheet.

They are what is callea expended 1) rolled at tTe very acttom.

They are forced out.

That is li the pipe oetween the primary and the se:ondary systam.

14 T.w revice you see cetween the tuces anc the 13 tuoss hee t is an area that we will os telsing a bout Ii considerably today, and is the area of real interest.

la fae proolem that se will ce talking aoout today, la p rin c ip ally, is occurring in this cre vi:e r?gion.

The tuces 1/

ere degrading, primarily, in f ac t, all the data we have seen 13 is ce tween the uppermost la/er of ta? tuoesnest anJ JoNn to 1) the rolled area.

All of the degradetion has oesn in tha:

2J region.

21 (311de.)

22 Ine next slide is a summary of the di ff ere nt 'cinus 23 of problems that we have seen in the past.

This is a slide 24 that I am sure you nave seen a numoer of time, summarizing 25 the types of proolems that we have oeen looking at.

You can

(

1527 038

7 32 pal Jo

.:a p 37!. i i

see from tais that there is the classic westage croolem that 4

you will re:all was experienced cact in the early 19 /0s, J

associatea with the chosphate treatment, cecause of the I

chemistry that was used on the secondary sto? of the plant.

.lastage is literally a phenomenon of, metal removal.

,lestaga a

a occurs aoove the tubesheet.

All wastage problems -- the princioal proolems 3

through that period of time, where you see tne Xs la the lef t-hanJ column, occurred in what is called the sludge y

10 pils, a pils of sluJge that accumulates on top of tne li t uc a s hee t.

This is an area of a couple of inches uo to six 12 to eight inches aoove the top of the tucesheet.

Those wars 13 princ ipally the proolems.

fou will see that Point 33ach-I 14 nad an X there.

Ina proolens were in the early '70s.

f 15 Inere is a U-oend f retting proolem associated with la a couple of the unique aesigns.

Desp crevice corrosion, is whicn is tne proolem we are talking acout here today, it has 19 ceen experienceo in the United Stetas in four reactors.

It 19 nas oeen exaerienced as f ar back as several years a go, four 2) or five years ago, unen these proolems first came uo.

21 5 tress corrosion cracking in this case is generally ref errea 22 to as cracking that has been occurring again above tne 23 t u ces hee t.

It is another proolem tnat we have seen, that wa 24 are not principally concern 3d with nera today, on Point 22 Seach.

s 1527 039

8 2 fil 06 kapBdH I

fae numoer of colunns on :he -ign: -- a c t t a lly,

z all o f them in a row, are basically associated with the 3

denting phenomena, which we hav2 talled about on a qumoer of o cc a s ions.

a fne next slide sunmarizes the Point Beacn Unit 1 3

nir to ry as it would ce loo'<?J at if you just looked at and i

concerned yourself Nith what has,actually occurred at this J

i unit.

J~N, 9

(Slice.)

f IJ If you just lookea at the numcer of tuoes clugged 11 nistorically as a function of time.' in the lef t-hana column 12 for doint Se ch Unit I, the date of the outage, the date la that the plants have been shut down for some reason, you can 11 see that the chemistry -- tnat is tne secondary chemistry 1;

-- control changed soout Septemoer 1974 Taa t change on 13 Unit I was an on-line change. They aid not shut the plant 1,

aown in September of '74 They cleaned out the system and 18 then switched to a chemistry.

They made the change, stopped 11 treating the seconda ry wi th phosphate and then changed to 23 A VT.

21 COMMIS5IO.iER AHEARNE:

.fas Unit 2 also on line?

22

'4 R. EIS E.sdVT:

It was not.

It was converted in 23 Augus t of ' 4 5.

24 CO MMISSIO.'IER AHEARNE:

It was not convertad on 25 line?

1527 040

9 2.01 07 ka pBiH I

'U. EISENHUT:

It was not.

2

2. CASE:

It was cleanea out in cetween?

3 H.

EISENHUT Yes.

There is a history of the 1

13aking tuoes in gallons per day, just to give you a quick 3

refarence point.

500 gallons per day is aoout th ee gellons 3

per minute, which is the primary coolant tech spec value.

7 30 if something is 12 that is a very smell leek.

In 3

/eoruary 1975 there was a large leac of about 125 gallons

/

per minute.

It was a quite large lask.

It was the first IJ known large steam generator tube rupture in any of tne 11 plants operating in the United States.

12 If you look at just the right-hand column, at 13 first blush it looks like tne numoer of tubes plugg3d was 14 considerab13 back in the 1 9 i2 ' 74 time frame, and Onen 15 recently in 1979 you see a consideraole amount of 13 de gra da tion.

That is, in fact, the casic ceuse of the 1,

concerns that have oeen raised at tnis time, because you 13 must explore anc go into this somewhat deeper to understand le what is going on.

20 COMMISSI0 DER GILINSKY:

How many tubes would nave 21 been leaking?

22

'G. EISENMUT Generally c as tube.

Occesionally 23 you find two tubes that are leakinc, but historically in 24 reactors, in all reactors throughout the United States, when 2a you see a 13aking tuce it is generally one leaking tuce.

s 1527 041

10 2.9) J8

3p 3 M i

fnere have been some dented plents.

. shen you sae a

some leake;3, it is essociated with one or more tuois.

3 00 t.IISS ID.lER AHEAR.4E fha t is one, that is now 4

leasing.

Taere are several behind that.

2

.G. EISE: HUT:

That could oe there eventuelly, as a

time goes on, yes.

This column, though -- the leat rate

/

gen 3 rally when the leakage -- the period of time you are 3

opereting with 9 leaking tuce is so short tnat enother tuos v

doesn't reach that point.

1]

00T4ISSIO'1ER GILI 15KY:

.inet is the critsrion for 11

.alugging a tuce?

12

'G. EISENHUT:

The utility in the past has ussa a 13 31ating requirement, but when a tube is -- 40 percant of thr it well thic kne ss is gone, they plug the tuce.

15 00 T.il S5IO:1ER AHEARciD cle do not aave a la criterion.

Ie

'G. EIS2NHUT:

Yes.

One of the regulatory guides 13 tells us how you determine what the clugging limit should I/

be.

It is generally 40 to 50 percent of the wall gone.

29 What you do is figure out tne rate o f degradation and than 21 it is 40 percent throughwall is the limit.

That has a lot 22 of ma rgin on i t, to show it coula probacly go 60 to to 2a percent throughwall, f rom t3 sts that have Deen Jone, tuces 24

-- fou will see some data in a lit:19 bit -- tubes with a 2a very small f raction of the wall lef t actually are capable of 1527 042

11 2.0} 09 k apStid i

nandling tn? differential pressur?s thet you might 2

experience during normal op3 ration end during postulated J

accident conJitions.

4 C014 I SS IO.1ER GI LI.'!S KY:

This is 40 or 50 percent 2

at eny on? ?oint?

a la. EI5ENHUT At any one point.

50 percent or 60

/

per:3nt left.

3 H. CASE:

Some are plugged bec aus e they are in a sus;qct area.

Not necessarily all of these reach 40 I)

,aer:3nti is that true?

11

13. EI5ENHUT Yes, what you will see in a moment 1:

when I dissect this last column, you will see that in fact 13 two things nave enanged recently.

One is the thing you are 14 looti n g with, that l's, the addy current prooe has changed.

13 It cecame wore sensitive for certain kinds of cracks.

It 13 used to ce what is callea a single frequency probe, and now le the eddy current proce is a multifrequency probe.

So you l3 are looking with a diff erent yardstic k measuring how much 19 material is left.

20 And secondly, the utility has changed its limit.

21 Jow ne no longer says that tube must be 40 percent of the 22 way gone to have a problem, out any defect that I see, I 23 will plug.

24 COMMISSIONER KENNEDY Any def ect?

2; MA. EISENHUT Any defect that is detectacle, so 1527 043

12 32,0'l 10 kapSici i

therefore of definition what you are going to do is see a 2

larger numoer of tuces plugged.

3 CO MMISSIONER GILIJ5XY:

io i of ten are all of tae 4

tuces examined?

a

13. EI3ENHUT Gene rally, generically, Regulatory 5

Guide 1.1 21 says that you do a three cercent inspection at

/

each outage.

3 C011ISS IONER AHEAhiEs Any outage?

/

MR. EISENHUT3 No, it is generally a refueling IJ outage, for some period not to exceeJ 24 months.

Generally 11 an inspection is done at the refueling outage and you do 12 three percent.

13 COMMISS IONER KENNEDY:

Three percent?

Is there a

i?

some method of wnich you select the three percent?

la MR. EI5ENMUT A plant that has not found a real 13 proolem, sor t of at random.

On plants that are suspect, or 14 plants that have seen some kind of proolem in the past, it 13 is e selected pattern, not oy Regulatory Guide 1.121, but 11 cecause as we are reviewing we require different plugging in 20 dif f e rent inspection approaches.

21 For example, if a plant had denting problems, you 22 would do it with multisize probes as well as different 23 f requ ency probes.

And we would look in the most suspect 24 areas.

If you had primarily a wastage problem, we would 25 tell them to look in the kidney region, as it is called, of 1527 044

13

~2 01 Jg ka p:Mn' I

the size half-moons of the steam generators, wnich is 2

principally where wastage problems occur.

3 So it is pre tty mucn general but if it gets to be 4

any more it is generally fi t to a problem, once a plant has 6

a problem.

o Cut.faISSIOJEH GILINSKY:

Three percent is about 100 7

tuces?

/

(,

o MR. EISEddUT:

There are generally 32,060, so v

three percent would be aoout ICO.

It we founc any defects Y.

10 in the I CC tubes, you pick ano ther three perc en t.

So in i li fact. f rom a practical standpoint --

m 12 COMi4ISSI0dEd AHEARNE:

Is tnat a continual 13 process, and then the second three percent?

14 MR. EISENHuf:

I think there is a limit on it, 15 but f rom a practical standpoint.

Let me give you a lo f or-e xam ple.

Tne August inspection and October inspections, 17 they inspected 100 percent of the tubes, all 32,060 tubes.

le S o, w ha t in effect IV COMMISSIONER KENNEDY :

Less those already plugged?

20 MR. EISENHuf:

Yes, which was under 10 percent.

21 COMMISSIONER BRA 0 FORD:

What is the total gallons 22 per day that would go through a tube?

23 MR. EISENHUI Procably from a double-endec 24 off se t.

25 MR. CASE:

Just going through the tube.

1527 045

14

'2 dI //).,

kapdH.i l

MR. EIS ENHU f ouring normal operations?

(ou take 2

32,000 tubes times two ano figure ou t the mass flow through 3

the system, 4

CoaMISSIOWEd AHEAHAE:

What leu to the inspection 6

of all 100 percent of the tubes?

o MR. EISENHUT:

We will get the number for you.

7 MR. CASE:

Why old Point Beach decice to look a t e

100 percent?

v t.iR. EISENHUT I tnink the e perience t ha t ha s 10 been growing of tne -- there was a leak last Septembert 11 there was a leak in Maren, leaks in August; and at some 12 poin t there has been clearly within the last year three

!3 different identifiable leaks.

The two August events on 14 here, I believe, are the same tube, wnich is a mistake in lo plugging the wrong tube, ana went back and returned to lo operation and foound the same tube.

17 COMMISSIoriER AHEARNE:

So does the 145 indicate le that they inspected 100 percent or the tubes?

Ana you say 19 that the criteria was "any defect,"

so i s i t o f the tubes 20 they only found 145 with aefects?

21 MR. EISENHuT:

That is correct.

22 23 24 25 1527 046

15 2 D$ 01 gshd.4 1

4.1. EI5E.iHUT Ao3ut 27 gallons per minute.

COTTIS3IOJER 3RADFORO:

130,000 per day for on3 J

tuce?

44. EI3 E.1 HUT:

Yes.

The flow-through tuos is cassa upon the pressure diff erential from the coolant on the a

instae of tne tuos.

I' is roughly around 2200 psi. The

/

coolant on tne outsice is somewhat under 1000 psi.

So one 3

could bre ak a tuos.

You could have consideraoly more flow 9

through that oroken tuce.

10 The maxi.num theoretical flow, if you postulate a tuce 14 instantly oraken in half and if it could phys ically o f fs 3 t,

12 would be prooably on the order of 500 or 600 gallons per 13 day.

14 Janerally, there are lots of restrictions in the steam la generator oefore you physically get to that.

la 30 what de did next was -- this slide really ought to 1.

loot in a little more de tail.

And tne next slice sort of 13 takes the last column.

It is the number of tuces that have IV ceen plugged and dissacted.

2]

(311de.)

21 It takes the same dates of the cuttages and says what was 22 the cause of them.

.ihen you look at it this way, you can 23 put problems in a little better perspective.

First, the 24 proolem that occurrec historically was the thinning or 2;

crac k ing, tne wastage associated phenomena which was 1527 047

32,02b2 16 gs h 3.1 i

occurring somewhat aoove the tuce sheet, a few incha s aaove,

d in that gen 3ral region, again primarily is wnat is callad 3

the tidney region, shaped like a kidney in the middle of it.

fnet proolem was principally assoc iated with the use of sodium phos? hate treatment for secoqJary treatment of the a

steam generators.

/

fne plant, you recall from the other slide, converted to 3

all volatil? treatment in S3ptember of ' 74 It was

/

converted on line.

And at the debruary, ' 75 shutdown, yo u IJ notic e quita a large numoer of tuces were plugged.

Thos3 11 nave grown ooviously during the period of time the plant was li on phosphate.

13 fnere was no shutcown in Septem'er, '74 o

14 fou will notice af ter th3y converted the secondary side 15 water treatment chemistry, that proolem basically went away.

la That is notning new at Point Beacr..

That is something tnat 1

has oeen seen at a very large numoer cf plants in the United 13 States and around the world, ly On the left-hand side, tne denting column, you will 20 recall in late 1975 we had consideraole attention paid to 21 the denting phenomenon.

A number of plants Icoked to see 22 whether or not there was any denting.

23 The denting surveyed there results in the pluoging of tin 24 tu bes in steam generator A and it turns out that those ware 22 all extremely minor dents.

There has been no evidence of 1527 048

17 32 02 03 Jsn 3?i i

growing centing proolems in any signi ficant way at all since 2

that point in time.

a inat leads us over to the last column, wnich is the 4

crevice corrosion proolem, which, as I seic earlier, is the tning that we primari:y from a safety standpoint were a

a conce rned aoout.

The proolem there is, as I said, exclusively, from 4

3 avarything that we have ever seen tisd to crac'.cs that

/

occurred in the crevice.

That is ceiow the upper surfac? of 13 the tube sheet in aoout a 20-inch scan of the tube Jown in li the tube sheet.

12 There ara, I celleve, 18 plant 3 in the United States with 13 this design.

As I pointed out earlier, 2 or 3 of tasse li othar plants have seen the same '<ind of phenomenon.

1; (311de.)

la C0%MISSIO.iER AHEA7dE Setore you leave this one, 1/

Just out of cur iosity, what wers th; othar il tuces plugged 13 for?

19 MA. EISENHUT On the last slide?

2J CO'.iMIS3IO;lER AHEAai4E On 10-5, there were 1 45 2!

tubes pluggad.

22

'.id. EISENHUT:

I think there were a few 23 misplugged.

Ano generally, the numoer went up from 135 that 24 were suppossd to oe plugged up a little oit higner.

2a VOICE:

11 tuces steam generator with no 1527 049

18 2.G5 J4 1shJd i

indt:ation in lacoratory exemination.

fhere was some indication (inaudiole ).

a MR. EIS dNHU T It won't eaa up.

The simple point is taat 2 or 3 of the tuces were p'111ed for examination.

a fhere were 2 or 3 plugged b/ mistate, fhere were 2 or 3 that were actually pulled for examinations eno test of a a

I couple of di ff erent times.

3 And to get a cetter understanding of what was going on in 9

the steam generator, the utility did pull good tuces.

1]

could I nave the next slide?

11 (511de.)

12 Let's skip that slide ar.d go to tne next one.

13 (Slide.)

14 I would like to focus on the piece of experience 15 asso:iated with what we call deep crevice cracking.

If /ou 13 l oo k a t the -- this, you s ee in '77 there were some proolems 1/

vitn 2 or 3 tuces.

In August, there were a numoer of tuces la plugged in August of '79.

l/

The real concern came ao3ut cecause in August,

'i),

tnera 2J was an extensive inspection, 100 percent inspection, which 21 resulted in that number of tuces plugged, aoout 1 00. And 22 then again, in Octooer, there was another 100 percent 23 inspection, which resulted in 134 tuoes nere being plugged.

24 So the cancern came down pretty simple of looking at the 23 August and October inspections.

1527 050

19 2.02 35 gshda CO TAISSIO.iER AHEAdNE:

fne August was 100 2

percent.

So these additional tuces two months later were 3

eitner --

4 Ad. EISENHUT:

That was my next statement exactly, a

The August -- there were two dif f erences.

In August, tne 3

plugging requirement was that you had to os 40 percent

/

degreced oefore it was plugged.

In Octooer, they alugged 3

all indications.

9 Goviously, they found 14] tuoes in Oc tobe r, cut also, IJ the/ used a diff erent measuring tecnnicue.

They used a 11 single frequency eddy current test prote in August and they 12 used a multi-frequency eddy current prooe in Octooer.

13 It is not simple to know what is the cause.

You get down 14 to either, tnere is a very rapic race of degradation and/or 15 the testing scheme, the previous tes ting scneme is in la question.

1.

fnat is tne single frequency.

13

'ile stingnouse estimates tnat of the 140 tuces that were 1/

plugged in October that were not found in August, maybe 20 one-t hi rd of those were due to the fact that they switched 21 proces, a new technique.

22 Ine other two-thirds, it is hard to say now many of tnem 23 were pluggea because now they have some indication which 24 cefore would have been below the limi t.

2a CD'.t'4 ISS I O:iER AHEA3N E:

Since you did or since they 1527 051

20 32,02 06 gsa N I

dio in August 100 percent, at least those that were celow 3

d the limit could have oeen -- was a record maintained?

o MR. EIS ENHUT Yes.

And in fact, that is ceing t

cone.

A nuncer of the records of tne -- it ts two times a

3003 -- 32,060 tuces are being chec%ed to look a t i t.

J I think in f act, our assumption nere is that in f act there was ma jor Jegradation over that period of time.

I J

don't oelieve that we will oe sole to pin down precisely now

/

mucn of that 140 was due to eddy current change or how musn 13 was due to mis plungeo.

Il There is also another parameter, and thet is it is more 12 an art than a science, doing eddy current t3 sting.

And in 13 fact, it cepenas a lot on the reviewer of tae eddy current 14 signals on the oscilloscope.

15 COMMISS IONER AHEARdE:

Of those 134, whatever, if la the previous criterion had Deen used, how many of those 1/

would have oesn --

13 Md. EIS ENHUT: I don't think that they went bact 19 through them all and checkea that.

2J CO.MMISSIONER GILINSKY:

I aidn't understand your 21 one-third and two-thirds.

I thought you were saying that 22 two-thirds of them would have f ailed the previous test.

23 MR. EIS ENMUT:

Let me use simple numoers oecause 24 it is easier with the one-third and two-thiras.

Let's say 23 the numoer is 150 tubes.

50 of those tuces would probaoly 1527 052

21 2.02 J7 gsh321 6

nave been found in August.

4 I3 ?lestinghouse's assertion if they nad used the 3

multi-frequency tasting proce -- that is, if they h3d looked 4

witn a diff arant tuce ?

5 CalMISSIOJER AHEARNE:

You say 50 would have oeen a

found and m3t the previous criterion?

4.1. EIS EilHUT:

do.

I am saying tnat 50 'f those 9

defe:ts --

s C31MISSIONER AHEAdNE:

.lould have shown up as IJ caf ects independent of the criteria.

11 1.1. EISENMUT Yes.

Of the remaining 100, some of 12 those procaaly would have ceen plugged before if they had 13 useJ a criteria tnat all indications would ce plugged.

I&

C3 WISSIO.1ER XENNEDY:

It would be 50 plus X.

la

.4R. EIS ENHUT:

Yes. Since we don't really have --

15 AR. CASE:

The remaining woula ce due to the 1/

degradation cetween the two periods of time end we 13 conse rvativ31y assume since we can't beno down the othe rs,

19 that most, if not all, was due to degradation.

2J M.t. EISENHUT:

Yes.

The reason is that we have 21 some serious questions aoout how aceg rate eday current 24 testing is in the tube sneet, whether it is single frequency 23 or multiple frequency when you get down to defects under 40 24 percent anyway because the problem with eddy current testing 25 is that in a straight run of pipe, we believe it is very 1527 053

22 32.02 38 gshda a

accurate.

It is a good measur? to oe sole to detect cracks e

or a3 fects. dven in tuce sheets using the multi-frequency 3

proos, wnat it does is it me asures the -- it looks at the 6

tuba, the lower frequency looks at the support plat? on the outside ana differentiates oetween the two anu gets a better a

handle on wnst is in the tuoe.

/

dut you need to nave a lot of correlation data and you 3

need to oe aole to look at the situation to get that i

c o rre la ted.

IJ fnere is not anough research wort done on this situation 11 down in the crevice in tne tube sheet Nnere you haue a 12 corrosion product around the tuce in a crevice to be able to 13 get a good measure of what it really looks like, wnst X 14 l ooks like.

13 For tne sake of this discussion, we just assumed that the 13 rate of degradation is very large.

?le don't oelieve that we 1.

will be able to oe convinced that tha t large number 13 significantly goes away, either, because of the change in 1/

technique or because of the change in the plugging limit.

20

/le just don't oelieve that we are going to be convinced.

21 CD'.NISSIONER GILINSKY:

Suppose tne August test 24 had been used in October.

Are you saying approximately 23 two-thirds?

24 MR. EISENHUT I am saying some number.

1.40 20 would be -- 140 --

I527 054

23 32 02 09 ash 3N I

C3 44ISS IO.idR GILI.i3 XY:

I aon't '<r.ow how much.

4 03'04 T SSIOllER 4ENN20Y: It would be 50 et least.

a Cof4IS3IO'IER GILIJ5KY: They are saying they f eel 4

it would ce et least 50 less.

But it may be as hign as --

a it is not necessarily 50.

I t is one-third.

a

43. EISENHUT:

I can give you one more piece of a

information.

riestinghouse celieves tha; the accuracy of the 3

edo/ current proce is such that you can detect crac~cs 23

/

percent tnrough wall.

!?

So now you are o,ily concerned aoout things that are 20 to 11 40 cercent, if you accept tnat.

12 rie are not accepting that ano we are saying, witnout more 13

.f o r <, it is just unclear that theref ore, we are saying that, 14 in fact, to oe conservative acout it, we are saying that it la 1cors like 140 tubes became oefects from August to ac tooer.

13 COMMIS5 I0 DER AHEARNE:

Do we have any program to 1/

Verity the eddy current multi-frecuency device?

13

'4 4. EI6ENMUT: I will get to that.

It is very 19 simpie.

Yes, we have a program at Oa k didge.

'Be nave some 2J research work underway.

I heve asked research as of today 21 if, in f act, they can move up and expedite a progran that we 2e have been t31 king at Oak Ridge about where tney would 23 actually tr/ to moc'< up the situation and to in and see the 24 accuracy of the eddy current orobes in this '<ind of 23 situation.

1327 055

24 2,0 2 1 0 a sn3..

i

.ie ar? trying to do it.

The first estimate was tney z

coulo do it in six.aonths.

I have asked them to try to co 3

it in something less than six montas.

4 CO T.(ISS 101ER GILI AS KY:

fo sun up, you said that you aay oe aegrading at som3 thing ilke 50 tuoes a month.

a a

1d. EISE:lHUTs We could conceiv8aly.

That would

/

oe an upper cound.

In fact, to get a better handle on the 3

situation, I guess the next slide -- this is some of the

/

dat? What is ceing founo.

clow this i s 3 composite of Aucust 10 and Octooer.

fou woula expect, first of all, on tne top part of th?

11 12 histograms, you would expect them to skewed toward the high 13 e nd.

It COMMISS IDAER AHEARNE:

To reiterate the point, the 10 coa?arison of August and Octooer, tais is using different la testing devices.

Ie Md. EISEdHUT:

This is not a comparison of the 18 two.

This is a summation of the two, recognizing taat they 19 were done with different. people reaoing the charts, 20 diff 3 rent probes ano differ 3nt plugging.

21 COMMISSIONER AHEARNE:

Different types of proces.

2e MR. EIS ENHUT:

Absolutely.

That is why I want to 23 highlight -- you can' t just walk into these nuncers and 24 accsp t these numoers without carefully examining the 25 tecnnology associated with the nigh numoer.

1527 056

25 32.02 11 gsh3W i

.ie have considaraole debate with the experts aoout the 4

accuracy of the proces and the different configurations, a

d? now have a numoer of our consultants looking at it. It 4

is a very complicated --

a COT 4ISSIO.1ER GILIWSKY:

All of this cuts two ways, 3

dotsn't it?

'M.

EIS ENdUT Aosolutely.

From a prudency 3

stendpoint, we are assuming that there wers a s igni f i can t

/

numoer of tuces degraded.

That is my bottom line.

I don't 13 thin'< we are going to be able to resolve that discussion in li short order.

12 And from a licensing standpoint, it is prucent to hav? a 13 cons?rvative approach.

14 One thing that we are going to try to look at also, we la will try to duplicate this chart as to what it looked like la in August and what it looked like in October so that we can li make a comparison.

IS This is the data that we have at this point.

19 The important point that you see here is the cop really 23 doesn't tell you much except the sensitivity of eddy current 21 proces is higher f or defects nearly throughwall.

And hence, 22 you will see a lot more of those.

23 30 you may well nave a Gaussian aistribution in the sense 24 of the numoer of indications versus wall thickness.

2a fou can't-really ascertain that without knowing the 1527 057

26 32.02 12 gsn3N I

sensitivity of the instruments you are looking at.

d The co ttom part o f it, thougn, Joes tell us some tning e 3

little oit firmer.

It shows us where, in fact, these 4

def 30 ts are occurring.

And you will see that taey are cccurring, oy and large, looking at A and 3 together over a s

a considerable portion of the crevice.

4 I should point out that the top region tnere is a little d

cit less.

It is 20 inches to 23 inches.

It is only a 9

3-inch cand.

IJ Again, most of the def ects are actually, we oelieve, away li f rom the to,a surf ace of the tuce sheet.

le CO'4MISSI0 DER AHEARdE Most are away from?

13 Md. EISENHUT Slightly away, and slighly, you 14 will see in a moment.

But 7ery, very --

15 CO MMISS I0 DER AHEARNE:

Still in the upper three id inche s, ab3-1/

.4R. EISENHUT In the upper tnree inches.

.ie have 19 not s een any above the surface of the tuce sheet.

l>

COMMISSIONER AHEARNE:

An/ particular reason why 2J the difference in the distrioution?

21 MR. EISENHUT Not that we know of at this period 22

( n t i me.

A little more of what you would expect in the 23 upper curve on the steam generator S.

Also IB.

24 COMMISSIONER AHEARNE:

But it is more uniform 23 across that whole region.

1527 058

27 CR.8'532 WH'ITLOCK t-3 mte 1 I

COMMISSIONER KENNEDY:

It is also interesting that 2

at the very bottom on that one, whereas there is no indications on the other one.

4 MR. EISENHUT:

That is correct.

And if in fact 5

you ask a lot of the experts on the crevice corrosion cracking, 0

in[anyenvironmentatthetipofthecreviceiswhereone whuldexpectmorecracking.

And what it shows you in lA is 7

S 8

tliat 3.6 in 1B is at the tip of the crevice.

There is none i

9 down in the old area.

So it really tells you that is all 10 lo ated at the tip of the crevice, which is what you would 11 expect.

12 To get a little bit better understar. ding of what 13 is going on, the utility did a couple of other things.

He Id went in and pulled three tubes by cutting them out from the 15 bottom and pulled on the tubes tc, see how hard it would be 0

to pull the tubes out.

He vorried about a tube that is 17 crac 2d slipping out of the crevice.

18 He found that it took an stremely large force to 19 pull the tubes out.

20 (Slide.)

21 This also tells you something about the corrosion 22 product buildup around the tube.

He did just to see whether 23 or not you have to worry about a crack, where a tube can 24 lift out of the crevice region.

It is also significant that o=-Federal Reporters. Inc.

25 in the crevice we have never seen circumferential cracks.

1527 059

28 mte,2 1

From a safety standpoint, you would be more worried about a 2

circumferential.: rack, because a tube would be &ee to lift 3

itself out if it is very, very close to the top of the tube 4

sheet.

5 If the crack, of course, occurs down in the tubesheet, 6

there is not enough play in the tube where you can get anything 7

near an offset.

The theoretical limit, that is, the amount of 8

flow you would expect if you postulated a throughwall circum-9 ferential crack down in the crevice, and if you have a clean 10 crevice, is only about seven gallons per minute.

So this II kind of cracking, while it is a concern if it is occurring 12 down in the crevice, is not a problem of major primary 13 system leakage per tube.

14 COMMISSIONER AHEARNE:

Your distribution is up in 15 the top.

16 MR. EISENHUT:

That's right.

But there have been 17 calculations done that show that if the crack is below 18

.15 inches from the upper surface of the tubesheet, it cannot 19 pull out.

It is not circumferential.

It is longitudinal and 20 at some angles and at some matrix, number one.

And number 21 two, it has got to be within.15 inches before it can pull 22 out.

23 COMMISSIONER AHEARNE:

In your previous chart, with 24 the 40-some percent in the upper region, are those within hwei nepomn inc.

25 the.15?

I527 060

29 mte,3 I

MR. EISENHUT:

We can't detect it that accurately.

2 It is a backward look at it.

How much can the tube actually 3

give?

There is none above the upper surface, we do know that.

4 Even though you would think that the number there would be 5

small, even though they are longitudinal, you can see that 6

we would require a couple of extra defenses down the road to 7

back it up.

8 The utility did a few other things.

He removed 9

three degraded tubes and tested them to pressurize them, 10 degraded tubes.

I don' t have the details on how bad they II were degraded.

But none of them failed.

They all failed 12 between 5,000 and 11,700 psi.

13 COMMISSIONER AHEARNE:

Is that a static test?

Id MR. EIS::NHUT:

The 11,700 didn't fail, didn't burst.

15 It ballooned and started to leak.

16 The utility also did a number of metallurgical I7 examinations as to how much of the wall had to be there if 18 now you had this degraded situation, if a tube is free and I9 if it can move, and you now superimpose on it an accident.

20 I again remind you, the wall thickness is about.050, fifty 21 thousandths.

This is for a main steamline break.

You need 22 about.013; 26 percent of the wall must be there to certainly 23 amply be able to withstand the main steam line.

For no 24 collapse under a LOCA, you need something in the order of

s-Fweral Reporters, Inc.

25 about.015,

.02, or you need something on the order of about 1527 06i

30 mte,4 I

forty thousandths.

2 COMMISSIONER AHEARNE:

These are calculations?

3 MR. EISENHUT:

Calculations.

All it really tells 4

you is this is nothing new.

There has been a considerable 5

number of independent calculations that the staff has done 6

or had done by its consultants at the national labs.

What 7

you find is that a severely degraded tube has a considerable 8

amount of strength.

9 COMMISSIONER 'GILINSKY :

Let me understand that point.

You are saying for a large LOCA, as long as you have 10 Il more than 40 percent remaining tube wall, you can withstand I2 the forces?

13 MR. EISENHUT:

Yes.

I4 COMMISSIONER GILINSKY:

To maintain tube integrity.

15 MR. EISENHUT:

Yes.

That is outside the tubesheet.

16 That is a conservative calculation -- I didn't bring my 17 notes -- circumferential uniformity distributed in an area 18 outside the tubesheet.

It is a conservative calculation I9 even at that.

20 COMMISSIONER KENNEDY:

It would be less in the 2I crevice.

22 MR. EISENHUT:

Yes, it would be much less.

23 COMMISSIONER GILINSKY:

To go back to your earlier histograms, if I understand them correctly, some appreciable 24

e Fooeral Reporters, Inc.

25 fraction of the tubes had penetrations of as high as 1527 062

31 mte,5 1

80 and 90 percent?

2 MR. EISENHUT:

Correct, in the tubesheet.

But in 3

the tubesheet, you only need -- inside the tubesheet, you 4

only need 10 percent of the wall required, even under accident 5

conditions.

6 COMMISSIONER GILINSKY:

Even so, you had 40 percent 7

of the total steam generator lA.

8 MR. EISENHUT:

That's right, and that was part of 9

our concern as to things that have happened.

And you will 10 see it is because of that -- if the utility shut down the II unit, if he does a conservative plugging pattern, if he does 12 a thorough inspection, conservative plugging pattern, extra 13 precautionary things, we know on day one when you start up 14 you know with confidence that there are not a lot of tubes in 15 the 90 percent range.

16 COMMISSIONER AHEARNE:

The title you have is 17

" Summary of Lab Examination and Tests."

Whose lab examina-18 tions?

19 MR. EISENHUT:

All of the licensees.

I believe we --

20 our consultants have gone out to Westinghouse and the labs 21 and examined.

22 COMMISSIONER AHEARNE:

About the point of the 23 calculations, of the 10 percent being adequate?

24 DR. SHAO:

We have test results for outside the

s-Lrst Reporters, Inc.

25 tubes.

1527 063

32 mte,6 I

MR. EISENHUT:

And we have calculations.

2 DR. SHAO:

We do have test results to back up the 3

40 percent remaining outside the tubes, not for Point Beach e

4 but the segment types.

5 MR. EISENHUT:

We have also had, as far back as a 6

couple of years ago, we have had the national labs do calcu-i 7

lations for us as to how mu h material is left, how much has 8

to be left, that you ensure /.the integrity.

What you are find-

\\.

9 ing, it takes not that much haterial to ensure that, even 10 under transient situations, including dynamics, to ensure II that you don't have a big problem.

12 COMMISSIONER AHEARNE:

Do you say your own calcula-13 tions are at 10 percent?-

I4 MR. EISENHUT:

Yes.

15 DR. SHAO:

The calculation --

16 COMMISSIONER GILINSKY:

One is concerned about a I7 relatively small number of tubes bursting.

18 MR. EISENHUT:

Not quite so much from an ECCS standpoint.

Before you have a problem there is a window 20 where you have a concern, anywhere from about 1300 gallons 21 per minute maybe up to 5,000 gallens per minute.

So you 22 see if these leaks are occurring down in the crevice, and 23 the maximum theoretical leakage of a circumferential crack 24 is like seven gallons per minute, you need a very large

-k _eal Reporters, Inc.

25 number of tubes.

You need a couple of hundred tubes.

That 1527 064 l

33 mte.7 1

is for a clean crevice and for circumferential cracks, these 2

cracks.

We've never seen circumferential.

Ne see longitudinal.

3 Leakage would be less.

And the crevice has products in it, so 4

the leakage would be less.

5 COMMISSIONER AHEARNE:

Is there any significant 6

difference between calculations or the tests under dynamic 7

conditions than nder static conditions?

8 MR. NOONAN:

We basically looked at the blowdown 9

characteristics of the steam generator, both for the LOCA and 10 for the main steam line break.

The time durations we are 11 talking about in the main steam line, break are in the tens 12 to hundreds of seconds.

In other words, the time it drops 13 from -- peak pressure drops on down, it takes at least 25 14 seconds to get down to a point where it stabilizes, and that 15 is basically a static type load from the standpoint of 16 dynamics.

17 For the LOCA load, we talk in terms of milliseconds.

18 Again, we talk in terms of 30 to 50 milliseconds and. the 19 dynamic property of these tubes. That is again considered a 20 static-type load.

21 COMMISSIONER AHEARNE:

When you say quasi-static, 22 are you saying that the tests and analyses are adequate for 23 the 30 to 50 millisecond load?

24 MR. NOONAN:

Yes, would be adequate for this tube.

s-Federa! Reporters, Inc.

25 COMMISSIONER AHEARNE:

Do you have some lab tests 1527 065

34 mte.8 I

under both conditions to sort of support that judgment?

MR. NOONAN:

We have analytical stuff to show.

We 3

don't have any basic lab tests te represent that.

4 COMMISSIONER AHEARNE:

What is the time duration 5,

for water hammer?

6 MR. NOONAN:

That could be in terms of a very --

7 in the millisecond range.

8 COMMISSIONER AHEARNE:

Would that end up being 9

dynamic loads?

MR. NOONAN:

That would be dynamic load.

But I 11 would like to point out that for the steam generator it would 12 be almost impossible for us to get a water hammer dimension.

13 First of all, to get the water hammer through the feedwater, 14 you would have to come in through the feedwater and go out 1

to the sparger.

There would be no way for us to generate 16 that wave propagation down into the generator as a total wave 17 propagation.

18 Again, happening from the primary side it comes 19 in through the bottom of the steam generator, into a large 20 volume area, and into 3,000 tubes.

It is almost impossible 21 to get that kind of classical water hammer.

MR. EISENHUT:

It can't propagate through that 23 down into the crevices to -- it would be greatly attenuated 24 Y

9 m-Fewsl Rmomn, lm:.

25 at and dismissed.

i527 066

.te 9 35 1

(Slide.)

2 The nar.t slide summarizes what we have been saying.

3 Outside the tubesheet you need 40 percent of the wall and 4

inside you need 10 percent of the wall.

On the main steam 5

line break, the tube, even if it is greatly degraded, the 6

pressure differential is such that it pushes the tube out 7

against the tubesheet, which supports it and stops, even if 8

it were greatly degraded.

9 Now, the next slide is the last slide.

10 (Slide.)

11 I guess one other thing I should point out before I 12 do this, there are a couple of other things that the utility 13 has done to give himself some added assurance that the 14 integrity of the steam generator tubes is in fact still 15 adequate.

16 One is, in order to simulate a main steam line 17 break or to simulate a LOCA, he has ran some hydrostatic 18 tests.

Granted, they are hydrostatic.

But he ran a 2,000 psid 19 primary to secondary, and he ran an 800 psid secondary to 20 primary test, which is very similar to the hydrostatic test 21 that you run, that is required every time you open up the 22 primary system.

23 He did this 3 cst as another feature toggive himself 24 some assurance that in fact the integrity of the system is m Federal Reporters, Inc.

25 there.

1527 067

.te 10 36 I

MR. CASE:

This is in addition to all of the plugging, 2

MR. EISENHUT:

It is an extra tier to everything he 3

has done.

4 One item I didn't mention also, a second item, is 5

that all of the degradation that has been seen in the crevice 6

cracking has all been on.the hot side of the tubes.

By the 7

hot side, I mean the inlet to the steam generator.

Nominally, 8

the hot is comething on the order of 597 degrees and the cold 9

is on the order of 547, about a 50, 60 degree difference.

10 All of the degradation is on the hot side, even for other Il phenomena.

Most of the degradation is on the hot side because 12 there is a big temperature dependence on all of there corrosion 13 phenomena.

14 The utility therefore is considering an option of 15 reducing the hot leg temperature in the steam generetor by 16 about 40 degrees.

He will now make the hot leg temperature 17 comparable to the cold I?g temperature, and hopes to be able 18 to arrest the corrosion.

To do that, he has to reduce the 19 power output of the plant to 83 percent.

He is considering 20 that as one of the means to be able to certainly arrest his 21 problem and to hold it.

22 We are certainly looking at that right now.

It is 23 not something, again, that we have to specifically review and 24 analyze,. because that happens to be the mode that he would 2-F,.at Reporters, loc.

25 be operating ;on, a power coast-down.

1527 068

37 trte,1b.

I MR. CASE:

It is a permitted mode of operation under 2

the tech specs and an analyzed mode of operation.

3 MR. EISENHUT:

Exactly.

He can operate his plant 4

at any power up to 100 percent.

This would be the conditions 5

for operating.

6 He is also considering several other things:

closer 7

feedwater chemistry surveillance, that is, looking closer at 8

the condenser to see that--certainly if you have a condenser 9

Isakage problem, you can either -- you can isolate that leak very rapidly.

He is looking at more frequent sludge lancing.

10 II He also went through a program of trying to boil out the 12 crevice, that is, cle an out the crevice by popping the valves 13 on the steam side, going down into a couple of feet of water 14 on the tubesheet.

He literally tried to boil out scme of 15 the impurities in the crevice.

16 Those are the kinds of things he has done.

17 COMMISSIONER BRADFORD:

How successful was that?

18 MR. EISENHUT:

We don't believe that program can I9 be that successful.

You can certainly get some out.

There 20 are a couple of problems with it.

You could probably do that 21 forever.

22 COMMISSIONER AHEARNE:

You are describing a list 23 of actions which you don't think are going to do much.

2#

MR. EISENHUT:

Certainly the change in temperature

-essi Reponm, anc.

25 seems to have a considerable amount of merit.

Since he is 1527 069

38 mte,12 I

only considering it, we did not put that in as an assumption 2

on our program.

3 COMMISSIONER KENNEDY:

His paper of November 23rd 4

says, we are planning.

That is the word he used.

5 MR. EISENHUT:

We are planning?

6 COMMISSIONER KENNEDY:

On returning to power 7

operation, we are planning the following program in an attempt 8'

to retard tube degradation.

9 MR. EISENHUT:

That sounds pretty definitive, based 10 on that.

COMMISSIONER GILINSKY:

Can I ask you, in this 12 whole picture what concerns you most?

What would cause you 13 to come out the other way?

I#

MR. EISENHUT:

Come out what way?

5 COMMISSIONER GILINSKY:

Not feeling that the plant 16 could operate.

I7 MR. EISENHUT:

You haven't heard my bottom line yet.

IO COMMISSIONER GILINSKY:

I thought we heard it at the I9 beginning.

20 MR. CASE:

You haven't heard the conditions.

2I MR. EISENHUT:

I think in fact -- I think the thing 22 that would really change it is your confidence in the overall 23 integrity of the system is less, and therefore you can offset 24 that.cutfidence by a number of different parameters and a csheral Reporters, Inc.

25 number of different changes.

1527 070

39

.te.13 1

We have gone through -- and it is not any one thing.

2 It is a family of things.

I would be a lot more concerned if 3

in fact this phenomenon was occurring in the free space, 4

where the tubes can actually fail.

I think the theoretical 5

physical restrictions are being done in the crevice.

They 6

go a very long way to telling you that you are not worried 7

about a large amount of leakage.

8 COMMISSIONER AHEARNE:

What that tells me is if you 9

see a crack up in the free space, you would start getting very 10 concerned.

11 MR. CASE:

If you saw a number of them.

12 MR. EISENHUT:

A number of large amounts of degrada-13 tion.

14 COMMISSIONER AHEARNE:

I would have felt that, 15 given that this is an increasing phenomenon, that you would 16 view it as a precursor.

17 MR. EISENHUT:

If this were an increasing phenomenon 18 in the free space, absolutely.

19 MR. CASE:

I would more think at least one in the 20 upper level (Inaudible).

21 MR. EISENHUT:

Sort of in summary -- and I will go 22 through these in brief detail -- if things continue as they 23 are, as a linearity hypothesis, and if things have continued 24 as they have over the past two years -- that is, about three

-rou.rm n.conm, inc.

25 leaks per year, not really safety significant as such-per se, 1527 07i

40 mte 14 as much as, again, the general question in the back of your I

2 cind about the overall integrity of the steam generator, the 3

confidence you have.

4 The utility both in August and in October ran 5

100 percent inspections.

He switched to the multi-frequency inspection.

He switched to a different level of expertise 6

1 7

He has taken a more conser-jts far as eddy current testing.

8

,lvative plugging approach.

He ran some hydrostatic tests.

N

\\

I think all of those things together would tell you 9

khatinthisshortperiodoftime,atleastinthenearfuture, 11 you would expect to see less leakers than in the same compara-12 e-3 ble period of time in the past, if everything continues.

13 14 15 16 17 18 19 20 21 22 23 24 ce4ast Reporters, Inc.

25 1527 072

32$401 41 ka psari 1

CO:.Ir.tI SS 10 tier t<=NNEui

.i ha t is a snort period of 2

time?

3 MH. dISENHuf:

I will get to that in a minu te.

We 4

are not going to really rely on tha t, because in the past it 5

nas oeen running -- if there are three leakers a year, o

normally every four months you see some thing.

he don't 7

think you can rely on tha t completely.

le have been working u

with the utility.

He has pro posed some various approaches.

Y rJe are uiscussing some of those witn him, and I think he is 10 modifying some slightly.

After 30 effective full cower days 11 of operation, it a ppears appropriate to do another 12 hydro static test.

2000 psid, primary to secondary; 800 13 psid, the otner direction.

14 If tha t is okay, if you don't fino anything that is, you don't have 15 significant at that point in time lo an indication of any continuing degradation -- then we think 17 it would be a ppropriate for him to go another 30 eff ective lo f ull power days, for a total of 60 ef f ective full power 19 days.

20 At tha t point, we think it is appropriate t ha t the 21 plant be shut down and perf orm a thorough ecdy current 22 testing program, " thorough" being defined as something yet 23 to oe worked out by the staff to the staf f's sa ti sf ac tion.

24 COMMISSIONdR AHEARNE:

Why shouldn't it be 100 25 acccent?

I527 073

42 32 04 02 KapdWH I

"R. EISEiHui:

ihere is no reason it shouicn't 2

be.

?le are thinking, maybe -- we wan t to look more at the 3

t ec nnique s.

I am not necessarily happy witn just saying 4

"100 percent in s pe c ti on. "

5 Col.U.iI SS ION ER r:EhNEJY:

W ha t is the ef f ect on that o

se t of a ssumptions if, in fact, as they said they did and 7

would in the uemorandum le tter of November 23rd, operate at o

63 percent f ull power?

9 MR. EIS ENdUT:

I con't know wha t the effect would 10 be of going r.o 63 percent power.

That is why we tied it to 11 30 effective full power day s.

It means instead of 30 12 calendar cays, it would be 3d days or something like that.

13 And in fact, the si tuation is, in fact -- it arrests the 14 situation.

Great.

But I can't take any comfort in the la fact that it will, because we don't have any real, firm, lo quantitative hanale on what the 83 percent power will do at 17 557 degrees F.

le So things, so far as that is set -- which is the 19 first item on here -- tell us that we think over the short 20 period of time -

"short" being defined as o0 ef f ec tive full 21 power cays -- we don't expect to see any major leakage.

22 The next item is tha t the problem is all in -- is 23 in crevice a ttack.

It is crevice intergranular a ttack 24 inside the tubeshee t.

And the fact that it's confined in 25 the tubesheet anc we have never seen intergranular attack i527 074

3a d4 03 43 k a pa' d H I

above that area, we have never seen circumf erential 2

cracking, recognizing that the maximum theore tical leakage 3

is some thing le ss than 10 gpm -- I believe it is seven gpm 4

-- all of those things taken together help to give you 5

another layer of confidence, that even if leaks shoulu o

develop, or even if any kind of transient situa tion or 7

accident situation should develop, it would not be complicated by this problem over the short period of time.

e v

Thi rd, we think to give us additional confort 10 that is, additional confidence, that even if something 11 shoulu happen, we are discu ssing f or some time the lowering 12 of the reactor primary coolant inventory limits.

He 13 prasently has a parameter that is 162 over E-bar microcurie s 14 per gram wholebody limit.

It is tied into the wholebody 15 dose.

The standard tech spec is 100 over E-bar.

lo It gives you cor fidence that even if you have a 17 leakage, t he total amount of radioactivity in the primary 13 system that can leak out should be reduced by a sizeable 19 fraction.

20 Also, we are looking for, and have been discussing 21 a one microcurie per gram of iodine-131 equivalent for 22 thyroid dose in tne same way.

The re is no tech spec and the 23 older. Vintage plan ts don't have it.

24 COMMISSIONEH AHEARNE:

Changing that would 25 translate to what in terms of operation of the plan t ?

I527 075

32 d4 04 44 Ka oB'.hi i

MR. EISEi1Hui:

ilo t t.a t muc h.

We think the 2

numbers are consiaerably below that, anyway.

3 It give s you assurance that during this period of 4

time there is not going to be a situation where the primary b

coolant activity goes up.

If it goes above t ha t limit, o

appropriate action has to be taken.

7 COMMISS10iiEd AHEARilEs You are saying, as f ar as o

you know v

MR. CASE:

This would not restrict operation.

10 COMISSIO.4Ed AHEAR;1Es It wouldn't af f e ct 11 operation?

12 MR. EISENHUT Yes, that is why it is not the 13 first main item.

It is saying these are some confort 14 factors to give you more confidence.

It is the "even if" 16 a pproac h, the bottom line being the confidence you nave in lo the first place is as good as you would have on other 17 plants.

le We are also in a more meaningf ul way -- the 19 utility has proposed and has been discussing some lower 20 limits for shutdown and plugging the tubes in the plant.

21 The primary coolant tech spec is.35 gallons per minute --

22 or it is actually 500 gallons per day, which equates to 23 about. 35 g pm.

Tha t is the same kino of limit I recall, on 24 that orcer, that is on the other severely oegradea plants.

2S This utility has proposed, actually, to impose even on 1527 076

32 6 05 45 ka pErld I

i tsel f some lower limits.

2 If he had a sudcen leak that occurred at.1 3

gallons per minute, he would, in fact, shut down and plug 4

the tubes.

If he haa any leaker, any leakage of the.17 o

gallons per minute or greater, he would shut down and clug o

the tubes.

7 CoMMI5S10i1ER KdpNEd(:

.I7.

o MR. EISENHUT: (.17gpm.

And if you have a rate of v

c hange of.01 gallons per;' minute per day, in that range, S.

10 between

.I and.1 7,.01 g pm per day, he would do the same il thing.

That is a very, very tight tech spec.

He has, 12 however, mea sured down to several gallons per day, so it is 13 well within the de tec table limit.

14 COMMISS10.4ER BR AUFORD:

When you say " tech spec,"

15 will you treat it as a tech spec?

Io MR. EISENHuf:

Administratively, how we treat all 17 of these, I will get to in Just a second.

la These are all proposals f rom the licensee.

We are 19 working -- his pro posal is that he scrild go in and plug the 20 defective tube.

We are saying one more thing that we are 21 discu ssing wi tn him, and that is we think if any leak 22 develops that gets up to.35 gpm, that is ac tua lly to the 23 tech spec threshold, or about.347, or 500 gallons per day, 24 we believe the plant ought to be not only shut down and plug x

25 the tubes, but at that time it should undergo an eddy 1527 077

4e 32 04 C6 k a p3'. n I

current test.

That is, it moves the 60 ef f ective full cower 2

day ins, ec tion up to that point in time.

3 CO,h4I 5b IONEH AHE AH.lE s Lo you have a limiting 4

nuacer of pluggea tubes?

D MR. EISENHUT:

The limiting number of plugged o

tuces -- this plant has pro po sed, and has sent in a request 7

to get authorizec, for 18 perc en t plugged tubes.

Actually, plants can't go up to the oroer -- durry is up to 26 o

most y

percent plugged. There is a simple rule of thumb t ha t says 10 there is a six degree penalty for each percent of tubes 11 plugged, on peak clad temperature.

This plant is not ceak 12 clad tempera ture-limited.

It was then to slightly over 2000 13 degrees F.

Therefore, tney have a long wa'.

to go.

I 14 believe at 18 percent plug they would be up on the order of 15 2130.

16 VOI CE:

2113.

17 MR. EISENHUT:

So if you take the delta of 180 --

Io COMMISSI0 DER BRADFORD:

Why did you originally Iv limit it to 10 percent?

20 MR. EISENHuT:

The original acplications are zero 21 percent.

That is the way the evaluation is done in the 22 first place.

The real yardstick, the real measure you put 23 on plants, is they must opera te in a mode that keeps them 24 under 22 degrees F.

The plug-in number is only an input 25 parameter to a computer code, and that is a pproved by the 1527 078

32 04 07 47 kapohd I

s ta t f.

2 The a cproach we take is that tne operating 3

parameters tnat tne plant operates under must, wnen fit into 4

an a pproved box, g'ie you a number under 22 degrees F, and S

taey must do that calculation.

It is not a tech soec limit o

or a requirement per se.

7 COMMISSIONER BRAUFORD:

But if 18 percent f it into o

t ha t bo x, t ha t gi ve s yo u --

Y MR. EISENHuT:

S till some thing unoer --

10 COMMISSIONER BRADFORD:

Why wouldn' t they say 18 11 percent in tne first place?

12 MR. EIS ENHu f:

The utility likes to have the extra 13 margin of operating at 2200 degrees F peak clad temperature, 14 so the next time a problem is associa ted wi th flow blockage

\\

it was not a limit.

16 lo MR. CASE:

I t wa s an assumption made in the FSAR 17 a naly si s.

The assumption made was 10 percent.

16 MR. EISEdHUT It would be prudent if you were a 19 licensee -- I would think if my evaluation that I could 20 operate the plant in the modes I wanted to operate, and show 21 tha t my peak clad temperature is 2000, I would want to do 22 it.

Then, if the next time a small glitch comes along, of 23 whether it is a clad swelling that gives me a new blockage, 24 I have already got the margin there.

I am not going to be 2b

.ieverely impac ted.

You have some margin.

1527 079

4e se C4 Oc kapM!d i

The pla n t that is at 2200 degrees, if he would --

2 and this parameter comes up quite of ten, if a plant comes in 3

and says, "My evaluation is based on the 10 percent 4

plugging," the first thing people look at i s, w ha t is the 5

calculated peak clad temperature?

10 percent clugging gives 6

you 22CO.

7 The first reaction of people is, when you see a minor perturbation, a change in the ECCS evalua tion model --

o "My heavens!

Thi s plan t ha s a 10 percent peak clau 10 temperature penalty and they are over 2200 degrees."

11 T ne truth of the matter is the plant is not a 10 12 percent, anyway.

It takes a simple calculation to back it 13 down ano show that there is a sufficient macgin.

It is not 14 a saf ety sense, it is a calculational sense.

15 C014MISSIONER GILINSKY :

Does that bring you to the 16 end of your presentation?

17 MR. EIS ENHUT A couple of other things I would Id like to put on.

19 We are also saying that any two leaks in 20 days, 20 the plan t should shut down for an eddy current test 21 inspection, and go through eddy current testing.

22 COMMISSIONER AHEARNE:

A leak of any size?

23 MR. EISENHUT:

Any icentified leak. That is 24 similar to what we used in the dented plants.

If you see 25 any tube leaks in 20 days, any 20-day period, it should be 1527 080

av 32 04 Gy kapoNn i

assigned.

2 The other things simoly over here is, under 3

a cc iden t concitions we don't believe even the degraded 4

tubes, if they were existing in the plant, would ructure to 5

cause any significant problem.

We also believe that -- the o

licensee is consioering longer-t.9rm solutions.

He has told 7

me, as late as last night, that he is considering such options as re tubing or steam generator replacement down the o

v road.

10 And he is studying those options right now.

Some 11 extra actions wnich we are discussing with the licensee is 12 that in August -- the ' rea son tha t it appears that there are 13 two leaks was tnat the wrong tubes were plugged.

We are 14 asking for an extra eneck on the OA approach for plugging.

15 This happened at other plants, where plugs weren't detonated to or wrong tubes were plugged.

17 W ha t they oc is go in and take a photograph of the Ib bottom of the su pport: pla te so you can see what tubes are IV pluggea.

Then you can do a cro ss-check, a correlation on 20 paper,. counting the rows and tubes and checking to make sure 21 that all of the a ppropriate tubes are plugged.

22

'We are rechecking the plant to be sure that they 23 have an adequate procedure to handle any steam generator 24 tube ruptures tha t they develop, emergency procedure.

The 25 plant had a rupture, you recall, in 1975.

The plant 1527 081

32.04 10 50 k a po'c!n I

response was very good, to tnat.

They did a good job of

'ie have no rea son to suspect there is, 2

responding to it.

3 but we want tnat recheckeo.

But since 19'i3 nas been a long 4

time ago, we want all of the operators to be re-alerted that 5

you're operating with steam generators that you should not

.i have as much confidence in as before, and you should all be 7

very, very well aware of this proceaure for taking, care of o

the situation.

(,

And that is our a pproach.

It is an overa,ll v

V 10 defense, in-de pth approach, covering a multi-numbered layer 11 of things, administratively, how we get f rom where -we are 12 today to get these requiremen ts into place, or get this 13 agreement into place.

The vast ma jority of the se were 14 pro posed by the licensee in his overall package. We have 15 been discussing witn him his proposal.

Administratively we 16 haven't come down to deciae wha t vehicle to put it in place.

17 COMMISSIONER KENNEDY :

Is a confirmatory order --

id MR. CASE:

That i s one way.

IV COMMISSIONER GILINSKY:

We could hold other 20 questions until we have heard the other presentations.

Can 21 we do t ha t?

Is tha t acce ptable?

22 Col4MISSIONER AHEARNE:

I wanted to ask Mr. Bickwit 23 a question.

24 COMMISSIONER GILINSKY:

Go ahead.

25 COMMISSIONER AHEARNE:

There may be some people x

1527 082

32 04 11 Si kapuVIH I

here -- it might even include myself -- w ho a re n ' t 2

completely clear that t he proc e ss we have underway is -- the 3

m ee ting started with Ed mentioning that they had a certain 4

intention wi th respec t to the 2.206.

I thought it might 5

help at least some peoole if General Counsel briefly o

described -- what is the process we have?

7 COMMISSIONER GILINSKY:

Why don't you do tha t?

o MR. BICc3IT:

2.206 pe ti tions are, under our v

rules. rilea with the staff.

They are petitions for 10 enforcement actions.

The Commission, on its ow.i mo tion, may 11 take review of a staf f decision, with respect to 2.2C6 12 pe ti tion.

13 This particular petition was filed no t wi th tne 14 s taf f but wi th the Commission.

Part of the rationale for a s

15 decision to file with the Commission was the neec to get a lo quick decision from some element of this body, given that 17 the licensee was pre pared to start up shortly.

Io The Commi ssion, mindf ul of that motivation on the 19 part of the petitioner, cecided to ref er the pe ti tion to the 20 staf f to be treated as a 2.206, but to depart f rom the 21 normal procecure under wrdch the staff woula reach a 22 decision on the 2.200 followed by review of the Commi ssion 23 if i t c ho se, and decided to collapse that particular way of 24 proc eeding, so that the staff would advise the Commission on 25 the tack it was likely to take on the 2.206, and the 1527 083

132 04 12 62 kapc1h I

Commission could then decide whether to step into the 2

ma tter, if it disagreed with the tack the staf f was taking.

3 The options available to the Commission, if it 4

aces cisagree with the staf f action, would be to come in 2:d 5

i ssue its own order-o COMMISSIOJEd AHEARHE:

Thank you.

7 COMMISSIONER GILIN3KY:

Mr. Bradford.

6 CD:(MISSIONER BRADFORD:

You talked a little y

earlier about tne adminstrative framework of this.

now 10 enforceable it it?

The right way to regaro this, as you see 11 it, is a voluntary package by the licensee?

Or you are 12 i ssuing orders, you are making these license conditions?

13 MR. CASE:

Right now it is a voluntary package by 14 the licensee.

And we are still discussing with him what he 15 is going to volunteer.

The alternative, then, is to treat to it as a voluntary package and approve the opera tion under 17 those conditions, or the next step would be a conformatory 16 o rder ;

that is, confirm his volunteering by order.

lY And another option was just to orcer him to do 20 these things without waiting for him to volunteer.

T ho se 21 are the principal options.

22 MR. SHAPAR:

An d to treat it as an amendment, that 23 is another option.

Those are, I think, the four principal 24 options.

25 COMMISSIONER GILINSKY :

Could we now hear from 1527 084

32 C4 13 63 Kapd.hi i

Misconsin Electric Power Companyi 2

COl4MISSIOJER BR AUFORU One o ther questions it we 3

treat it as voluntary, and if the licensee changes his mind, 4

what happens?

5 MR. CASE:

Then you can issue en order.

o MR. EISENHUT I think what we would do -- it 7

wouldn't be just a voluntary thing.

We would send a letter, 6

as a minimum, ano say, "With the understanding that these v

are the conditions you are operating the plant under, here l>

I 10 is our evalua tion."

Our evaluation would be contingent 11 upon those conditions.

12 MR. SHAPAR:

That is the mode we are under now, 13 and they are shut down in an informal manner, without any 14 formal oraer.

Any time you have that kind of an informal 15 situa tion, a commitment is broken, the circumstances change lo and then you can step in witn an orcer.

17 COMMISSIONER GILINSKY:

Can we now hear from a lo representative of the licensee?

We went over our allotted 19 time with the staff, largely because the commissioners asked 20 quite a few questions.

I think we will make the same 21 aajustments in the case of the licensee and petitioner.

22 23 24 25 1527 085

54 32.05 31 ashd.i I

(4. CHA.hla ?F :

I wasn't coing to ask for : qual time, out it is hard to resist tnat invitation.

19 nava 3

five or six points that I would like to ma ke.

4

.1/ name is Gersla Charnoff. I aa with the law firm of a

Shaw, Pittman, Potts, and Trowbridge.

And with me nere a

today is Mr. 5y 3erstein, wno is the executive vice

/

Jresident of.lisconsin Electric and is here to answer an/

i tecanical questions you might have.

/

Ar. 3erstein is in the secona row, the distinguished gray 1J hairid looking man -- the distinguished applies to the gray 11 ratner than to the man.

la The six points that I would like to aake oriefly, if I la can, is, on3, that it seems to me, as I was listening to 14

?lr. Eisenhut's presentation is that it is significant tnat 15 both the staff and itisconsin Electric agree that the unit la can go oack into service without enaangering the cualic I,

health ana saf ety.

la If tnere were any contention between us, it woulJ go only 1/

to tne frequency and intensity of tne surveillance 23 recuirements.

21 As you know, from the letter that you have bef ore you 22 f rom Mr. Berstein and Mr. Denton, we, too, have already 23 started an intensified surveillance orogram.

'/le hav e 24 conducted the hydro tests at 800 and at 2000 pounds that 2;

were descrioed. And the tubes have already passed that 1527 086

55 32 05 02 gsn3W l

test.

2 le have also agreed that we would propose to conauct a a

numoer of otner tests as time goes oy in the 30-day interval I

and anotner interval thereaf ter.

o lie haa r?ad to us just prior to the meeting the 5 or /

a condi tions that the staff would like to give them added confidence.

And while we taink that it is a little more 3

onerous, perhaps, than is nacessary, we will aoree to do y

that.

1)

We would commit unequivo a lly that we will do that and we 11 will confirm that in writing later today.

12 COMMISSIOJER AHEAdNE:

You say that it is a little 13 more onerous in tnis area.

putting asiae tne quicoling I?

aoout some cegree of being onerous is necessary, to Nhich I;

don't you feel are necessary?

la JR. CHARdOFF de have proposed some of the la surveillanca conditions.

I think it is on page 7 or 8 of Id l.tr. Berstein's letter to Mr. Denton.

We have proposed to is pick up in 30 days a 2000 pound test primary to secdondary.

20 fne staff is asking for, in addition to that, another 2!

secondary to primary test which we nave just run and 22 completed.

23 fo do that, that requires going down to cold condition 24 and more time than would be necessary in our judgment 2a because we nave just run that.

s 1527 087

56 32 05 33 gsadd i

It seems to me tnat is the natura of the diff erence d

cet.ieen us.

Je are preparea to provide that additional a

confidence oy coing that se:ond test as well.

i I shoula point out that, as you 2now, from our filings in tnis case, and we filed a raply to the petition of tae a

a decade of tn3 environmental decade ye sterday, so I won't no 7

into that 11 any Jetail, we have from tae outset of this 3

condition end actually over the years '<ept the sta ff fully 9

informed of the conditions of tubes.

IJ Aqd inde3d, we had a meeting with th? St3ff serly li

.lov3mber before the petition was filed oy tae decada to 14 ori?f the staff as to what was going on and what we proposej l3 to do.

i.

And then, of course, there was a second neeting af ter the la decaae's petition was suomitted to the staff.

la In our Vlaw, we think that the p3tition should c3 dentea, il as 4r. Case indicat?d is th3 Staff's intention.

That 13 petition as<s for a continu3d shutdown of the facility.

19 It also as:i pluggid?

14

'A R. CHAAN3FF:

I think in one steam generator is 16 it 1.1 and the other it is 9.8.

19 COT 4ISS I0 DER AHEAANE:

Around 9 to 10 perce nt.

2)

MR. CHARN0FF:

Right.

21 CO MMISSIONER AHEAdNE:

Ana if you are requesting 22 going to around 13 percent as tne limit, that if the rata of 23 the last two months continues, you would have to ena up 24 plugging th3m at the rate of close to 2 percent a month.

25 M2. CHARN0FF:

If you take a straight line from 1527 090

59 32,06 36 gsh3.d I

that, I tnink one of the important : harts tnat Jr. Eisennut presented snowea tnat different time histories of tne units, e

3 there were aiff erent kinds of proolems with the steam 4

gen 3rator and they showea arr e s t.

3 a

031.4ISS IO.iER AMEA.iiiE But part of that was we are now moving into a different mode of croolem.

I was just a

/

wonda ring il you foresee in four or five months f acing a 3

question of neving reached tnat limit, then what to do?

v

'4 2. C H A R J a F F As I think 'Ar. Case indicatea, the IJ 18 percent is not a limit.

It was an assumption goinc into li the dCCS anelysis.

le COMMISSIONER AHEARNE:

That is the old assumption, 13 whi:n was 10 percent.

14 4R. CHARN0F.::

The new assumption is in effect 15 18.

The analysis was based upon that.

And the reason wny la we did IS, frankly, was that it was the kind of anelysis I,

that coula ce done much more quickly by Westinghouse et 18 13 than at some higher number.

But we are aware that that 19 numoe r has oeen done and evaluated elsewhere.

20 Theoretically, we can go further.

21 We do know that it is either Surry or Turkey Point or 22 cotn that have been looked at in terms of 25 to 30 percent 23 of tne tubes oeing plugged, and they can still meet the 2003 24 crite ria.

25 CO MMISSIONER AHEAdNE:

Let's say it goes to 30,

\\521 D4\\

32 05 J7 60 gsn 3?l 1

then.

20 percent ac 2 percant a month.

2

..W. CH A2;ia.:F :

If your question is what are we a

loo <ing for --

4 CO'W ISS IO.lER AHEA3.iE:

I didn't get a sense from a

reading the material that I have read that there is a claar 5

understanding of what is caJsing the proclam ana, therefore, a clear understanJing of what steos are going to prevent the 6

proolem from continuing.

v

13. CHARN0FF

?le have offerea so.n? proposal, one 13 of #hich is temperature reduc tion, whicn we think will o?

Il significant in raaucing the trena that we have seen the last 12 few months.

13 de are also looking, at Mr. Eisenhut indicatea, at 1+

cac.c-up altarnatives shoula we continue to see this 13 happening.

And the back-up alternatives consist of retuoing la or sleeving or replacing a portion, or all of those Il generators.

19 Indeed, we just completea two aays of hearings cefore the 19 puolic service commission of disconsin, where we indicataa 2) thase are tne things that we are looking at.

.le don't have 21 any definitive position on either the feasioility or the 22 economics -- or which is tha most ettrac tive of those 23 alternatives or the time-frames.

24 But clearly, we are going to be looking at that over the 25 near-term in order to arriva at some back-up solution.

1527 092

61 32,05 38 gsh0W i

inis is Jrimarily at this point looked at, I tnin%, oy 4

the utility, not as a safet/ proolem, but rather in terms of 3

availacilit/ of tne unit.

4

'*l e are not int 3 rested in havina this unit go down repatitively for either failure to coserve the leak rate or a

a for testing.

Ca ?4MISS IO.iER GI LI.lSKY:

fnank you, Nould the 4

3 repre sentatives of /lisconsin's Environmental Decede please come forward?

1)

'13. F AL.< a My nama is Kataleen Fal%.

I am li attorney for Wisconsin's Environmental Decade, whicn is a 12 state-wide citizens group in Wisconsin that has many memoers 13 that live in the vicinity of the Point Beach plant.

14 W3 thank you for inviting us to aopear oefore you today.

la fne main point I would like to leave you with today is 16 tnis afternoon, since quartar to 3:00, we haven't yet heard ie one word aoout the issue that we raised in our petition.

13 As long ago as 19'i5, the very prestigious American 19 Physical Society wro as "It was the consensus of the group 23 that steam generator tuce failure during a severe LOCA coula 21 occur frequently.

Moreover, it appears that ruptur? of a 24 f ew tubes on the order of 1 to 10, dumping secondary steam 23 into the depressurized primary side of the reactor system, 24 could exasperate steam oinaing problems and induce 25 essentially uncoolaole conditions in the course of a LOCA."

1527 093

62 32, 05.

gsnBW Joaody to this day has aadressed that proolem.

CT UIS3IOJER GILIJ5KY:

aasn't tnat tne questian 3

that I was as41ng Mr. Eisennut?

?

M5. ?AL.<a That is a different ouestion.

You asked the question, out dian't get an answer.

What you cot

]

wa.t we don't think that is ever coing to occur, not that we looted at it to see what will happen if it occurs.

i COMMISSIOJER GILIWSKY:

I undarstood nim to sa/

/

that in dealing with flaws anJ possiole creaks in tne bottom 13 plate, the situation was differann.

The numoer of tuoes 11 that would pose a danger would oe rather larger.

12 4?. CASE:

Approximately 200.

13

~.i3.

FAL.<* Can anyoody here today prove that there 14 will be no rupture of a tube above the tube plate?

The la people of disconsin living near that plant want to know the is ans,ver to tnat question.

And tha t i s i reasonaole question il to expect an answer to.

13 ao oooy knows that et.

We want to find out, de want to,

19 get the experts together to hash over that question.

20 It hasn't oeen hashed over yet, de naven't heard a 21 response yet either by the company or by the commission 22 staff to that proolem.

And it is a real one.

23

.1 hat have we heard in response to our petition?

de have 24 heard a new promise, a new plea, a new of fer, a new 25 suggestion oy the company, not of how to deal with the 1527 094

63 32 05 lO gsnd.

I proolem oecluse they don't know how to Jeal with the a

proolem.

'th can' t concede that tne tube f ailure rate is 3

going to decrease.

They don' t '<now why.

4 doint Beeca right now is experiencing the highest tuo?

Jegradation rate proolem in tne country.

a 3

COT.IISSIO:iER GILIN5KY:

Can I just stop you for a

/

mom nt?

3

15. FALK Sure.

/

CO T.IISSIO lER GILI.lSXY:

In eff ect, it seems to me IJ that you are disputing the analysis of the source of these la flaws and failures as it was represented principall/, or 12 almost entirely now within this lower region.

13 (ou seem to oe saying that you aon't draw a aistinction 14 cetween that region and the other region.

la MS. FALX:

There may be a very legitimate la distinction to draw, but on whose. promise, whose f aith, on ie whose competence snould we rely?

13 JEPCO, in the history of this plant, has not built in a 1>

lot o f cecisions on which the people around that plant can 2]

rel/.

And let me give you an example on this proolem.

As 21 f ar oack es 1965, at the time of the licensing, we do not 22 anticipate that tuce thinning and denting problems would 23 aevelop.

24 Then when proolems did start -- and.testinghouse 25 suggested that we use the phospnate treatment to preclude 1527 095

32 00 l'

64 gsh3M i

the s econoary water chemistry proolem.

2 In

't2, they found out tnat that wasn't vorking oscause 3

there was danting occurring.

4 30 what aid nestinghouse suggest?

Keep using phosphates, a

increase the phosphate.

a fnat canoage, that promise at that time, 7 years ago, turneo out to be che exact worst thing tnat they shoula nave a

j J

d{

done.

Then what happened after that, wnen tney finally

/i realized that the chospnates were increas ing the proolem,

'U IJ \\

they said, change to AVT without cothering to snut aown the la,

plant, without figuring out the proolem, without fi gu ring 12 out the solution.

Let's try something else.

13 Ne don't know what, but le t's try something.

14 faat didn' t work.

la In 1979 now, we aave in the month of August 97 tuces that 15 nad to oe replaced.

6 weeks later, af ter they saia that il the/ did 103 percent testing of all of the problem area 13 tuoss, 145 tuces had to be replaced.

1/

The confidence that you asked the people of Wisconsin 2]

near that plant to have with this company is just not 21 there.

The f acts don't show it is there.

24 They want proof that nothing is going to happen.

That's 23 all.

They are not saying the company is bad people.

They 24 are saying they want experts to sit down and look at the 22 proolem they are worried about and not just ask the company s

1527 096

32 Oo 12 65 gsn3M i

to caly on their confidence.

2 5/en tha commission step, Mr. Eisenhut haa to concede s

that they just don't have tne confiaence in the eday current a

4 testing that they snould have, tnat they nesa to nave.

o ine many caveats that the staff is sugges ting they put on 5

the license of the company as a recognition that tnere is a problem and they Jon't know what to do acout it.

a 9

C:) '.RI SS I O.lER AHEA.L9 E:

fhen you say proof, could you explain what you mean?

/

10

45. FALK I mean the experts such as the American 4

e 11 Physical So:iety, the Union of Concernea Scientists, W

12 ressected experts wno say tnat there is a potentiil proolem 13 that has to oe looked r -

go through the necessary 14 f act-finding, not tais informal kina of negotiation and to aosolute panic that has been going on the past week.

Io You can't make taese decisions af ter having a 1/

Thanksgiving dinner when you.

f amily wants you at home and 19 you should oe here.

A week's work is not just enough to 1/

answer the question that has been posed five years ago ano 2J still, everyoody agrees has not been resolved.

21 faey want the sworn testimony.

Chey want to be aole to 22 cross-examine the witnesses who are so confident the next 23 oandaid will work when it hasn't oefore.

24 2a 1527 097

CR 8532 66 WHITLOCK t-6 mte 1 1

They want the opportunity to get to the facts.

2 COMMISSIONER AHEARNE:

When you say that you want 3

proof that this would be safe, by proof do you mean agreement 4

of individuals?

You say, get together with the experts.

Are 5

you talking about some kind of experimental proof?

6 MS. FALK:

I would imagine that would include both.

7 Don' t experiment with an ongoing plant knowing that there 8

could be a problem.

That is not a reasonable scenario.

Those 9

are dreams and wishes and hopes.

The people living near that 10 plant want something more than dreams, wishes and hopes.

They II hope fervently that WEPCO would be right.

But they want I2 Mr. Eisenhut to be able to come to their house and say, I am 13 confident that eddy current testing works.

He can't say that 14 right now, because the scenario we have given and which he If agrees to shows it isn't working.

16 It isn't showing where the failures are.

It is not 17 an adequate testing mechanism.

18 COMMISSIONER AHEARNE:

Do you see that there is 19 any -- you point out significant differences in new tubes 20 that had to be plugged two weeks after they were set.

The 21 staff had made the argument that a large part of that was 22 due to changing, three types of changes:

personnel doing the 23 tests, the type of equipment used, and the criteria for the 24 test.

co Federal Reporters, Inc.

25 MS. PALK:

What are the criteria fut the test?

How 1527 098

mte 2 67 I

can the criteria -- like if you are going to do it once a 2

month or every two years?

3 COMMISSIONER AHEARNE:

The criteria are -- that you 4

plug at 40 percent or you plug on defects.

5 MS. FALK:

That is not the issue.

What happens if, 6

even if you did, under your scenaric, plug 40 percent, what 7

happens with the 'nes you don't catch?

That's the issue.

8 COMMISSIONER AHEARNE:

I am asking the question:

9 You had made the point that they said they did 100 percent 10 tests, and two months later they had to plug 145 tubes.

I II am asking what way do you get to the fact that the cacond 12 test, two months later, was based with three differences from 13 the first set of tests?

14 MS. FALK:

I can only believe Mr. Eisenhut, and he 15 says he doesn't know.

I don't know.

Nobody knows.

That's 16 the point.

17 Your questions that you have all asked here are 18 excellent, and I don't think you have gotten answers that 19 you would rest comfortably with.

You haven't gotten answers 20 to a lot of questions, the same ones that we have been asking.

21 All we want are some answers.

22 COMMISSIONER GILINSKY:

Are you in effect saying 23 that you believe the assumptions the staff is making are not 24 sufficiently conservative and don't, therefore, provide co-Federal Repo,ters, Inc.

25 sufficient protection?

1527 099

mte 3 68 I

MS. FALK:

If I understand your question correctly, 2

the assumption that I think the staff is working on is that 3

the eddy current testing will work.

Even though we don't 4

think it maybe is working, it will work in the future.

Just 5

do it more of ten, do it for mor e tubes, et cetera.

I think 6

their own admissions and statements today are saying that 7

assumption is no longer true.

The assuruption for keeping 8

these plants open with the current leakage problem is that, 9

eddy current testing ic going to predict everything before 10 it happens.

II Now they are coming to you and saying today, we are 12 not sure that assumption is any longer true.

13 COMMISSIONER GILINSKY:

Let's see.

Let's see if I Id understand correctly.

Aren't they requiring certain criteria 15 in interpreting the test that would then take into account I0 the uncertainty in-the result?

I7 MS. FALK:

It will be too late. Given that nobody 18 has looked at the problem yet of the LOCA, that will be too I9 late.

Once the LOCA situation has occurred, if it is a 20 reesonable scenario, as many experts say, then at tL.: point 21 it will be too late.

22 COMMISSIONER GILINSKY:

They are taking into account the possibility of a LOCA.

They were making the point, which 23 24 I take you to be disputing, that, given that the cracks would co-F5eral Reporters, Inc.

25 occur within the region of the plate, the number of defective 1527 100

69 te 4' I

tubes that one can stand is larger than if the cracks were 2

in some higher region.

3 MS. FALK:

On our petition we showed that there 4

is reason to doubt that that scenario will be true, and when 5

nobody here can promise me, given the enormous rate of tube 6

degradation right now,,that that will continue to be true in 1

7 the future, that is resting on real shaky ground.

8 COMMISSIONES$GILINSKY:

You are in fact di~sputing

\\.

T 9

the analysis that was on one of the charts, which allocated 10 the three causes of tube degradation.

The suggestion was that 11 two of them are no longer of concern and the one that remained 12 was in fact the one that left -- that produced cracks in the 13 bottom plate region.

14 MS. FALK:

Right.

15 COMMISSIONER GILINSKY:

Is it right that you are 16 disputing that analysis?

17 MS. FALK:

Yes.

That kind of dispute is exactly I8 what we need facts on.

And I think it is asking an awful 19 lot of you four.right now to have to make a decision of this 20 magnitude after a five-day analysis on everybody's part.

It 21 just isn't sufficient.

22 COMMISSIONER KENNEDY:

Have you participated in 23 that analysis, Ms. Falk?

24 MS. FALK:

We have not been asked by anybody what

-Fouerst Reporters, Inc.

25 our opinion is on the company's reducing pressure or reducing 1527 101

m t e 5' 70 I

tempert ture or testing every three months instead of two years, 2

That has all been done informally, and certainly that is no.

3 objectionable to the people that would like to have an input 4

in that process.

5 COMMISSIONER BRADFORD:

What is your opinion on 6

those measures?

You obviously think they are insufficient.

7 But do you have more specific criticisms on them?

8 MS. FALK:

From what I understand, the reducing 9

pressure and reducing temperature, nobody here, including the 10 company, knows if that is going to cure the problem.

From II what I have heard from people that advise me, it is that there 12 is reason to believe it is not going to cure the problem.

13 That is what we have to look at.

Id our purpose here today was to ask you, to beg you,.

15 to have that ki.nd of necessary fact-finding.

These are I0 citizens that don't have, you know, the in put or the 17 opportunity to call on some very good people in this agency 18 and say, hey, what is this about.

And it seems to me that I9 these people in your agency are saying, we don't know yet 20 what it is about.

21 This whole issue comes down to the company has said that, in its submissions to the Wisconsin Public Service 22 23 Commission, that it is, quote, " reasonable probable," and 24 they are planning on replacing the steam generator, taking co-Federal Floporters, Inc.

25 something equally as drastic a measure in the next year and a 1527 102

71 mte 6 1

half or two.

This should be before you, not as to whether to 2

shut the plant down.

That is not the sole issue.

The issue 3

is, given that it is likely that this major drastic step is 4

going to be taken in the next year and a half, how should we 5

proceed between now and then.

6 The balance that you have got to make is, is the 7

risk presented by keeping that plant open one year and costing 8

WEPCO maybe four percent in increase in charges for that one 9

year, balanced by the risk it is causing those people in the 10 vicinity of the plant?

That is a different scenario than 11 if the company wasn't now cenceding that they have to eventuallt 12 replace that steam generator.

It is a very different balancing.

13 It is a year and a half we are talking about.

14 We submit -- and I will conclude on this -- that 15 the reasonable way to proceed is to get answers to questions 16 first.

My God, they deserve an answer to questions first, 17 not experimenting with that plant.

18 We would be glad to answer any questions you have.

19 If they are very technical questions or financial things, I 20 would like to defer to my colleague Peter Anderson, who did 21 financial things in the submissions on the cost to the company 22 of keeping it shut down in the next year and a half.

But for 23 other highly technical expert questions, please commence the 24 kind of fact-finding that is necessary.

z-Federal Reporten, Inc.

25 COMMISSIONER AHEARNE:

Could you say a few b, re 1527 l

72 mte 7 I

words on this technical fact-finding process that you had in 2

mind?

3 MS. FALK:

It is not so much different from what 1 4

just heard Mr. Eisenhut say in part.

That is, they would like 5

to do some analysis of the eddy current testing.

And the 6

first time I have heard that they are doing some kind of 7

experimentation on the Oak Creek situation -- that is wonderfuls 8

but it still doesn' t answer the question, is it significant 9

enough to keep the plant open while we are doing the testing?

10 And that is only one aspect of the testing.

11 For example, you don't have any technical specs or 12 regulations or guidance that I know of on how serious the 13 rate of degradation is.

How significant is a 10 percent or 14 18 percent total amount of tube failures?

We don't have 15 answers, not even guidance.

They said their rate of degrada-16 tion problem they are experiencing right now is unprecedented.

17 We need some guidance, some technical specs on those things.

18 COMMISSIONER BRADFORD:

Could you be a little more 19 specific as to what it is that you feel in the staff's 20 method of presentation can lead to a serious accident?

That 21 is,.my understanding of it is that they are proposing to 22 permit restart, but under considerations based on other early 23 warnings, would result in the shutting back down, the plugging 24 of that, the tubes, the tubes they are shutting back down, co-Federal Reporters, Inc.

25 and not reopening.

1527 104

mte 8 73 1

Is there -- have they missed something in the early 2

warning indications?

3 MS. FALK:

Mr. Eisenhut would be the better one to 4

ask that.

I think somebody asked that before of him:

What 5

confidence do you have that reducing pressure and temperature 6

is going to make a difference in the rate of tube degradation?

7 And he said -- and Mr. Eisenhut car repeat it again -- frankly, 8

he doesn't think there is much reason to have confidence in 9

that.

10 COMMISSIONER BRADFORD:

It is not so much solving 11 the problem of tube degradation as the fact, if these measures 12 don't solve the problem, there are then several indications 13 in terms of additional leak rates and what have you, that 14 will trigger --

15 MS. FALK:

Trigger what?

What guidance --

16 COMMISSIONER BRADFORD:

The shutdown for plugging.

17 MS. FALK:

Are there any rules or specs that say 18 that?

19 COMMISSIONER BRADFORD:

I thought there were.

20 COMMISSIONER KENNEDY:

As I understood it -- and 21 maybe I am misunderstanding what you are now saying -- as I s.

22 understood it, the company had indicated -- Mr. Eisenhut had 23 indicated that the ccmpany hcd -- was agreeing to a series 1

24 of conditions which would have to be undertaken as a conditic:a co-Federal Reporters, Inc.

25 for continued -- or beginning operation of the plant.

Those 1527 105

.~

74 mte 9 I

included a series of points at which the plant would require 2

shutting down.

3 COMMISSIONER BRADFORD:

The company's proposal is 4

at page 6 of their November 23rd --

5 COMMISSIONER KENNEDY:

It carries on through page 7.

6 My understanding is -- and I asked if,this was A

7 something <nich the company had offered, and the,-answer was Thecompanythenasserted,asIunderstochit, that this 8

yes.

9 was a firm offer; it intended to do this, and indeed, intended 10 to go further and do those things which, although they didn't II feel them necessary, the staff did.

12 And then I asked another question about, as did 13 Mr. Bradford, I believe, what the options were of dealing Id with that.

And there are a variety of ways to confirm that.

15 MS. FALK:

Confirm what?

16 COMMISSIONER KENNEDY:

Am I misunderstanding some-I7 thing?

18 MS. FALK:

Yes, and that is that no matter what the 39 company promises to do in the line of additional measures, they 20 don't know at all with any cortainty that that is going to 21 stop the rate of tube degradation.

22 COMMISSIONER KENNEDY:

Yes, okay.

23 MS. FALK:

So if they --

2#

COMMISSIONER KENNEDY:

Is it not true, though, that co Federal Reporters, Inc.

25 they have asserted that, should tube degradation continue and 1527 106

.te 10' 75 O

1 leaking occur, that the plant will be shut down and steps 2

will be taken to stop the leaking.

3 MR. ANDERSON:

If I could focus a little bit better, 4

the question is whether you're going to pick up the failure, 5

so that if you have a loss of coolant accident, will there 6

be no incipient failures at that instant in time.

And if the 7

rate of degradation is low, you are going to pick them up 8

with these increased surveillance measures.

If the rate of 9

degradation is high, to a lessening extent you will not be 10 picking up incipient failures.

11 So thatSdrn that -- if the LOCA occurs, you cannot 2

be confident there will not be incipient failures.

So the 13 key factor is surveillance effectiveness is a function of the 14 rate of degradation.

If the rate is very high, the surveil-15 lance is going to -- the effectiveness will be less.

And 16 the degradation that we saw at this plant is extremely high.

17 I think there should be a rate of degradation 18 limitation, because the surveillance will be less effective 19 with the high rate.

20 COMMISSIONER AHEARNE:

Let me ask you the question 21 I previously asked Ms. Falk.

Since you asked again the 22 question of rate of degradation, do you think that there is 23 any significance in measuring -- measuring that rate, due to the 24 fact that changes in the measurement techniques and the e-Federse Repo,ters, Inc.

25 criteria used between August and October?

1527 107

mte 11' 76 1

MR. ANDERSON:

I think -- I don't see a relationship.

2 I don't want to purport that I can understand, I can confi-3 dently say that.

I would give the same answer that Ms. Falk 4

did:

I don't know and I don't think anyone really knows.

5 One thing I have see, watching it on a day to day 6

basis, is the facc that the representations made initially 7

are always based, by the utility and by the vendor, are always 8

ones that look for the rosy answer.

The initii.1 explanation 9

given in October was that all of it was probably picked up by 10 virtue of the multi-as opposed to the single.

And the 11 explanations that are given I think are always biased and 12 skewed in the exercise of their judgment to find the answers 13 which are confident.

14 I would say, as Mr. Eisenhut, I don't know.

We 15 don't know.

The question is, are we going to take the risks 16 being imposed by these accumulating levels of uncertainties.

17 We don't know.

For s ix years -- for four years we haven't 18 lt.ked at the issue.

It was frozen out of the ECCS hearings 19 earlier in this decade, and we still haven't looked at it.

20 And the crisis in terms of the time i's utility-imposed.

21 COMMISSIONER BRADFORD:

When you talk about the 22 absence of a iate of degradation standard, are you saying that 23 the proposal for rate of change, leakage increasing above 24 15 gallons per day, is a sufficient rate?

m Federal Reporters, Inc.

25 MR. ANDERSON:

What that picks up i s where the 1527 108

77 mte 12 1

leaks actually occur.

So if you have a situation where there 2

is general corrosion, where leaks occur slowly, that would be 3

fine.

We have a situation where the kind of corrosion, as 4

we understand it, is stress corrosion, where there is inter-5 granual corrosive attack and the tube is stained together.

6 There is no leak, so the leak is not being picked up as a 7

general statement under a stress corrosion type of situation.

8 And in point of f act, we go back to that viewgraph.

You will 9

see what we are talking about is stress corrosion, not the 10 previous or general corrosion.

11 The kind of thing the leak rate detection will do 12 is not going to be most particularly appropriate for a stress 13 corrosion situation that we have today.

14 COMMISSIONER BRADFORD:

What about the other 15 criteria, the sudden leakage of 150 gallons per day?

16 MR. ANDERSON:

Again, we are picking up leaks and 17 not the incipient failures of the tube degrading before 18 leakage.

If you have a lot of stress corrosion occurring, 19 which is occurring but no leak occurring, you will not be 20 picking anything up in terms of your surveillance.

But if 21 you have a loss of coolant accident, you have an incipient 22 failure in that tube, as the accumulation of the stress 23 corrosion, that can, under stress, snap, that will bring the 24 kind of American Physical Society scenario into play.

w+eceral Reporters, Inc.

25 COMMISSIONER KENNEDY:

I thought I understood the 1527 109 j

mte l'3 78 1

staff to suggest that would not happen.

2 MR. ANDERSON:

The thesis is, if it is within the 3

tubesheet, the APS thing will not go into play.

That has been 4

a statement just popped off their heads.

I don't know what 5

the basis is.

But we have a very, very reputable, exhaustive 6

report by the American Physical Society five years ago, still 7

sitting on the table.

There has been no public systematic 8

awareness of it, analysis of it.

9 But when this is subject to rigorous analysis, they 10 crumble and fall away.

We are talking about the kind of e-6 11 situation that is grossly insufficient in our 'rien.

12 13 14 15 16 17 18 19 20 1

21 22 23 24

-Federal Reporters, im

79 2,07 J1 pv 3dl i

13. FALK:

The company has suomitted an 2

unauthorized statsmant to you.

I nave not oeen given a J

copy.

Out o f the goodne ss of one of the commission staff's hearts, ths/ gave me a copy et noon today.

I have not oeen 4

servid with e copy oy the company in spite of tne f ac t tqat our submission was served on the comoany bef ore even the 3

/

JRC.

Unless you are prepared to act within the ver/

o immediate fu ture, we would like an opportunity to strutiqiza

/

their docum?qt and get comments to you, if we feel the IJ need and if we are in a timely fasnion to get them to you in 11 tima.

12 CD '4M ISS IO;iER AHEARNE:

You are speaking there of 13 t he --

14

43. ?ALK It is a document they must havs fil+d 15 Late yesterday.

la CO'JMISSIONER AHEARNE:

November 27, it seys.

II Licensee's reply to filing.

13

'45. FALK I don't know.

l.)

CO'4MISSIONER AHEARNE:

You are listed on the 20 service list.

21 MS. FALK:

We have not been servea, and they could 22 hav3 done it oy mail, which obviously would not have gotten 23 to us.

24 CO MMISSIONER GILINSKY:

Any further questions?

25 (No response.)

1527 111

80 32 07 02 pv 8'nd i

CO TAISSI0 DER GILINSKY:

Inank you very mu:hr.

2

13. FALK Thank /ou for your time.

3 CO T4ISSIONER GILI lSKY:

I have some questions of 4

the 3 taff.

.inere have you actually lef t tn? plant?

/Iha t a

sort of arrangements have been made oetween fou and the 6

licensee concerning startup of the plant?

41. EI3cJdUT:

First, in the same package thet the 3

licensee agreed at the meeting with the Environmental Je:ade

/

and a numoer of other outsiae inoiviauals and staf f and 10 everyone present las t Tuesday, they agreed that the plant woula not start up without prior written aoproval, even 12 though the approval may not ce normally required ce:ause of 13 tech moec cnange, et cetera.

It I told them that wanted the plant to stay down la until, numoer one, the staff had written the saf ety 13 evaidation addressing all of these conc 3rns, and, numoer 1.

two, we had adcressed the Environmental Decade -- at least la we addressed the petition at least preliminarily.

If we 19 don't have the complete detailed response prepared, ther3 20 would be a reply out and a saf ety evaluation written.

Until 21 the details are worked out on the actual finetuning of tassa 24 requirements and the administrative vehicle is in piace, the 23 plant is shut down.

It is operating at zero po.ver.

2 COT 4ISSIONER AHEA2NE:

"The administrative 25 vehicle" meaning " order"?

1527 i12

81 32 07 03 pv 37td i

it. EISINd3T:

Yes.

2 CD'.iMI SSIO.'IER GILI.lSKY:

einere are you in the 3

proce ss of preparing the documents?

4

'U.

EIS di1 HUT:

As of late last nignt end early a

this mornin]. we have a final draf t safety evaluation, and I guess we have a first draf t at the response to the a

invironmsntal Decade, to do whatever we can.

Me should have e

3 that issued oy comorrow.

v CO T. TIS 5 IO.id' GILI:1 SKY:

Are you sa /ing tha t, 10 barring conmission ac tion, the olant could then operate 11 r.fter that nac been --

12 MR. EIS E?idUT That would be the administrative 13 vehicle.

14 MR. SHAPA2:

iaer 2.205, the only thing that is 15 aiffe rent is, the general counsel explained, that the 15 commission asked for this oriefing oefore the staff took 1/

action.

So, if the commission wishes to --

13 CO MMISS IONER KENNEDY:

Let me remind you that it 19 is my recollection the commission also requested staff after 2J this briefing allow 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to elapse oefore taking any 2i actio n.

24 CO MMISSIONER GILINSKY:

Tha t wa s my 23 understanding.

And I want to be absolutely sure that that 24 was the case.

23 Md. SHAPAR Yes.

t 1527 113

82 32 07' J4 pv SWH I

001t!.II SS IO.iER G ILI.i5 ff:

Okay.

.fe will than ha7e 2

tha: period to consider the matter.

3 I ha ve two more brief quas tions.

One is --

4 concerns ope rator ins tructions.

Could you just say a little a

more about wnat steps have oeen taken to ensure that 3

operators can cope with f ailures in these steam generator tuces that aay take place or should they take place?

o da. EISE:lHUT:

All plants nave an emergency

/

procedure.

That eme rgency arocedure is supposea to lay out 13 t.ow the plant is supposed to respona, what actions the li opera tor should take following a major ruptured steam 12 generator tuoe.

This plant, as it turneo out, as I 13 mentioned earl.~.er, had one in effect.

It turns out, even in 14

'75 and, in fact, the utility, the operators responded va ry la well to that transient.

They brought the plant cown as it la was designea to.

Il The thing we are asking is that on this plant 18 there be a recheck to go cack in and ma'<e o. aerators really 19 aware of tnat --

2J 00'.14IS5 I0 DER GILIdSKY:

You may not hsve this in 21 operators, for one thing.

22 Md. EISENHUT:

Yes, but tnere is an emergency 23 procedure, so we want to ma<e sure that it is again called 24 oack to their attention, particularly because of the 23 discussion we are having about integrity of the steam s

1527 i14

83 32 07 03 p v BN.i i

generator tuoes.

2 COMMISSIO JER GILIJSKY:

.ina t e re we doing to caec%

J to ma ke sur? that tnat in fact happens?

4 f.R. EI5dNHUT de naven't done tys much yet.

.ee i

a would be asking the utility to, numoer one, check his a

suoni ttals and his submittal to us.

Ne would be looking at the emergency procedures.

Wumber two, we would ask him to a

d go through all of his operators and be sure that he has an

/

internal retraining program to ensure that they are 10 thoroughly familiar with that emergency procecure.

And we 11 will ask that that ce auditea 'y I12.

o 12 C0itiISSIOJER GILINSKY:

Could I also esk Howard.

13 I ass umed it is a section 104 license.

14 Md. SHAPAR:

Sack in 1970, I assume it was, too.

1; COMMISSIONER GILINSKY:

Is there any difference in la the way a case like this is handled as opposed to 3 1/

situation if they had a 103 license ?

13 MR. S HAP AR :

No, the only diff erence in the act in 19 relative context is that the commission is supposed to apply 20 the minimum amount of regulation for 104s.

But that has 21 never reflected itself in any significant respect in the 22 regul ations, as such.

23 COMMISSIONER GILIasKY:

Tha t doesn't enter into 24 this situation?

s 25 MR. SHAP AR:

No.

There is no real differe, ice.

1527 115

84 32 o f 35 pv 6.sn 1

CJ 1:. TIS 510ciER GILI:ISXY

\\nything f urther?

d CD 't.IIS3 IO.1d2 AdEAlclE:

Yes.

Sinc? there are many 3

people here who mignt. De incersted in tne answer, would you go cack care fully tarough tais issue of the APS whi:h has 5

ceen raisea, and, as Ms. Falk pointea out, she aidn't a

oelieve it nad addressea?

/

.t2. EISENHUT I will adoress a different pieca of 3

it, ano I brought along Chris Parcz?Nsti, of our staff, who

/

is an ECOS expert, ana he can addr?ss some of th? s,a e ci fi c la details of it.

Il fae casic concern is that if you nave large 12 amoun ts o f leating in tuoes and elec tricity, a very large IJ numoa r, the amount of gpm I?akage in the primary system --

la C31MISS IO.4ER.<ENNEDY:

Of what oraer are we la talling aoou t?

la

.12. EI3ENHUT Greater than 1300 ga llons pe r ie minute.

Th?re is a question that has been raised by tne 10 APS.

That question has to ao witn steam binding.

The I/

situa tion we have here is --

23 CO MM ISS IOJ ER AHEAddE Being defined as?

26 Md. EISENHUT Retardation of the amount of -- the 22 way /ou could be recovering the core following a 2J loss-of-c ool ant accident.

It would retard the cooling of 24 the core.

22 CD'4MISSIONER AHEARNE:

Slow it down.

1527 116

85 32 07 07 pv - a.i I

'42. EISEiiHUT Yes, slow it down.

It woula 3

2 there fore slow down the amount of cooling to the core.

3 Slowing cown the coolant to the core would in fact. if that 4

hapoened, could cause higher temperatures in the core.

The o

condi tion you find is that you have to nave a la rge amoun t a

of, in leakage, something greater than acout 1300 gallons e

per minute.

5 fne situation we are seeing here is this

/

cr ac'c ing.

Every piece of evidence we have ever seen shows lJ that all of these defects are in the crevice.

They are 11 celow the upper surf ace of the tuce s heet.

12 The only other thing, the other aspect of it is 13 the amounts of lea'< age we have been seeing are extremely 14 small.

In f act, to give you a handle on how it comaares to 15 1300, we aia a theoretical calculation that shows that even 13 if a tube was circumf erential1y through-wall in a crevice, 1/

if the crevice was completely cleaned so that you hed the 13 maximum flow area, the theoretical ooper limit is aoout lv seven gallons per minute for the amount of flow at the 2J maximum delta P you see that would oe seen coming out of one 21 tube or going into one tube.

Seven gallons per minute.

You 22 can, of course --

23 COMMISSIONER AHEAD?lEs That is where you ge t your 24 2 00?

2a M.4. EISENHUT And you have to have a very large 1527 117

86 32, 0 / 38 pv dan i

numoer of tuces that woula f ail simulteneously in sucn a 4

Catastropni way that has n3ver ceen observeo.

Every crack 3

we nave ever seen runs longitudinally.

So, therefore, we 4

con't expect one of those situations would present itself in that straigntforward mode.

a a

faerefore, while the steam cinding question is a

/

good theoretical question, we celieve it is not direc tly 3

applicaole to this situation, becaus ? Ne really believe that 9

all the degr adation we are seeing is actually with tuces in 1) the tube sheet.

11 CO'4 MIS 3 IONER AHEAdHE:

In the tubes that were 12 pulled out, were they examined to see wheth?r there were 13 cracks in tne part of the tuce sheet?

14 JR. LIAU ilo, sir.

15 CO?4MISSIONER AHEARNE:

They were not examined?

la DR. LIAU:

.lo, sir.

The tubes -- first, one tu be Ii was celow tae support plate s the first was f our to six 13 incae s aoove the top surface of the tuba sheet.

In f act, I/

t he t u be -- gives us a section aom

he tuce sneet.

And 2) the thiro tuce sample was broken, aoout one inch celow tas 26 top surf ace of the tube shee t.

So, we did not have a 24 sample.

23 MR. EIS ENHUT There were some that were loo'<ed 24 at.

2a

02. LIAU:

With tne two samples, there were no i527 118

87 32 01 39 pv J.M i

inaic at io ns at all aoove tas tuce saeet.

d CO T4ISSIOciER XENNEJY:

fney were examined for tnat 3

purpo se ?

4 J.1, LIAU:

Yes, sir.

3 0.) '44I SS I O.iE R AHEAD.4 E dext ouestion:

Do you nave any information that the No. 2 plant might ce somewhat osck o

out ooing dovn the same pata?

e 3

4.1. E ISE.'lHUT Me have no information along tnat Line.

But we make the observation that if you loo'c at the 13 experience with it, you don't see anything like the rate of 11 degradation tnat you see on the first unit.

,ve believe t rom 12 a chemistry standpoint tlat it is very well tied.

It is not 13 completely true to say that there is no understandina of 1;

vha t is going on at all.

Tnere is a consideraole amount of la chemistry work trying to understand the precise details.

la dut we celieve there is some logical differences that you 1/

might expect.

Point Beach 2 would never see this kind of 13 proolem.

19 COMMISSIONER AHEARNE:

Could someone explain tnose 2J logic als?

21 DR. W EEKS :

I can explain.

22

'Ad. EISENHUT He has been -- run a research 23 program.

fnis is not a five-day proolem.

fne 24 crevice-cracking has been with us for many, many years.

ile t

23 have been coing a research program that not only is run out 1527 119

88 32 O f 10 sv 6,a 1

of 3cocknavan, it entails a lot of "tork at a large numcer of 2

oth?r national laos.

Dr. Weeks is the aead of that.

a

03. P!EEK5 :

Could I ask you to repeat the exact question?

+

2

'a.NI55 IOJER AHEA.LiEt In various ways of framing a

it, it ist Nhat is your unaerstanding of wnat is happening?

[.

And aart of that is:

'/Ihy saoulan't we expec t it to oe k, 3 nap,a? ning a t Point deach 2 and why not in other plents?

Jd. W EE.<5 :

Our understanoina of what is happening

\\. /

ilJ is cased rather o'n recent ooservations of these tuces pullea 7i from Unit 1.

There is a general intergranular atta:% of tn?

12 grain bouncaries, not intergranular str? ss corrosion 13 cra:41ng per se, because it seems to be c i-di rec tion 31.

It Tnis can be reprouucea in the laboratory under two la specific conJitions, one of which is rather acidic la environment with a lot of sulfices present.

..e don't la oeli3ve that cnat exists at Point Beach.

13 The other one is in a caustic environment in tne 1/

presence of copper ions.

This is possioly what exists at 23 Point Beach.

21 fo oe honest with you, sir, I think it would as 22 impossiole to say we understand tnis phemonenon any furtner 23 than that general statement.

I t c an be reproduced in tha 24 laooratory.

At Point Beach Unit I there appears to or --

23 and I was earlier today looking at the water chemistry 1527 120

89 2O/ 11 hv o.1.1 i

Sf tne two units -- greater amounts in :ne past history of 4

the plant of, say, free caustic in tne coolant, whica there fore suggests that the possioility of a causti; a

environment developing in these crevices may be greater in r

+

a Unit I than in Unit 2.

3 However, there is nothing that we know at this i

tim? that would, say, in tha long term preclude its i

nappening in Unit 2.

/

COTAI SSIO.1ER AMEAR.iEs fhat would then similarly IJ stana for otner similarly designed stean generators?

11 0.1.

,iEEKS:

This is possiole, yes.

12 MR. EI5EllHUT:

How about a backup slide?

13 (311ce.)

14 Ne have two backup slides, which orings the la question of what about the other -- there is a total of 18 la units in tha United States.

14 COMMIS5 IO.4ER AHEARNE:

But let me ask the 13 gentleman.

lv So, if I gather correctly f rom what you are 23 saying, it is that, as f ar as the understancing of tnis type 21 of cracking, you are really going forward cased upon this 22 small experimental sample size, trying to reproJuce that 23 effect?

Ana at the moment, it is ossed upon having oeen 24 aola to reproduce it on two types of water enemistry, but 26 not necessarily reaching a conclusion tnat that is the s

1527 121

34 0I I2 90 hv in i

cause?

d J3..1EEKS:

Tna t i s co rrec t.

I think the 3

ocservations show that, at least in doint Beach Unit 1,

there was ceustic in that crevice.

ihere is certainly a

copper in tne sludge, and presumacl/ some could be present 6

in that crevice, as well.

3omething is filling the crevice

/

wita some deoosit.

3 JR. SHAO:

The que stion wa s way Uni t I and Unit 2 9

are o f fferent.

There is oni possiole r a a son.

During la conve rsion f rom phosphate to AVT in 1974, for Unit I, they li converted to the -- they -- for Unit 2 they shut dovn the 12 whole planti they cleaned the whole unit and then converted la to A/T.

So, I think that it makes a lot of diff erence 14 cetween on-line conversion and shutting down for 15 c on ve rs ion.

16 C04MISSIONER AHEAdNE:

That is a f actual 1e d i f f e re nc e.

13 DR. SHAO:

That translates -- on-line conversions, 19 there may be a lot of deposits in tne crevices which are not 20 cleaned out.

If it is shut down and cleaned out and then 21 c onve rted, then you get rid of the deposits.

22 C04MISSI0 DER AHEARNE:

It is still a f actual 23 dif tet ence as opposed to an e xplanation --

24 Od. SHAO:

You can translate it into some logic.

23 MR. EISENHUT:

The other aspec t, all you ge t is

(

1527 l22

32 07 13 91 pv 3;ld i

fro.a the things that you see.

It co'31d oe associatea wita just like when you study the centing phemonena, many, 2

a many diff erent situations ccn cause centing.

4 fas other thing we are looking at is tne other 18 i

a plants.

I oelieve there are four in the United States tnat a

have experienced some degree of tais proclem, and we are aware of three overseas plants that nave also experiencea 4

i tais proolem.

We are following theirs very, very closely.

Mowever, the other plants appear to ce very

/

1) similar to. Joint Beach 2-type situations.

fou get a very 11 minor amount of it, but you aon't see tne repid major le degradation as you do within Point Beach 1.

Again, it is 13 just an observation.

The f actual di f f erence of how they 14 have operated and tne way they made changes in the :hemistry 15 of their plants.

la COTTISSIOi4ER GILIi4 SKY:

Peter, do you have another 1/

question?

13 COMMISSIO.lER SRAD?ORO:

The statement was made 19 earlier that replacement of these stias generators ras 2v inevitaole eventually.

Do you have a time?

21 M1. EIS ENHUT I didn't say it was inevit? ole.

22 COMMISSIONER BR ADFORD:

Somebody did.

23

4R. EISENHUT The discussions I nave had with 24 utilities is that they are considering the various options:

23 slesving, tuoing replacement, rhey are talxing aoout 1527 123

32 01 14 92 p v

?Id i

get:ing something suomittea to us very tentatively in the 3

e springtime of this next yea.'.

A suomittal for such action, a

of course, would entail staff revie1, ano procaoly in tne t

long lead t i m e -- t ha t i s, if you manuf acture new s:eam a

generators -- that would be for tnem to go out for them to 3

.aur: nase new steam generators and get tnem manuf actured.

4 Ca tt,(ISS IO.iER AHEARdE If one of the conclusicos 3

tha t you say Westinghouse is reacaing is that a cause is sludge cuildup or waatever in the crevices, as one of taa

/

1) solutions, it is to try to : lean it out.

li V 12

/

h 1;

14 la la li 13 19 2J 21 22 2a 24

(

23

\\

l527 124

93 32 06 01 pv 3.id i

MR. EI5dddOT:

It is not just sluage ouildup.

It is the type of chemicals present, ce:ause when they made the 4

3 on-line conversion they turneo off the phospnate treatment 4

f or a wnile end they started converting to AVT.

Doing that certainly cnanged the chemistry of that plant unioue to no a

a other that we are aware of.

COMMISSIONER AHEALIE:

Are you saying thet this 9

was due to cleanup?(

9 M.4. EISENdUT:

It is certainly unclear.

I S.

I; perso nally don' t kno'w.

It woula ce aifficult.

It is a 11 tight crevice, an d 1-i it is a material anytaing, certainly 12 like the materials you see from a denting onemonena that are 13 extramely herd -- in fact, they are harder than the tubei 14 that is why they are crushing the tuoe.

la CO'4MISSIONER GILINSKY:

Peter.

la C0 4MISSI0 DER BRADFORO:

3uite a loc in terms of Ie the aoility if anything snould go wrong suddenly seems to Id depend on tne accuracy more or less of this 19 seven gallon per-minute calculation that you make.

Is that 23 calculation in a form that you can f urnish it to the 21 parties?

22 4R. EI5EdHUT:

I think it is a rather simple 23 calculation, certainly.

24 COMMISSIONER BRADFORD:

't. a n ?

23 MR. EIS ENHUT nhan tne staff reconfirmea it i

1527 125

e.

32 03 02 94 pv dein i

recan tly?

aben was the calculation made?

In the last have ' een actively working very z

couple of weeks.

.ie o

3 thoroughly on this croolem since the first of lovemoer, so 4

it aas oeen in that time frame.

2 CO T4ISS IO.iER BRAD.20RD:

'Asae in tne context of tna a

Point Becch o oolem?

/

44. EISENHUT:

Yes.

3 CO.'.t.MISS I0 DER GILIJ5XY:

Can we see that, too?

v (Laughter.)

IJ 00 4:4IS5 IONER GILI.15KY:

fnank you very mucn.

fne 11 matter is osfore the commission..

4 s'

12

( ?lhe: eupon, at 5:02 p.m.,

the meeting was 13 adjourned.)

14 13 13 1:

ld 19 23 21 2A 23 24 2a 1527 126