ML19270H834
| ML19270H834 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/17/1979 |
| From: | Falk K WISCONSIN'S ENVIRONMENTAL DECADE |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19270H835 | List: |
| References | |
| NUDOCS 8001040041 | |
| Download: ML19270H834 (2) | |
Text
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ca December 17, 1979 fm,,_
fIo Hon. John F. Ahearne, Chairman
',3 Hon. Joseph M. Hendrie, Commissioner
'3 Hon. Victor Gilinsky, Commissioner
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nu Hon. Richard T. Kennedy, Commissioner t.t.
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bbC17 $79 $~*,
Hon. Peter A. Bradford, Commissioner U. S. Nuclear Pegulatory Commission ep-.g...,
O 1717 H S tree t, N.W.
"Qm Washington, D. C. 20555 b
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.N Re : Point Beach Nuclear Plant Docket No. 50-266
Dear Chairman Ahearne and Commissioners Hendrie,
Gilinsky,
, Kennedy and Bradford:
Enclosed please find five copies of the submission of Wisconsin's Environmental Decade, Inc., in the above-matter, made this day, requesting of the Staff a hearing on its Confirmatory order dated November 30, 1979.
Also on November 30, 1979, the Staf f issued its Director's Decision under 10 C.F.R. 2.206 denying our Petition, dated November 14, 1979. We understand that the agency's regulations do not permit persons to file petitions with the Commission seeking its review of director's decisions.
(See: 10 C.F.R. 2.206(c)(2).) However, we are certain that the Commission will want as complete and accurate a record as possible to conduct its own review of the Director's Decision during its twenty day review period.
(See : 10 C.F.R. 2.206(c)(1).)
Thus, we are enclosing copies of our request to the Staff for a hearing on the Confirmatory Order to assist in providing that complete and accurate record.
At the same time, we would underscore a matter o f the utmost gravity which is contained in the attached papers. As you may recall, the safety concerns surrounding steam generator tube degradation involve the question of whether secondary-to-primary inleakage through ruptured tubes during a LOCA will cause steam binding and prevent adequate reflooding of the core.
On November 28, 1979, the Staf f informed the Commissio'n"tlia"t in the case of Point Beach there still existed satisfactory bases for continued operation because the corrosion was confined to the crevice in the tube-sheet where ruptures would be more unlikely and any leakage which did occur would be throttled.
We have just received a document, which the Staf f had since November 19, 1979, showing that during the October 1979 refueling there were eddy current test indications of defects one-half inch above the tubesheet in one tube and at, the top o f the tubesheet in four other tubes.
(A copy of 1683 326 G
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9 Hon. Ahearne, Hendrie, Gilinsky Kennedy and Bradford December 17, 1979 Page 2 this document, Licensee Event Report No. 79-017/01T-0, is appended to this letter for the convenience of the Cocsission, with the salient information found in Tables 1 and 2 of the Report.)
That is to say, not only does the primary basis for continued operation of Point Beach 1 not exist, but it appears that the Staf f was aware that the basis did not exist at the time it inforced the Commission that the basis.
did exist.
This, in addition to the other material set forth in the attached request to the Staf f for a hearing on the Confirmatory order, show, in our view, that all necessary factors were not considered by the Staff and that the Director's Decision is demonstrably untenable.
(See: In the >htter o f Consolidated Edison Company, 2 N.R.C.173, at 175.)
The operating license for Point Beach 1 should be suspended forthwith pending replacement of the steam generator or other appropriate permanent solution and an ajudicatory hearing should be held on the generic issues raised by steam generator tube degradation.
Sincerely, WISCONSIN'S ENVIRONMENTAL DECADE, INC.
t'u n n. W KATHLEEN M. EALK General Co unsel KMF/mt Enclosures :
(1) Licensee Event Report No.79-017 /01T-0 (2) Request for Hearing on Confirmatory Order (3) Ehmorandum in Support of Request for Hearing on Confirmatory Order cc: Gerald Charnof f, Esq.
Mr. Edson G. Case
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231 W. MICHfGAN P.O. 3CX 2046. MILWAUKEE. WI 532M Nove=ber 16, 1979 h CV Mr. J. G. Keppler, Regional Director g
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Office of Inspection and Enforce =ent, Region III d
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A Mc U. S. NUCLEAR REGULATORY COMMISSION s
799 Roosevelt Road os Glen Ellyn, Illinois 60137 l'4
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Dear Mr. Keppler:
S DOCKET NO. 50-266 we' C'I POINT BEACH NUCLEAR PLA'iT t' NIT 1 LICENSEE EVENT REPORT S0. 79-017/0lT-0 Enclosed is Licensee Even: Reper: No. 79-017/OlT-0 (a 14-day followup report) with an attachment which provides a description of an event reportable in accordance with Technical Specification 15.6.9.2.A.3, " Abnormal degradation discovered in fuel cladding, reactor coolant pressure beundary, or primary contairstent. ".
We will provide you with an additional su==ary report including the results of our investiga:icns. of the tube samples which were removed for metallurgical analysis upon ce=pletion of our review of this data.
This matter will be the subject of a meeting with representatives of the Office of Nuclear Reactor Regulation in Bethesda, Maryland, en Nove=ber 20, 1979.
Very truly yours,
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Dw Exec /
utive Vice President Sol Surstein s
Enclosure 1683 328
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- i l Steam generator tube eddy current testing during refueling seven o
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and completed 11-3-79 revealed 69 defective tubes in the "A"
steam generator and 62 defective' tubes in the "B".
All but five of the o,,
o 3 i defects were in the tubesheet crevice region and all were on the inlet side.
100% of the inlet sides of the tubes in both generators were o
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i ia l Three inlet tubesheet samples of tubine were removed for metallurcical i t, l
evaluation.
Plugs were welded in the three tubesheet holes.
The
- I defective tubes were explosively plucced.
Also explosively plug ed 2
l after leak testing were two dripping tubes in the "3"
steam generator i4 1
and one in the "A" steam generator.
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m ATTACHMENT TO LICENSEE EVEMT REPORT No. 79-017/31T-0 Wisconsin Electric Pcwer Cc=pany Point Beach Nuclear Plant Unit 1 Docket 50-266 Steam generator tube eddy current testing was conducted in both steam cenerators on October 16 and 18, 1979, for further evaluation of certain., tubes examined during an outage in August 1979.
A cost cutage review c:.the August 100% eday current tion, a 4'00 KH: crocram, had raised questions on a number.o:ynspec-tubes which it was fel't should be verified by an additional multifrequency inspection.
Thirty-eight (38) tubes were inspected in the hot legs of both steam generators.
Of the 38 tubes instected in the "A" stea= generator, 12 tubes were found defective'.
Of the tubes inspected in the "B" steam generator, six tubes were found defective.
All defects found were located in the tubesheet region.
The tube at cosition R15C45, one of the defective tubes in the "A" steam gener'ator, was chosen to be removed for metallur-gical evaluation.
While doinc crofilcmetry inspections of the tubes adjacent to al5C45 =rior to its' removal, a defect was found in a tube which had not he'en cart of the original sample program.
Discovery of this additional de'fective tube required an expanded inspection pregram in accordance with Technical Specification Table 15.4.2-1.
Prior to ccmmencing the expanded eddy current inspection, the tube at =csition al5C45 in the "A" hot leg was cut just belcw the second sue cr: 01 ate and removal preced*ures began en Oc cber 20.
With culling ressures u p
~ to 25,380 pcunds and several equipment failures, five pieces of tube totalling approxima:ely 21 inches in length were removed on October 21 and 22.
An examination of the tube portions, plus a later eddy curren: Orche verificatien, indicated that the pulling operation had brok'en off the tube at a known defect, approximately one inch below the top of the tubes,heet.
Following cemeletion of the removal of the sections of tube frem 15C45, a 25 '(approximately 199) tube sample eddy current ins =ection was cc=menced in the "A" hot leg on Oc:cber 23.
The ana'lvsis of the 199 tubes determined that 28 cf the tubes were de f e'ctive.
All defects in the tubes were located within the tube-sheet.
The inspection program was again expanded in accordance with Technical S=ecification Table 15.4.2-1 to 100% of the unbes in the "A" inlet. 'This also required that an eddy current pr: gram be conducted in the "3"
steam generator. 1683 330
! The 100% multifrecuency eddy current inspection in the "A" inlet ccmmenced on Octcher 24 and was c =pleted on October 27.
The analysis of the eddy current data showed 69 tubes with defects
>40% which would require plugging of the tubes.
See Table 1 for details.
Following completion of eddy current testing in the "A"
steam generator inlet, a decision was made to ra=cve two additional tube samples from the generator.
The first of the two tubes was chosen as a good tube from an area where no deep crev. ice tubesheet defects were cvident.
The tuce at position R20C73 was cut just below the second support plate on October 28 and four pieces of tube totalling over 140 inches were removed on October 29.
The breaking force for this tube was 10,400 pounds, the pulling force varied between 3,000 and 1,500 pounds.
The final tube to be removed was chosen as a good tube with no previous defects located in an area of the tube bundle where numerous deep crevice defects have been found.
This tube at position R22C37 was cut just below the first support plate on October 29.
The tube broke loose at a loading of 25,380 pounds en October 30 and three sections totalling 74 inches were removed on October 31.
After breaking lecse, the pulling force varied between 4,400 and 10,000 pounds during this operation.
The holes frem which the three tubes were removed frem the "A" inlet were weld repaired on Novembur 2 and 3.
Pric: to the weld plugging of the hole at R15C45, a stabilizing rod was inserted 132 inches up into the tube to tie the tube which was cut just below the second support plate, but broken off one inch below the tubesheet to form a single member with the original tube and tubesheet
- top, hole.
The 25 (apprcximately 199 tube) =ultifrecuency eddy current inspection of the "3" hot leg was commenced on Ccecber 29 and was completed on November 3.
The analysis of the eddy current data showed 62 tubes with defects greater than 40%, which would recuire the tubes to be plugged.
See Table,2 for details.
Prior to explosive plugging, an 300 psi secondary side leak test was performed on the "3" steam generator on November 5 to determine if any of the 90% (plus) defective tubes would leak or if other leaks could be generated by the test.
Seven leaks were s
identified.
Four of the leaks were leaking plugs in previously explosively plugged tubes, the other three being tube leaks.
Of the tubes identified as leaking, one was previcus'y identified as defective during the eddy current program: two tubes with extremely small leaks, in the range of one drip every ten seconds, were not identified as defective by the eddy curren: program.
1683 33I
d
, The four leaking plugs were weld repaired in the "B"
inlet during the week of Ncvember 5.
The defective tubes totalling 67 were explosively plugged during the period be: ween November 6 and 8.
In summary, a total of 68 tubes were plugged in the "B"
steam generator on the above dates:
62 tubes had defects greater than 40%; three tubes had defects less than 40%, but were plugged as a conservative meas'ure; tw6 tubes were found leaking during the leak test; and one tube, a sound tube, was plugged by mistake.
See Table 2 for details.
An 800 psi secondary side leak test was scheduled to be performed in the "A" steam generator on November 7.
Preparations for the leak test were terminated abruptly during the initial filling of the generator when water was found to be issuing from a tube directly over the cold leg manway and cut the manway.
It was immediately recognized that a scheduling error had been made in that the "A" steam generator should not have been filled prior to explosive plugging the outlet side of the tubes opened up to the cold leg side by re=cval of the three sample tube lengths on the hot leg side.
For further details, reference Licensee Event Report Nc. 79-019/01T-0, ":nadvertent Reactor Coolant System Dilution During Refueling Shutdown".
The outlet tube ends were explosively plugged on November 8.
The 800 psi secondary side leak test was performed in the "A" steam generator on November 9 prior to explosive plugging of the defective tubes.
Cne leaking tube (R24C32) was noted which had been previously identified as having a 92% defect by eddy current testing.
Explosive plugging of the defective tubes in the "A"
steam generator on November 12 revealed one additional leaking tube (One drip every 20 seconds), R29C25, with 0% defec: indicated during the eddy current program.
This final tube was plugged on November 12.
In summary, a total of 77 tubes were explosively plugged in the "A" steam generatcr:
69 tubes had delects greater than 40%;
three tubes had defects less than 40%, but were plugged as a conser-vative measure; two tubes were plugged by mistake; cne tube was identified as a leaker.
Two good tubes were plugged because of the above described tube removal program.
See Table 1 for details.
This event is reportable per Technical Specification 15.6.9.2.A.3.
i683 332
TABLE 1 Plucced Tubes with Defects >'401 Tube
% Defect Location R18C24 84%
18" above tube end R24C32 9 1 % _..
5" above tube end R09C24 93%
11',' above tube end R10C41 94%
18" above tube end R10C42 95%
21" above tube end R22C41 87%
21", 15" and 5" above tube end R15C45 89%
20" above tube end R23C62 89%
7" above tube end R19C5 4 83%
20" above tube end R19C5 3 92%
20" above tube end R12C54 92%
20" above tube end R12C55 93%
18" above tube end R08C53 93%
20" above tube end R12C53 71%
17" above tube end R13C53 75%
20" above tube end R09C51 89%
20" above tube end R13C50 95%
20" above tube end R05C50 90%
11" above tube end R13C49 92%
20" above tube end R15C49 88%
21" above tube end R19C49 91%
20" above tube end R15C47 92%
20" above tube end R10C46 96%
20" above cube end R10C45 93%
20" above tube end R17C45 92%
20" above tube end R19C45 901-81%
20", 21" above *::be end R15C44 97%
21" above tube end R12C44 84%
12" above tube end R23C41 80%
6" above tube end R27C40 81%
20" above tube end R24C40 93%
4" to 12" above tube end 223C39 65%
5" above tube end R27C39 59%
21" above tube end R23C37 87%
10" above tube end R24C36 82%
6" above tube end R22C36 76%
11" above tube end R27C35 90%
21" above tube end R23C33 89%
3" to 8" above tube end R20C32 42%
20" above tube end R08043 82%
15" above tube end RllC37 88%
17" above tube end R03C36 91%
10" above tube end R13C26 95%
16" above tube end RilC26 58%
19" above tube end R20C25 92%
17" above tube end R21C45 79%
21" above tube end R22C46 55%
Top of tubeshee:
R29C46 84%
21" above tube end 1683 333
Table 1 Page 2 Tube
% Defect Location R20C40 99%
19" to 21" above tube end R30C53 65%
14" above tube end R17C53 73%
15" above tube end R15C51 81% ~
2.0" above tube end R05C56 87%
10." above tube end R30C57 80%
Top of tubesheet R17C57 76%
8" above tube end R09C57 71%
20" above tube end R15C58 85%
18" above tube end R05C59 97%
10" above tube end R15C61 73%
17" above tube end R13C61 94%
19" above tube end R13C62 31%
21" above tube end R14C62 95%
15" above tube end R13C63 96%
21" above tube end R12C63 76%
21" above tube end R13C64 91%
17" above tube end R23C64 72%
19" above tube end R13C65 921 19" above tube end R05C76 85%
8" above tube end R15C62 94%
20" above tube end Tubes Plugged as Conservative Measure "A"
Steam Generator R19C38 34%
8" above tube end R28C25 26%
14" above tube and R24054 37%
21" above tube end Tubes Plugged by Mistake "A" Steam Generator R2 4C30 R23C63 s
Tube' Plugged - Leaker R29C25 s
1683 334
TABLE 2 Plucced Tubes with Defects >40%
Tube
% Defect Location R14C61 86%
20" above tube end R14C48 86%
21" above tube end R23C43 63%
16" above tube end R24C30 90%
8"',
14", 16" above tube end R06C39 90%
11" above tube end R06C35 87%
12" above tube end R22C31 90%
5" above tube end R20C32 89%
17" above tube end R23C32 94%
10" above tube end R22C33 78%
20" above tube end R25C38 90%
6" above tube end R23C41 87%
3" to 11" above tube end-R12C43 91%
21" above tube end R24C45 84%
6" above tube end R23C45 73%
6" to 8" above tube end
.R22C45 92%
15" above tube end R14C46 93%
21" above tube end R24C46 75%
13" abcve tube end R26C54 93%
20" above tube end R09C16 83%
3" to 8" above tube end R11C18 83%, 92%
15" and 18" above tube end R04C19 77%
8" above tube end R11C24 73%
20" above tube end R17C27 78%
11" above tube end R12C27 72%
20" above tube end R06C27 64%
20" above tube und R11C29 85%
21" above tube end RilC30 92%
21" above tube end R13C30 53%
21" above tube end kl3C31 92%
19" above tube end R04C32 76%
6" above tube end R09C33 86%
14" above tube end R27C36 95%
5" above tube end R04C37 90%
4" above tube end R28C38 45%
Top of tubesheet R09C39 62%
19" above tube end R08C39 95%
8" to 13" above tube end R32C42 61%
" above tubesheet R29C44 65%, 50%,
20",
10",
5".bove tube end 90%
R30C44 83%
Top of tubesheet R31C44 90%
3" to 13" above tube end R29C45 77%
11" above cube end R10C46 87%
20" above tube end R27C50 89%
3" to 15" above tube end R22C56 91%
10" to 15" abcve tube end R20C57 82%
17" above tube end R21C57 83%
6." above tube end
- 1683 333
Table 2 Page 2 Tube
% Defect Location R20C58 93%
14" to 21" above tube end R03C58 90%
3" above tube end R06C59 90%
15" above tube end R15C59 84%._s 20" above tube end R08C60 89%
- A0" above tube end R21C61 94%
5" to 10" above tube end R23C62 96%
5" above tube end R13C62 61%
20" above tube end R03C62 48%
15" above tube e..d R21C64 76%
7" above tube end R08C65 64%
12" above tube end R10C66 40%
13" above tube end R01C68 95%
11" above tube end R24C71 93%
5" above tube end R02C77 95%
3" above tube end Tubes Plugged as Conservative Measure "3"
Steam Generator R25C36 32%
21" above tube end al3C39 36%
15" above tube end R13C59 36%
20" above tube end Tube Plugged bv Mistake "3" Steam Generator R09C32 Tubes Plueged - Leakers R23C47 R20C39 Leaking Plugs Weld Re aired "3"' Steam Generator (Inleti
-.s
~'
(RE:
Tnese plugs inserted during previous outages.)
R22C41 123C31 s
23C50 11C26 1683
- 36