ML20011A643

First Interrogatories & Request for Production of Documents to Licensee on Demonstration Sleeving Program

ML20011A643
Person / Time
Site:	Point Beach
Issue date:	10/24/1981
From:	Falk K WISCONSIN'S ENVIRONMENTAL DECADE
To:	WISCONSIN ELECTRIC POWER CO.
References
NUDOCS 8110290225
Download: ML20011A643 (7)

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WED-10/24/81-P:50266NRC.PO8 5 mi 26 Pi:05 UNITED STATES OF AMERICA NUCLEARREGULATORYCOMMINSION OFFICE OF SECRETE . .

00CKEigtgERVICt. Before the Atomic Safety and Licensing Board Wisconsin Electric Power Company W y POINT BEACH NUCLEA". PLANT UNITS 1 & 2

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/ g/6 Docket Nos. 50-266 and 50-301 g h ,

Operating License Amendment (Steam Generator Tube Sleeving Program) gg d [) L Ug l 00T2 8 9g y "-

DECADE'S FIRST INTERROGATORIES AND I6 p,. #mag # h)

REQUEST FOR PRODUCTION OF DOCUMENTS TO LICENSEE ON.THE DEMONSTRATION SLEEVING PROGRAM g'

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The Licensee, Wisconsin Electric Power Company, is het ein required to answer the following interrogatories and to produce

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the following documents and to serve a copy of the documents and its answers and objections upon Kathleen M. Falk, Director'of Legal Affairs, Wisconsin's Environmental Decade, 114 North Carroll Street, Madison, Wisconsin 53703, on or bef ore 9:30 a.m.,

October 27, 1981.

INSTRUCTIONS

1. Answer each interrogatory separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection must be stated in lidu of an answer.

2. An evasive or incomplete answer is deemed to be a failure to answer.

3. You are under a continuing duty to seasonably supplement your response with respect to any questions directly addressed to Y 401 the identify and location of persons having knowledge of hdl 0110290225 a11024"' -

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discoverable' matters, and the identity of each' person expected to be called as an expert witness at hearing. Furthermore, you are L

under a similar duty to correct any incorrect response when you 1 later learn that it is incorrect. ,

4. 'Whenever in these interrogatories a request is made to l identify a person (s) or source (s), state .the name(s), and the last known address.

5. Whenever in these interrogatories a request is made to

" list",'" describe", or " identify" documents, those terms shall be interpreted as a- rquest to provi-de the documents, or, if the documents cannot for good cause be produced, to supply as to each document the f ollowing information where such information is appropriate for each document:

letter, memorandum, (a) The type of ' document - (e.g.,

report, study, etc.);

(b) The date of the document; ,

(c) The name(s) of the signer (s) of the document; (d) The present whereabouts of the document or copy thereof and the name and address of the custodian thereof; (e) A brief summary of the subject matter of the document; and (f) Whether you are wiling to produce the document.

6. As used in these interrogatories, the term " document" is used in . a comprehensive sense and includos, without limiting its generality of meaning, all written, typed, printed, tranccribed or graphic or electronically recorded materials.

7.- Whenever in.these interrogatories a request is made to

state any facts, basis and/or, information, in addition to stating the requested facts, basis and/or information, identify the natural person (s) most knowledgeable as to ea'ch such fact, basis and/or inf ormation and list all documents which relate to any

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such fact, basis and/or information.

8. Whenever in these interrogatories a request is made to state any facts, basis and/or information or to describe documents, state the name of any other person (s) without the Wisconsin Electric Power Company whom you know to possess suc's facts, basis, . ap df._o, r information or documents and the best description known to you of the facts, basis and/or information and documents in the other person (s) possession.

9. All portions of these " Instructions" shall be deemed to be part of these interrogatories. "

INTERROGATORIES Part A Part A Interrogatories seeks to determine facts bearing on whether and the extent to which operational modifications intended to r' educe steam generator tube degradation may have an adverse effect on reactor vessel embrittlement and visa-versa.

1. Describe all changes in operating parameters at Point Beach Nuclear Plant which have been undertaken or which are presently planned to be undertaken in the future in order to reduce or alleviate steam generator tube degradation subsequent to August 1,1979.

2. State whether any study, analysis or consideration has been given to the direct or indirect effect of any change in operating paramaters undertaken or planned to be undertaken to reduce or alleviate steam generator tube degradation.may have or e-

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has had on reactor vessel embrit tlement. If so, please state whether any written discussion of any such study, analysis or -

consideration has been ever made and desiribe the document. If so, but no written discussion has ever been made, please state the name(s) of any persons. involved in'the study, analysis or consideration. .

3. Describe all changes in operating parameters at Point Beach Nuclear Plant which have been undertaken or which are planned to be undertaken in the future in order to reduce or elleviate reactor vessel embrittlement.

4. State wh%tTEr any study, analysis or consideration has been given to the direct or indirect effect of any change in operating parameters undertaken planned to be undertaken to reduce or alleviate reactor vessel' embrittlement may have or has

• had on reactor vessel embrittlement. If so, please state whether any written discussion of any such study, analysis or considertion has ever been made and describe the document. If so, but no written discussion has ever been made, please state the name(s) of any person in the study, analysis or consideration.

Part B Part B Interrogatories seek f acts to determine whether the sleeve or tube may be physically damaged in installation or operation.

5. Describe all laboratory or field t'ests which will be conducted prior to sleeve insertion to determine the tubes' manufacturing and installation tolerances.

6. State whether any studies, analyses or consideration

-that has been given to- the possibility physical contact between

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the sleeve and/or tube caused by physical contact between the upper -and lower weld or braze, including that from vibration. If oo, please state whether any written d'isr:u'ssion of such study, analysis or considerati'on has been made and describe the document. If so, but no written discus'sion has ever been made, please state the name(r) of any persons involved in that study, analyses or consideration.

Part C Part C Interrogatories seek facts to determine whether rew corrosive processes might be caused by the sleeving process.

7. State all material that will be inserted into the steam generator in the process of sleeving and the purpose and location of such material.

8. State whether any study, analyses or consideration has been given to the possibility of galvanic corrosion occuring in the steam generator tubes. If so, please state whether any written discussion of any such study, analysis or consideration has been made and describe the document. If so, but no written discussion has ever been made, please state the name(s) of any persons involved in the ttudy, analyses or consideration.

9. State the row and column location of the tubes which have been selected for sleeving in the demonstration sleeving program and include a compl et e description of all observed defects in the tubes.

10. State the basis or criteria upon which the tubes in the demonstration sleeving program were selected and state the reasons why the tubes were selected.

11. State whether any study, analysis or consideration'has

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been given to the environment of any water in the annulus between the sleeve and tube and/or to the potential corrosive processes J

that might occur in that environment. II so, please state whether any written discussion of any such study, analysis or

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consideration has ever been made and describe the document. If so, but no written discussion has ever been made, please state -

the name(s) of any persons involved in the study, analysis or consideration.

Part D Part D Interrogatories seek facts'to determine whether the weld or b raze w hich ' bonds the sleeve and tube will reduce the

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structural integrity of the sleeve or tube,

12. Describe all inf ormation and documents that exist of the ef fect of the braze or weld which bonds the sleeve to the tube on the structural.integ,rity of the sleeve or tube. .

Part E Part EJInterrogatories seek facts to determine whether the inspectibility of sleeved tubes will deteriorate. .

13. State any changes.that may or will be made in the manner eddy current tests or hyrostatic tests of sleeved tubes will be conducted and interpreted as compared to the manner unsleeved tubes have been tested subsequent to August 1, 1979.

14. State whether any study, analysis or consideration has been given to the' accuracy of eddy current test's or hydrostatic-tests in sleeved tubes. If so, please state whether any written discussion of any such study, analysis or consideration has been been made and describe the document. -If so, but no written document has ever'been made, please state the name(s) of any persons involved in the study, analysis or consideration.

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l Part'F Part F Interrogatories seeks facts to determine whether adequate quality control can be maintained with the intended work force.

15. State the number of vorkers by job classification who will be employed in conducting the demonst r a;; ion sleeving program.

16. State the background, past training, on-th6-job' training, and method of selection of the workers who will be employed in conducting the demonstration sleeving program.

17. State the name of the contractor who will be responsible for hiring the w o r k e.r s who will be employed in conducting the demonstration sleeving program.

18. State whether any formal or informal complaints have been filed in the past ten years against the contractor who will be responsible for hiring the workers on the gr,ounds of selecting -

workers who are unfit for the job.

DATED at Madison, Wisconsi.n, this 23rd day of October, 1981.

WISCONSIN'S ENVIRONMENTAL DECADE, INC.

, &(W KATHLEEN M. FALK Director of Legal Affairs 114 North Carroll Street Suite 208- .

Madison, Wisconsin 53703'

(608) 251-7020

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