ML20033B971
| ML20033B971 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/25/1981 |
| From: | Patricia Anderson WISCONSIN'S ENVIRONMENTAL DECADE |
| To: | WISCONSIN ELECTRIC POWER CO. |
| References | |
| NUDOCS 8112020530 | |
| Download: ML20033B971 (8) | |
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[ nELATED COEnznOsCE DOCKETED l WED-11/25/81-50266 NRC. P18
'81 NOV 27 P353 UNITED STATES OF AMERICA SER.j.
NUCLEAR REGULATORY COMMISSION
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. V iiH Before the Atomic Safety and Licensing Board
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'A Wisconsin Electric Power Company
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POINT BEACH NUCLEAR PLANT UNITS 1 & 2
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Nl.JW(jd Docket Nos. 50-266 and 50-301 DEC Ibbl" Operating License Amendment (Steam Generator Tube Sleeving Program)
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DECADE'S ANSWER TO LICENSEE'S FIRST SET OF INTERROGA,
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,cj RELATIVE TO FULL SCALE SLEEVING g, j ;' \\
j Wisconsin's Environmental Decade, Inc. (" Decade") makes the following full and complete answer, under oath, to the Licensee's First Set of Interrogatories and Request for Production of Documents to Intervenor Decade Relative to Full Scale Sleev.ing Program, dated November 10, 1981.
Oualification This answer does not repeat matters which are already included or referenced in the official record in the proceedings in the above-captioned matter or in the related proceedings before the Public Service Commission of Wisconsin in its dockets p
6630-CE-20, 6630-UI-2 and 6630-ER-10, to which the Licensee has been a full party, nor does the answer include matters which are privileged.
It is also noted that additional bases for the Contentions may arise in response to subsequent discovery, independent investigacion and cross-examination.
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Interrogatories
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8112020530 811125
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PDR ADOCK 05000266 G
' 3-1.
See Qualification.
3-2.
The.rea in which we contend that.he original tube mg be weakened in the laboratory is at the point at which the original tube is bonded to the sleeve.
3-3.
See Qualification.
3-4.
The area in which we contend that the original tube mg be weakened in the field is at the point at which the original tube is bonded to the sleeve, and in the surrounding area of that bond where the bonding process may af f ect.
- See, also, Qualification.
3-5.
Yes.
See Qualification.
3-6.
See Qualification.
3-7.
Fatally compromise is defined to mean the rupture of the primary-secondary boundary in the steam generator during instanteous depressurization of the primary system.
3-8.
See Qualification.
3-9.
The various operating and/or accident conditions include normal plant operation at power or returning to power, main line steam break and loss of coolant accident.
3-10.
The forces at work during the conditions described in i
V3-9 are the primary to secondary pressure differentials arising i
from each of those conditions.
3-11.
Yes, insofar as field installation is concerned.
See Qualification.
3-12.
Yes, insofar as field installation is concerned.
See Qualification.
3-13. (a)
See Qualification.
(b)
See Qualification.
w -
O (c)
At this time, we do not have the name of any person whom we intend to call as a witness.
3-14.
Not applicable.
3-15.
See Qualification.
3-16.
At this time, we have not yet assembled documents which we intend to offer as exhibits during this proceeding or to use during cross-examination.
4-1.
See Qualification.
4-2.
Unexpectedly corrosive environment is defined to mean an environment in the annulus between the sleeve and the original tube in those cases where there is leakage into the annulus that is corrosive to either the original tube or the sleeve or the bond between the original tube and the sleeve.
4-3.
The reason that we use the adjective " unexpectedly" is to retlect the f act that it may not be possible to predict the potentially corrosive environment, anymore than the vendor or licensee predicted the new corrosive effects that followed from sludge lancing or from converting to all-volatile treatment.
4-4.
Yes.
The annulus between the original tube and sleeve may more closely resemble the crevice between the original tube and tubesheet, assuming greater concentgation effects than in the free standing region, than the chemical environment of the free standing original tube above the tube sheet.
4-5.
We do not dispute that the sleeves have been heat treated, but, at this time, we do not take any position on whether that treatment will significantly enhance the sleeves' corrosive resistant properties in the environment that may occur
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' in the steam generator.
4-6.
Yes. See Qualification.
4-7.
The practical safety significance from the unexpectedly corrosive environment in the annulus occurs when there is secondary-to-primary in-leakage during a loss-of-coolant-accident.
4-8.
(a)
See Qualification.
(b)
See Qualification.
(c)
At this time, we do.have, the name of any person whom we intend to call as a witness.
4-9.
Not applicable.
4-10.
See Qualification.
4-11.
At this time, we have not assembled the documents which we intend to offer as exhibits or during cross-examination.
5-1.
See Qualification; see also answer to Interrogatory 5-8.
5-2. The area in question is the span between the lower bond and the upper lip of the sleeve.
5-3.
Yes.
Significant degradation MAy occur.
See Qualification.
5-4.
Yes.
See Qualification.
5-5.
See Qualificatio'n.
5-6.
(a)
See Qualification.
(b)
See Qualification.
(c)
At this time, we do not have the name of any person we intend to call as a witness.
5-7.
Not applicable.
5-8.
See Qualification.
Also, Memorandum to Piles f rom
- Peter Anderson, re Point Beach Tube Degradation-Eddy Current Test Effectiveness, dated January 3, 1980.
5-9.
At this time, we have not assembled all documents which we intend to offer as exhibits or use during cross-examination.
7-1.
See Qualification.
7-2.
The employment of channel head workers is from a transient population with no continuing relationship to the Licensee.
7-3.
We assert deficiencies in motivation, experience and qualifications, not in on-the-job training.
7-4.
The post-installation inspections may not be performed for the correct tube and may not be adequate to detect improper installation.
7-5.
The tasks which may not be performed or may-be performed incorrectly include decontamination, cleaning, insertion and boncing.
The error or omission may not be detected because either the wrong tube will be inspected or the inspection The safety significance of such procedure will not be adequate.,
an error or omission occurs when there is secondary-to-primary in-leakage during a loss-of-coolant-acciclent.
7-6.
(a)
See Qualification.
(b)
See Qualification.
(c)
At this time, we do not have the name of any person whom we intend to call as a witness.
7-7.
Not applicable.
7-8.
See Qualification.
r^
6-7-9.
At this time, we have not assembled exhibits we intend to offer or use during cross-examination.
0-1.
At this time, we do not have the name of any person whom we intend to call as a witness.
0-2.
Not applicable.
0-3.
At this time, we have not assembled documents whicu we intend to offer as exhibits or use during cross-examination.
0-4.
Peter
- Anderson, Director of Public
0-5.
All of the interrogatories.
0-6.
See 10-4.
0-7.
All of the interrogatories.
The location of the search was the Decade's files f or this proceeding, for related proceedings before the Public Service Commission of Wisconsin in dockets 6 6 3 0-CE-20, 6 6 3 0-UI-2 and 6 6 3 0-ER-10, and f or general steam generator issues.
0-8.
This interrogatory is interpreted to embrace documents relevant to all of the contentions, and not just to any single contention.
The following documents may be relevant to the contentions:
(a)
H.M. Fontecilla, Radiol 6$ical Consecuences,qi a Main Line Steam Line Failure with Larce Steam Generator Tube Leaks, undated.
(b)
Memoranda from S.
S.
Pawlick, to V.
S.
- Noonan, dated August 29, 1980, and September 30, 1980, re PWR Steam Generators.
(c) Memorandum from R. J.
Comar and M. Rosen to ECCS
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Task Force, dated June 1,
- 1970, re Comments and Recommendations to the REG ECCS Task Force.
(d)
Letter from P.
Anderson to Wisconsin State Legislators, dated August 8, 1980.
(e)
Meeting Summaries of Staff and Southern California Edison Company, re San Onof re Unit No.1, dated March 31,1981, June 8,19 81, August 8,1980, September 11, 1980, and September 22, 1980.
Document Production Attached is a copy of the memorandum identified in 15-8, and the memoranda and letters identified in 10-8 (a) to (d).
The meeting summaries identified in 10-8 (e) are not provided because they are voluminous and it is believed that the Licensee already possesses copies of this document.
If the Licensee wishes to review the Decade's copies of these omitted documents it should contact Decade's counsel to make arrangements for the Licensee's representative to review the documents at the Decade's office.
DATED at Madison, Wisconsin, t h day of November, 1981.
WISCONSIN' EHEIRONM TAL DECADE, INC.
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By PETER ERSON Director of Public Affairs Subscribed and sworn to before me this d9/- day of November, 1981.
ffjlks, n,h LL:
Notary'Public '
State of Wiscon. sin My commission # M I ATH'.EEN IA. FAIK n,'.TE OF W'SCCNS!:4 NOTARY P'J?,UC T?
E_
TED CORRESPOCDCE
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Wisconsin Electric Power Company POINT BEACH NUCLEAR PLANT UNITS 1 & 2
' Docket Nos. 50-266 and 50-301 Operating sicense Amendment (Steam Generator Tnbe Sleeving Program)
CERTIFICATE OF SERVICE I certify that true and correct copies of the foregoing document will be served this day by depositing copies of the same j
in the first class mails, postage pre-paid and correctly j
addressed, to the following:
s Peter B. Bloch, Chairman
- Atomic Safety & Licensing Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Dr. Hugh g. Paxton 1229 -41s Street Los Alamos, New Mexico 87544 Dr. Jer ry R. Kline Atomic Safety & Licensing Board O.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 i
Docketing & Service O.
S. Nuclear Regulatory Commission j
washington, D. C. 20555 Mr. Richard Bachmann Office of Executive Legal Director U.
S.
Nuclear Regulatory Commission
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Washington, D. C. 20555 Mr. Bruce W. Churchill
- Shaw Pittman Potts and Towbridge 1800 M Street N.W.
Washington, D. C. 20036 t+l-dbdww bdM,iHI v Lu Attachments only served on names with asterisks.
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