ML20031C574

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Answer Opposing Licensee 810928 Motion for Authorization for Interim Operation of Unit 1 W/Steam Generator Tubes Sleeved Rather than Plugged.Record Does Not Contain Sufficient Info. Serious Safety Problem May Be Created.W/Certificate of Svc
ML20031C574
Person / Time
Site: Point Beach  
Issue date: 10/04/1981
From: Falk K
WISCONSIN'S ENVIRONMENTAL DECADE
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8110070313
Download: ML20031C574 (3)


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' EPORE THE NUCLEAR REGULATORY COMMISSION Before the Atomic eafety and Licensing Board OCT 51981> g Officeof tbSxtttM n -t + 5 a k rJ;s Ead POINT BEACH NUCLEAR PLANT UNITS 1 & 2 DOCKET NOS. 50-266 and 50-301 N

(Steam Generator Tube Sleeving Program)

DECADE'S ANSWER TO LICENSEE'S MOTION FOR INTERIM OPERATION OF UNIT 1 WITH STEAM GENERATOR TUBES JLEEVED RATHER THAN PLUGGED Intervenor Wisconsin's Environmental Decade, Inc.(" Decade")

makes this answer, pursuant to 10 C.F.R. 5 2.7 3 0 (c),

to the Licensee's Motion f or Authorization f or Interim Operation of Unit 1 With Steam Generator Tubes Sleeved Rather Than Plugged,"

dated September 28, 1981(" Motion").

The Decade is it: opposition to the Motion for the reasons set forth herein.

It has been established by reputable, independent scientists that the rupture of between one and ten steam generator tubes in the course of a loss of coolant accident could cause esscatially uncoolable conditions in tiie reactor.

Report to the American Physical Society by the Study Group on. Light Water Reactor Saf ety, 47 RevieH Rf Modern Physics, Supp.1, Summer 1975, at S85 - S91.

It is also known that controlled laboratory tests of the j

sleeving process reduces the'ctrength of the original tube by approximately 10% it the point where the top of the sleeve is 8110070313 011004 09 PDR ADOCK 05000266 99 9 0\\

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T welded or brazed to the inside of the tube.

Obviously, field experience with sleeving may result in significantly greater reductions.

At this juncture, unfortunately, the record does not contain suff>cient information to make any determination on the extent of this reduction in strength in the field.

This means that, were Unit 1 permitted to return to service following the " demonstration" sleeving of "up to 12 tubes" a serious without a f ull hearing on the issues in contention, safety pr.oblem may be created.

That is to say, the fact the only a few tubes are alleged to be the subject of the " demonstration" program does not in any way imply that major issues are not at issue, because the inopportune rupture of only one tube weakened by the welding or brazing process brings the APS conces.,n into play.

At the same time that premature approval based upon incomplete information raises grave safety issues, virtually no reasons have been given by the Licensee why 12 sleeved tubes must be returned to service without plugs prior to completion of this proceeding.

. For the foregoing reasons, the Motion should be denied.

WISCONSIN'S ENVIRONMENTAL DECADE, INC.

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KATHLEEN M. PALK Director of Legal Affairs 114 North Carroll Street Suite 208

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Madison, Wisconsin 53703 (508) 251-7020 i

Dated: October 4, 1981

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BEFORE THE NUCLEAR REGULATORY COMMISSION POINT BEACH NUCLEAR PLANT UNITS 1 & 2 DOCKET NOS. 50-266 and 50-301

.(Steam Generator Tube Sleeving Program)

CERTIFICATE OF SERVICE n

I hereby certify that copies of Decade's Answer to Licensee's Motion for Authorization for Interim Operation of Unit 1 with Steam Generator Tubes Sleeved 3atper Than Plugged, dated day of October,19 81, October 1,1981, are being served this by deposit in the first class mail, upon the individuals listed below:

Peter B. Bloch, Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Paxton Dr. Hugh C 1229 - 41sE Street Los Alamos, New Mexico 87544-Dr. Jerry R. Kline Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D,. C. 20555 Docketing & Service U. S. Nuclear Regulatory Commission Washington, D. C. 20555 e

Charles A. Barth, Esq.

Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Bruce W. Churchill, Esq.

g-^s 1800 M Street N.W.

Washington, D. C. 20036 e)

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