ML20049H840

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Response to Wi Environ Decade First Interrogatories & Request for Production of Documents on full-scale Sleeving Program.Affidavit & Certificate of Svc Encl
ML20049H840
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 03/01/1982
From: Churchill B
SHAW, PITTMAN, POTTS & TROWBRIDGE, WISCONSIN ELECTRIC POWER CO.
To:
WISCONSIN'S ENVIRONMENTAL DECADE
References
NUDOCS 8203040263
Download: ML20049H840 (31)


Text

.__________________ _

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Ma'r'ch E l', 19 8 2 l

UNITED STATES OF AMERICA '82 MM -2 A11 :51  !

i j NUCLEAR REGULATORY COMMISSION

{ n i\
n'H Before the Atoniic Safety and Licensing Board In the Matter of )

( )

WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266

) 50-301 (Point Beach Nuclear Plant, ) (OL Amendment)

Units 1 and 2) )

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LICENSEE'S RESPONSE TO Jts- . .. 3 DECADE'S FIRST INTERROGATORIES 1 ,an,

} AND REQUEST FOR PRODUCTION OF DOCUMENTS -. v ON THE FULL SCALE SLEEVING PROGRAM [k ;, ' 13323,[f_

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Licensee herein responds to " Decade's First 's, ~ ; f i ,,, y ') '\8 Interrogatories and Request for Production of Documents to Licensee on 'he Full Scale Sleeving Program."

c Decade has requested production of the documents identified in Licensee's answers to the interrogatories.

Licensee will endeavor to make copies of the documents available for inspection at the offices of David K. Porter, Wisconsin Electric Power Company, 231 West Michigan Street, Milwaukee, Wisconsin, at a time mutually agreeable to the '

parties. However, many of the documents may contain informa-tion proprietary to the Westinghouse Electric Corporation, and 3D I

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8203040263 820301 PDR ADOCK 05000266 0 PDR

can be made available only under suitable protective order.

Documents not authored by Westinghouse which contain such information will have to be reviewed by Westinghouse to identify and delineate such information. Licensee will contact Westinghouse, Decade, and, if necessary, the Board, to attempt to work out arrangements for appropriate production of docu-ments containing proprietary information.

Part A Part A Interrogatories seeks (sic] to determine facts bearing on whether and the extent to which operational modifications intended to reduce steam generator tube degradation may have an adverse effect on reactor vessel embrittlement or thermal shock and visa-versc.

OBJECTION Licensee objects to Part A of the interrogatories, Interrogatories 1 through 4, in its entirety. The subject of the interrogatories -- reactor vessel embrittlement and thermal shock -- is in no way related to the sleeving of steam genera-tor tubec, and is thus totally beyond the scope of the pro-ceeding.

" Decade's First Interrogatories and Request For Production of Documents To Licensee On The Demonstration Sleeving Program," dated October 23, 1981 (hereinafter

" Demonstration Program Interrogatories"), included four very simila r interrogatories on the subject of reactor vessel embrittlement (Interrogatories 1-4). " Licensee's Response To Decade's First Interrogatories and Request For Production of 1

i t

l Documents On The Sleeving Demonstration Program" (October 27, j 1981) cited the same objection to those interrogatories.

Subsequently, the Board expressly rejected Decade's proposed l

l reactor vessel embrittlement contention on the ground that it was unrelated to the proposed sleeving and thus could not

" appropriately [ appear) as part of this proceeding." Tr. 598;

" Memorandum and Order Authorizing Issuance of A License Amendment Permitting Return To Power With Up To Six Degraded l Tubes Sleeved Rather Than Plugged" (November 5, 1981), at 12.

l In accordance with the Board's directive at page 9 of its October 13, 1981 " Memorandum and Order Concerning The Admission of A Party and Its Contentions," counsel for Licensee discussed Licensee's objection to Interrogatories 1 through 4 l with a representative of Decade on February 26, 1982. Licensee

! and Decade were unable to resolve their differences; Licensee's objection stands.

l Part B Part B interrogatories seek facts to determine whether new mechanisms for degradation may arise from the full scale

< sleeving program.

l OBJECTION Licensee objects in principle to Part B of the interrogatories, Interrogatories 5 and 6, as unrelated to any of the contentions to be litigated in this proceeding.

Licensee also objects to so much of Interrogatory 7 as requests 4

l l

test information unrelated to any of the contentions to be litigated in this proceeding. However, in the spirit of cooperation, and in the interest of the open discovery process urged by the Board in, inter alia, its October 13, 1981

" Memorandum and Order Concerning The Admission of A Party and Its Contentions," Licensee is nevertheless responding to those interroghtories.

5. State any and all rtudies, analyses or consideration of any kind given to the possibility of physical contact between the sleeve and/or tube between the upper and lower joint, including but not limited to the possibility of result-ing degradation to the sleeve and/or tube.

RESPONSE

See Licensee's response to Decade's Demonstration Program Interrogatory 6. Information will also be contained in Section 6 of the revised Sleeving Report which is expected to be available and filed with the NRC in early March 1982.

6. State any and all studies, analyses or consideration of any kind given to the possibility of galvanic corrosion occuring in the sleeved steam generator tubes, apart from that specifically described in the Licensee's October 27, 1981 Response to Decade's First Interrogatories on Demonstration Sleeving Program, at 1 8.

RESPONSE

See Section 6 of the revised Sleeving Report.

7. State the preliminary and final results of tests performed (i) to demonstrate the corrosion and/or cracking resistance of thermally treated Inconel 600 to primary and/or

[ sic; apparently, secondary] water, (ii) verify the corrosion and/or-cracking resistance of the transition of the lower joint of the sleeve, (iii) to verify the corrosion and/or cracking

~

resistance of the upper joint of the sleeve; (iv) to verify leak limiting capabilities of the upper joint of the sleeve, (v) to verify the structural strength and leak tightness of the upper and lower joint of the sleeve after cyclical loading and during accident conditions, (vi) to verify the internal pressure capabilities of sleeve joint, and (vii) any and all tests related to sleeving either not specifically referenced in the Sleeving Report and/or commenced subsequent to preparation of the Sleeving Report; and, with respect to each of the foregoing , provide all details of the tests, if any.

RESPONSE

Test results and information will be included in Section 6 of the revised Sleeving Report.

Additional information is contained in the documents listed below.

1. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel +

600", EPRI NP-1354, Project 621-1, Final Report, March 1980.

2. G. P. Airey, R. G. Aspden, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, December 1979, second Quarterly Progress Report on EPRI Program RPl708-l.
3. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, March 1980, Third Quarterly Progress Report on EPRI Program RP1708-1.
4. G. P. Ai' rey, " Optimization of Metallurgical Variables ^

to Improve the Stress Corrosion Resistance of Inconel 600", Monthly Progress Report for the Month of April 1980 for EPRI Project RP1708-1.

5. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Monthly Progress Report for the Month of May 3 1980 for EPRI Project RPl708-1.

J

6. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Monthl's Progress Report for the Month of June 1980 for EPE( Project RPl708-1.
7. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, June 1980, Fourth Quarterly Progress Report on EPRI Program RPl708-1.
8. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, September 1980, Fifth Quarterly Progress Report on EPRI Program RPl708-1. ,
9. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, December 1980, Sixth Quarterly Progress Report on EPRI Program RPl708-1.
10. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, March 1981, Seventh Quarterly Progress Report on EPRI Program RP1708-1.

'll. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, June 1981, Eighth Quarterly Progress Report on EPRI Program RPl708-1.

12. G. P. Airey, " Optimization of Metallurgical Variables to Improve the Stress Corrosion Resistance of Inconel 600", Westinghouse R&D Report, September 1981, Ninth Quarterly Progress Report on EPRI Program RPl708-1.
13. G. P. Airey, " Carbide Dissolution and Precipitation Kinetics of Inconel 600", EPRI NP-2093, Project 1708-1, Topical Report, October 1981.
14. S. J. T. Balnit, "The Stress Corrosion Cracking of Inconel 600 in Acidic Sulphate Solutions at 289*C",

EPRI RPll71-1, December 1979.

15. EPRI, Workshop Proceedings: Corrosion of Inconel 600 Steam Generator Tubing in the Tubesheet Crevice",

EPRI WS-80-157, May 1981.

'16. EPRI, " Workshop Proceedings: U-Bend Tube Cracking in Steam Generators", EPRI WS-80-136, June 1981.

17. P. E. Morris, " Evaluation of the Effects of Heat Treatment on the Passive Behavior of Ni-Cr-Fe Alloys i in High-Temperature Water", EPRI'NP-1884 Project 1170-1, Final Report, June 1981.
18. J. L. Nelson, " Evaluation of Alternate Alloys for PWR Steam Generators", INCO R&D Center, Inc., October

1981, Combined Third and Fourth Semi-Annual Reports on EPRI RP1450-1.

19. N. Pessal, G. P. Airey, B. P. Lingenfelter, "The l Influence of Thermal Treatment on the Stress Corrosion Cracking Behavior of Inconel Alloy 600 at Controlled Potentials in 13% Caustic Soda Solutions at 315'C", Westinghouse R&D Center, 1977.

l

20. G. P. Toth letter, March 3, 1981, Wisconsin Electric Power Company, Point Beach Sleeving Program, NRC/SCE Meeting.
21. " Main Aspects of the Corrosion / Material Program for Brazed Joints", Westinghouse, October 2, 1980.
22. H. Moers Letter, March 25, 1981, " Wisconsin Electric Power Company, Point Beach Sleeving Program, Technical Evaluation Report for Hybrid Sleeve."
23. H. Keller Letter. November 11, 1981, " Constant Braze Current Braze Tests." .
8. State any and all studies, analyses or consideration of any kind given to the environment of either primary or secondary water in the annulus between the sleeve and the tube and/or to the potential corrosive processes that might occur in that environment, apart from that specifically stated in Section 6.1 of the Sleeving Report or in Section 6.1 of the San Onofre Repair Report.

RESPONSE

See Section 6 of the revised Sleeving Report.

The following additional documents contain informa-tion regarding this interrogatory:

1. Letter, G. H. Neils to Sol Burstein, February 7, 1982, regarding sleeving of steam generators.
2. Memorandum, G. A. Reed to C. W. Fay, February 12, 1982, Response to G. H. Neils letter.
9. State any and all studies, analyses or consideration of any kind given to'the effect of the process which joins the sleeve to the tube on the structural integrity of the sleeve or tube, individually or in combination, apart from that specifically stated in Section 6.1 of the Sleeving Report or in Section 6.1 of the San Onofre Repair Report.

RESPONSE

See Licensee's response to Decade's Demonstration Program Interrogatory 12. See also Section 6 of the revised Sleeving Report.

The following additional documents contain informa-tion regarding this interrogatory:

i

1. Letter, H. Moers to D. Porter, "Wisconson Electric i

Power Company, Point Beach Sleeving Program, Technical Evaluation Report for Hybrid Sleeve,", March 25, 1981.

2. Letter, G. Toth to D. Porter, " Wisconsin Electric Power Company, Point Beach Sleeving Program, NRC/SCE Meeting", March 3, 1981.

Part C Part C interrogatories seek information related to the inspect-ability of sleeved tubes.

OBJECTION Licensee objects in principle to Part E of the interrogatories, Interrogatory 10, to the extent that the interrogatory inquires into inspectability other than eddy current inspectability. Inspectability other than eddy current inspectability has not been raised as an issue to be litigated in this proceeding . However , in the spirit of cooperation, and in the' interest of the open discovery process urged by the Board, Licensee is nonetheless responding with respect to hydrostatic testing, as well as eddy current testing.

10. State any and all studies, analyses or consideration of any kind given to the inspectability and the accuracy of inspections of sleeved tubes, including but not limited to any results of inspection of sleeved tubes in the field at any nuclear electric generating plant, apart from that specifically stated in Section 7 of the Sleeving Report or Section'7 'f o the San Onofre Repair Report.

RESPONSE

See Licensee's response to Decade's Demonstration Program Interrogatories 13 and 14. In addition, considerations of sleeve inspectability is discussed in the following docu-ments:

1. Memorandum, J. Schweitzer to G. A. Reed, March 12, 1981, " Sleeving Unit 2 Steam Generators."
2. Memorandum, G. Frieling to C. Fay, September 18,,

1980, " Southern California Edison (SCE), San Onofre Unit 1 Sleeving, Meeting with NRC, September 3, 1980."

3. Letter, G. H. Neils to Sol Burstein, February 2, 1982, regarding sleeving of steam generators.
4. Memorandum, G. Reed to C. Fay, February 12, 1982, "G.

H. Neils (OSRC Member) Letter of February 2, 1982 Concerning Steam Generator Sleeving and Replacement."

5. Olds, F. C., " Sleeving Saves Nuclear Steam Generator Tubes", Power Engineering, December 1981.
6. Letter, H. Moers to D. Porter, " Wisconsin Electric

' Power Company, Point Beach Sleeving Program, Technical Evaluation Report for Hybrid Sleeve", March 25, 1981.

7. Letter, G. Toth to D. Porter, " Wisconsin Electric Power Company, Point Beach Sleeving Program, NRC/SCE Meeting", March 3, 1981.

Part D Part D interrogatories seek information related to the adequacy of quality / assurance control in the installation of sleeves by transient employees.

21. State the names, last know address and job title of all persons who were employed by the Licensee or its con-tractors or subcontractors to perform the fall 1981 demonstra-tion sleeving program at Point Beach Nuclear Power Plant Unit 1.
OBJECTION Licensee objects to Interrogatory 11 on a number of grounds. The wholesale and indiscriminate disclosure of the j requested names and addresses of all who participated in the sleeving demonstration program would constitute an undue invasion of personal privacy. Public disclosure of the information could subject workers to harassment and intimi-dation. Moreover, a general .equest for the names and addresses of all involved is nothing short of an impermissible fishing expedition, particularly since there has been no indication whatsoever of inadequate training, workmanship, or quality control / quality assurance in connnection with the demonstration sleeving program.

Counsel for Licensee discussed this objection with a representative of Decade on February 26, 1982. Licensee and Decade were unable to resolve their differences.

12. State whether any persons employed to perform the fall 1981 demonstration sleeving program at Point Beach Nuclear Plant Unit 1 were observed or were reported to have violated any of the plant's rules or procedures and provide all details of any such violation. l l

l l

L. . . . .

RESPONSE

Licensee knows of no persons observed or reported to have violated any of the plant's rules or procedures in the performance of the demonstration sleeving program.

Part E Part E interrogatories seek information concerning the effects of tube defects in the free standing region of the steam generator.

OBJECTION Licensee objects in principle to Part E, Interrogatories 13 and 14, as unrelated to the contentions to be litigated in this proceeding. Nevertheless, in the spirit of cooperation, and in the interest of the open discovery process urged by the Board, Licensee is responding to the ,

interrogatories.

13. Please list all defects in steam generator tubes at Point Beach Nuclear Plant by unit, steam generator, row, column, date observed, and percent defect observed, which were at a height of 22" or higher from tube and subsequent to 1975.

RESPONSE

Listings of steam generator tubes with defects observed subsequent to 1975 are provided in the 1976 and 1977 l

l Annual Operating Reports and the 1978 to 1981 Annual Results l

and Data Reports, submitted in accordance with Point Beach l Nuclear Plant Technical Specifications in Docket Nos. 50-266 1

and 50-301.

I l

The specific locations within the referenced documents, listed by the dates of observed defects for each unit's steam generators, are as follows:

A. Unit 1 Date of Observed Defects (Outage Date) Location in Referenced Documents 10/1/76 1976 Annual Operating Report, Section 8.1.1, pages 132-146 6/24/77 1977 Annual Operating Report, Section 5.1, page 55 10/4/77 1977 Annual Operating Report, Section 5.1, pages 55-56 2/2/78 1978 Annual Results and Data Report, Section 5.1, page 36 5/25/78 1978 Annual Results and Data Report, Section 5.1, page 36 9/20/78 1978 Annual Results and Data ,

Report, Section 5.1, pages 36-37 3/14/79 1979 Annual Results and Data Report, Section 5.1, page 70 8/5/79 1979 Annual Results and Data Report, Section 5.1, pages 70-73 8/29/79 1979 Annual Results and Data Report, Section 5.1, page 73 10/5/79 1979 Annual Results and Data Report, Section 5.1, pages 75-78

! 12/11/79 1979 Annual Results and Data Report, Section 5.1, pages 78-80 l 3/6/80 1980 Annual Results and Data l Report, Section 5.1, pages 60-64 l

7/26/8C 1980 Annual Results and Data Report, Section 5.1, pages 64-67 l

12-

11/26/80 1980 Annual Results and Data Report, Section 5.1, pages 69-70 7/4/81 1981 Annual Results and Data Report, Section 5.1, pages 28-29 10/9/81 1981 Annual Results and Data Report, Section 5.1, pages 29-32 B. Unit 2 Date of Observed Defects (Outage Date) Location in Referenced Documents 2/26/76 1976 Annual Operating Report, Section 8.1.2, pages 158-205 3/4/77 1977 Annual Operating Report, Section 5.2, pages 57-61 3/22/78 1978 Annual Results and Data Report, Section 5.2, pages 38-41 3/23/79 -

1979 Annual Results and Data Report, Section 5.2, pages 81-88 l

2/28/80 1980 Annual Results and Data Report, Section 5.2, pages 70-92 4/20/81 1981 Annual Results and Data Report, Section 5.2, pages 35-57

14. State any and all studies, analyses or consideration of any kind given to observed defects in steam generator
j. tubes at a height of 22" or higher from the tube end l

subsequent to 1975.

RESPONSE

A li-*ing of documents discussing observed defects in tubes at a height of 22" or higher from the tube end subsequent to 1975 is provided below and in the response to Interrogatory 13 above.

1. Report 10/3- T. E. Bowman Field Service Report 10/26/76 (FSR): MRS 4.4 WEP-9
2. Report 6/24- V. W. Doutt FSR: MRS 4.4 WEP-10 6/30/77
3. Report 10/12- V. W. Doutt FSR: MRS 4.4 WEP-ll 10/26/77 l 4. Report 2/3- V. W. Doutt FSR: MRS 4.4 WEP-12 2/7/78
5. Report 5/26- V. W. Doutt FSR: MRS 4.4 WEP-13 l 5/29/78
6. Report 3/13- V. W. Doutt FSR: MRS 4.4 WEP-15 3/18/79 -
7. Report 8/4- V. W. Doutt FSR: MRS 4.4 WEP-16 8/31/79
8. Report 10/6- V. W. Doutt FSR: MRS 4.4 WEP-17 11/16/79
9. Report 12/12- V. W. Doutt FSR: MRS 4.4 WEP-18 12/22/79
10. Report 3/10- T. E. Dunn FSR: MRS 4.4 WEP-19 ,

4/4/80

11. Report 7/27- T. E. Dunn FSR: MRS 4.4 WEP-20 8/8/80
12. Report 12/1- T. E. Dunn FSR: MRS 4.4 WEP-21 12/19/80
13. Report 2/27- T. E. Bowman FSR: MRS 4.4 WIS6 3/18/76
14. Report 3/6- T. E. Bowman FSR: MRS 4.4 WIS7 3/27/77
15. Report 3/28- V. W. Doutt FSR: MRS 4.4 WIS9 4/8/78
16. Report 3/23- V. W. Doutt FSR: MRS 4.4 WIS10 4/5/79
17. Report 4/11- V. W. Doutt FSR: MRS 4.4 WIS12 4/25/80
18. Report 4/17- T. E. Dunn FSR: MRS 4.4 WIS13 5/10/81 1

19 .' Letter 8/8/80 E. G. Case NRC Review of Results of Unit 1 Steam Generator Inspection

20. Letter 7/10/80 H. R. Denton L' 9ctor's Decision Regarding Operation of Point Beach Nuclear Plant Unit 2 Steam Generators
21. Letter 5/9/80 C. W. Fay Preliminary Results ,

Inspection of Unit '

2 Tube R18C37

22. Letter 5/2/80 C. W. Fay Final Results

. Inspection of Unit 1 Tubes

23. Letter 4/25/80 C. W. Fay Additional Information Unit 2 Steam Generator Inspection 24..
  • Letter 4/25/80 W. D. Fletcher Answer to NRC-Quection regarding Unit 1 Tube Examinations
25. Memo- 4/9/80 G. D. Frieling Unit 1 Steam Generator randum Tube Analysis Meeting with NRC
26. Letter 4/4/80 A. Schwencer NRC Order dated April 4, 1980
27. Letter 4/28/80 S. Burstein Results of Unit 1 Steam Generator Inspection
28. Memo- 3/25/80 Unsigned Telecopy of Requirement rand um for Unit 1 Restart
29. Memo- 3/24/80 C. W. Krause Unit 1 Steam Generator orandum Tube Inspection Requirements i 30. Memo- 3/10/80 J. Schi'11tzer Meeting with NRC on randum Tube Pulling
31. Memo- 3/6/80 G. D. Frieling Telecon with NRC on randum Tube Pulling
32. Letter 2/27/80 C. M. Trammell Meeting with NRC on Steam Generator Tube Inspection l
33. Memo- 2/22/80 C. W. Fay Unit 1 March 1980 randum Steam Generator Inspection
34. Memo- 2/19/80 G. D. Santer Meeting with Peter randum Anderson
35. Memo- 2/13/80 G. D. Frieling Meeting with NRC on randum Steam Generator Tube Inspection
36. Memo- 2/7/80 J. Greenwood Unit 1 Steam randum Generator Eddy Current Tube Plugging Commitments
37. Letter 8/5/80 C. W. Fay Results of Unit 1 Steam Generator Inspection
18. Letter 12/18/80 S. Burstein Results of Unit 1 Steam Generator Inspection
39. Letter 5/4/81 C. W. Fay Results of Unit 2 Steam Generator Tube Examination
40. Memo- 11/23/79 C. M. Trammell Summary of Meeting rand um with NRC to Discuss Unit 1 Steam Generator Degradation
41. Letter 11/23/79 S. Burstein Recent Unit 1 Steam Generator Experiences
42. Letter 11/19/79 J. E. Silberg Testimony in PSCW Docket 6630-UI-2
43. Memo- 11/16/79 C. M. Trammell Summary of 11/5 Meeting randum with NRC on Unit 1 Steam Generator Tube Inspection
44. Memo- 9/17/79 C. W. Fay Telecon with J.

randum Stolzenberg on Steam Generator Problems

45. Letter 6/9/80 C. W. Fay Unit 2 Steam Generator Eddy Current Indications
46. Letter 1/6/82 G. D. Frieling Permission to Perform Steam Generator Tube Sample Analyses
47. Letter 12/22/81 R. S. Grimm Concurrence to Destructively Analyze Steam Generator Tube Samples
48. Letter 8/4/81 G. D. Frieling Permission to Release Stcam Generator Tube Samples
49. Letter 7/22/81 E. P. Morgan Permission to Release Steam Generator Tube Samples
50. Memo- 7/10/81 J. Schweitzer Unit 1 Steam Generator randum Leak Test
51. Memo- 7/10/81 J. Schweitzer Results of Unit 1 Eddy randum Current Inspection
52. Memo- 7/9/81 J. Schweitzer Recommended Plugging rand um Criteria for July 1981 Steam Generator -

Inspection

53. Letter 6/5/81 G. D. Frieling Report of Unit 2 R15C73 Tube Analysis
54. Letter 5/18/81 G. D. Frieling EPRI Request for Tube Samples for Inservice Aging of Inconel 600
55. Letter 2/15/82 S. Burstein Summary of Steam Generator Inspection Commitments f rom 1/27/82 Meeting l 56. Letter 2/26/81 M. G. Keehan Unit 2 Refueling 7 i Steam Generator Inspection Program
57. Memo- 2/12/81 M. G. Keehan Unit 2 Refueling 7 randum Steam Generator Inspection

! 58. Memo-- 1/16/81 J. Schweitzer Steam Generator Tube randum Sleeving Candidates

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59. Letter 2/18/81 E. P. Morgan Preliminary Report on Examination of Tubes Removed from Unit 1, October 1979
60. Letter 8/29/80 E. P. Morgan Final Report on Examination of Tubes Aemoved from Point Beach Nuclear Plant, Unit 1, March 1980 61.- Letter 10/20/80 E. P. Morgan Report on Examination of Tube R18C37
62. Memo- 10/17/80 J. Schweitzer Unit 1 Refueling 8 randum Steam Generator Eddy Current Program
63. Memo- 4/9/80 G. D. Frieling Meeting with NRC on randum Unit 1 Tube Analyses
64. Memo- 5/12/80 J. Schweitzer Unit 1 90 EFPD Steam randum Generator Inspection
65. Memo- 5/9/80 J. Schweitzer Preventive Plugging ,

randum and Mechanical Plugging

66. Letter 5/8/80 W. D. Fletcher Status of Unit 1 ,

R18C37 Tube Analysis

67. Memo- 5/7/80 C. J. Olson Unit 2 Refueling 6 randum Steam Generator Inspectionc
68. Report 2/28/80 G. D. Frieling Summary Report of Tube 20-37 Analysis
69. Memo- 4/18/80 G. D. Frieling Preventive Plugging randum Program for Unit 1
70. Memo- 3/18/80 J. Schweitzer Review of Eddy Current randum Results for Unit 1
71. Memo- 2/22/80 C. W. Fay Unit 1 March 1980 randum Steam Generator Inspection
72. Memo- 2/13/80 G. D. Frieling Summary of Meeting randum with NRC on Steam Generator Inspections
73. Memo- 2/4/80 G. D. Frieling Meeting with Westinghouse randum and EPRI on Point Beach Nuclear Plant Unit 1 Steam Generators
74. Memo- 1/22/80 C. J. Olson Unit 1 Refueling 7 randum Steam Generator Inspection Results
75. Memo- 7/23/79 C. W. Fay Multiple Frequency randum Eddy Current Results

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76. Letter 12/27/79 J. Greenwood Point Beach Nuclear Plants, Unit 1 Unusual EDDY Current Signals
77. Memo- 11/5/79 G. A. Reed Meeting on rand um Unit 1 Steam Generator Status, Rev. 1
78. Memo- 10/26/79 G. A. Reed Meeting on Unit I randum Steam Generator Status
79. Memo- 10/23/79 J. Greenwood Minutes of Discussion randum on Steam Generator Work
80. Memo- 9/10/79 G. D. erieling Unit 1 Tube Inspection randum and Tube Pull
81. Letter 7/23/79 R. L. Kelly Draft of Proposed EPRI Evaluation of Point Beach Nuclear Plant Steam Generator Tube Sample
82. Letter 1/30/79 R. L. Kelly Point Beach Nuclear Plant Unit 2 Steam Generator Inspection Recommendations
83. Memo- 10/17/78 T. J. Rodgers Resolution of Eddy randum Current Data j 84. Memo- 10/16/78 T. J. Rodgers Interpretation of j randum Steam Generator Eddy Current Indications
85. Report 10/12/78 T. J. F.odgers Unit 1 Refueling 6 Steam Generator Inspection Results
86. Letter 8/18/78 S. Burstein Unit 1 Steam Generator Inspection Plan
87. Memo- 7/31/78 C. Harris Reply to Suggestion randum on Means to Control Steam Generator Tube Denting
88. Memo- 4/4/78 T. J. Rodgers Interpretation of randum Eddy Current Signals
89. Memo- 2/13/78 G. A. Reed Steam Generator randum Conditioning
90. Memo- 1/31/78 T. J. Rodgers Unit 2 Refueling 4 randum Eddy Current Inspection Program
91. Memo- 11/7/77 G. D. Frieling Unit 1 Refueling 5 randum Steam Generator Inspection
92. Letter 11/1/77 D. B. Ralsten Steam Generator Tube Plugging
93. Letter 11/1/77 R. L. Kelly Preventive Tube Plugging in Point Beach Nuclear Plant Unit 1
94. Memo- 10/31/77 T. J. Rodgers Interpretation of randum Eddy Current Signals ,
95. Letter 10/26/77 R. L. Kally Options for Preventive Tube Plugging
96. Letter 10/14/77 G. A. Reed Preventive Tube Plugging
97. Letter 10/19/77 R. L. Kelly Preventive Tube Plugging
98. Memo- 8/5/77 F. A. Flentje Summary of Meeting randum on Unit 1 Refueling 5 Steam Generator Programs
99. Memo- 3/28/77 T. J. Rodgers Evaluation of Results randum of Steam Generator Eddy Current Inspection 100. Memo- 3/28/77 T. J. Rodgers Evaluation of Changes randum in Eddy Current Indication l

1

101. Memo- 3/22/77 T. J. Rodgers Evaluation of randum Preliminary Results of Steam Generator Dent Inspection 102. Memo- 3/16/77 F. A. Flentje Meeting Governing randum Unit 2 Steam Generator Eddy Current Program 103. Memo- 2/7/77 T. J. Rodgers ERDA Request for randum Information on Steam Generator Denting 104. Letter 8/20/79 S. Burstein Steam Generator Tube

! Degradation 105. Memo- 8/31/76 G. A. Reed Unit 2 Primary-Secondary randum Leakage 106. Memo- 9/9/76 S. Burstein Unit 2 Primary-Secondary randum Leakage l 107. Memo- 5/6/76 R. L. Kelly Tests on Simulated tandum Thinned Steam Generator Tube 108. Letter 3/10/76 J. Trotter Steam Generator Denting 109. Memo- 3/8/76 T. J. Rodgers Cold Leg Defects randum 110. Letter 10/8/76 J. P. Tobin Proposed Steam Generator Chemistry '

Tech Specs 111. Memo- 8/16/76 L. E. Brown Periodic Load Reduction randum for Steam Generator Conditioning 112. Memo- 8/10/76 T. R. Wilson Steam Generator Update randum 113. Memo- 7/20/76 T. J. Rodgers Periodic Load randum Reductions for Steam Generator Conditioning 114. Letter 3/25/80 C. W. Fay LER 80-002/0lT-0, Unit 1B Steam Generator Primary-Secondary Leakage

j 115. Letter 11/16/79 5. Burstein LER 79-017/0lT-0, Defective Steam Generator Tubes 116. Letter 5/11/81 C. W. Fay LER 81-002/0lT-0, Degraded Steam Generator Tubes 117. Letter 4/16/80 C. W. Fay LER 80-002/0lT-1, Unit 2A Steam Generator Primary-Secondary Leakage 118. Letter 3/12/80 C. W. Fay LER 80-002/01T-0, Unit 2A Steam Generator Primary-Secondary Leakage 119. Letter 6/24/77 J. Greenwood LER 50-266/77-06, Unit 1B Steam Generator Tube Leakage 120. Letter 9/14/79 C. W. Fay LER 79-013/0lT-0, Unit lA Steam Generator Tube Leakage 121. Letter 8/20/79 S. Burstein Steam Generator Tube Degradation 122. Letter 10/15/79 C. W. Fay LER-79-012/0lT-0, Unit lA Steam Generator Tube Leakage 123. Letter 3/14/79 G. A. Reed LER 79-003/01T-0, i

Unit lA Steam Generator Primary-Secondary Leakage 124. Letter 10/4/78 S. Burstein LER 78-014/0lT-0, Unit lA Steam Generator Primary-Secondary E2akage 125. Letter 5/30/78 S. Burstein LER 78-010/01T-0, Unit lA Steam Generator Primary-Secondary Leakage 126. Letter 2/14/78 S. Burstein LER 78-001/0lT-0, Unit lA Steam Generator Primary-Secondary Leakage 127. Letter 11/13/81 C. W. Fay LER 81-017/0l?-0, Notification of I Degraded Steam Generator Tubes 128. Letter 7/16/81 S. Burstein LER 81-008/OlT-0, Notification of Degfaded Steam Generator Tubes 129. Letter 12/23/80 C. W. Fay LER 80-014/01T-0, Notification of Degraded Ste'am Generator Tubes 130. Memo- 1/13/81 R. Link LER 80-014/0lT-0 randum 4

131. Letter 8/11/80 C. W. Fay LER 80-009/01T-0, Notification of Degraded Steam i

Generator Tubes 132. Letter 4/17/80 C. W. Fay LER 80-002/0lT-0, Notification of Degraded Steam Generator Tubes 133. Report 5/6/81 W. D. Fletcher Point Beach Unit 2 ,

Tube Sample 134. Letter 2/10/82 B. S. Holmes Technical Report on Corrosion Testing and Metallurgical Examination of Tube Specimens 135. NUREG-0886, " Steam Generator Tube Experience,"

February 1982.

Part F Part F interrogatories seek information on the problem of loose plugs during accident conditions.

OBJECTION Licensee objects to Part F, Interrogatories 15 and 16, in its entirety. The subject of the interrogatories, i '

leaking plugs, is in no way related to the sleeving of steam generator tubes, and is thus totally outside the scope of this proceeding.

Counsel for Licensee discussed this objection with a representative of Decade on February 26, 1982. Licensee and Decade were unable to resolve their differences. .

Part G Part G interrogatories seek information concerning the detcils of the demonstration sleeving program.

17. State any and all studies, analyses or consideration of the fall 1981 demonstration sleeving program at Point Beach Nuclear Plant Unit 1, apart from that included in the Sleeving Demonstration Report.

RESPONSE

A field service report by Westinghouse Electric Corporation for the sleeving demonstration program is expected to be issued in the next several weeks. This report will provide a discussion of Westinghouse site activities and work accomplished during the demonstration program.

18. State the primary- P.o-secondary observed leak rate in Point Beach Nuclear Plant Unit 1 subsequent to completion of the fall 1981 sleeving demonstration program, including but not '

limited to the daily variation in such leak rate.

~

j 1 . .

RESPONSE

The total calculated primary-to-secondary leak rate in Point Beach Nuclear Plant Unit 1 following startup after the fall 1981 outage was as follows:

Date Total Leak Rate (Gallons Per Day) 12/15/81 less than 10 12/18/81 less than 10 12/22/81 less than 10 12/28/81 13, 12/31/81 13 1/5/82 13 1/8/82 17 1/12/82 20 1/13/82 23 1/18/82 20 1/25/82 19 2/10/82 20 2/22/82 25 Leak rate calculations following startup from an extended outage such as the fall 1981 outage are complicated by changing primary coolant radioactivity concentrations. Once steady-state concentrations are reached, calculated leak rates are more indicative of actual conditions. From the above data, a small increase in primary-to-secondary leakage apparently occurred in early January. This small increasa may be due to a change in the leak rate of leaking explosite plugs which were not repaired during the fall of 1981 outage due to personnel exposure considerations.

19. State the precise nature of the difficulty in verifying the acceptability of the cold leg of tube R27C49 after removing the explosive plug, including but not limited to the reason for difficulty in verifying that 40% tube wall thickness remained.

RESPONSE

As described in Section 4 of the Sleeving Report, the

! removal of explosive plugs is by drilling. During drilling, the drill will follow the axis of the hollow explosive plug rather than the axis of the tube. If the axis of the explosive plug is not aligned with the tube axis, there is a potential for excessive removal of the tube wall at the end of the drilled area. During fiber optic inspection of the cold leg end of tube R27C49 af ter removal of the explosive plug, some indications of drill offset and uneven tube wall removal were observed. Subsequent gaging of the tube provided further indication that this may have occurred. Inside diameter measurements confirmed that the cube inside diameter was acceptable. However, since the measuring device will follow the axis of the drilled portion of the tube rather than the axis of the tube, these measurements could not be used to positively verify that tube wall material in excess of the 40 percent plugging limit had not been removed assuming the drill had been offset during drilling. Therefore, as a conservative

measure, and based upon the inspection and gaging observations, a sleeve was installed in the cold leg end of tube R27C49.

Respectfully subritted, SHAW, PITTMAN, POTTS & TROWBRIDGE sf By e - / v M ruce W CRITrchill Delissa A. Ridgway I Counsel for Licensee 1800 M Street, N.W.

Washington, D.C. 20036 Dated: March 1, 1982 l

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l . .

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266 -

) 50-301 (Point Beach Nuclear Plant ) (OL Amendment) .

Units 1 and 2) )

AFFIDAVIT OF DAVID K. PORTER ,

l County of Milwaukee ).

ss .

State of Wisconsin ) l DAVID K. PORTER,'being duly sworn according to law, deposes' and says:

1. I am Manager of the Nuclear Engineering Section of the .

Nuclear Power Lepartment of Wisconsin Electric Power Company. .

i I graduated from the University of Illinois with a bachelor of  !

~-

science degree in electrical engineering in 1965. I then spent

..- i four years in the U. S'.-

Navy's Nuclear. Power Program which

-' ~

, -> . . i included one year in . training and three . years of reactor operator

~

l

. I

. r,  ; ,

experience as an engineering o'fficer abo'ard a nuclear-powered j cruiser. I joined the Nuclear P'rojects O'ffice of Wisconsin Electric in 1969 and have been involved in various engineering assignments relating to the Point Beach Nuclear Plant and pre-

\

construction nuclear projects since that time. As Manager of the Nuclear Engineering Section, I am responsible for providing technical, licensing, and engineering support to the Point Beach l

Nuclear Plant. These responsibilities include the technical review of plant equipment and repair specifications, and implementation of U. S. Nuclear Regulatory Commission ("NRC")

licensing actions involving Wisconsin Electric's operating nuclear facilities. I am personally familiar with Wisconsin Electric's activities concerning inspection and repair of the .

Point Beach Nuclear Plant steam generators and our application before the NRC with respect to these activities.

2. I have prepared or participated in the preparation of the responses to Questions 1 through 19 in " Licensee's Responses to Decade's First Interrogatories and Request for Production of Documents on the Full-Scale Sleeving Program",

dated March 1, 1982; the information contained in those responses is true and correct to the best of my knowledge and belief.

l

< 1 Davic K. Potter  !

Subscribed and sworn 't o before me -

'thiirist day of March,1982. ,  !

&,.,95tf & f_ n __ .'

~

.56tary Public

, i.

My Commis'sion Expires: M /,j/3'f'

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l

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board v 1 In the Matter of )

)

WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266

) 50-301 (Point Beach Nuclear Plant, ) (OL Amendment)

Units 1 and 2) )

l CERTIFICATE OF SERVICE This is to certify that copies of " Licensee's Response To Decade's First Interrogatories and Request For Production of Documents On The Full Scale Sleeving Program" are being served to all those on the attached service list by deposit in the U.S. Mail, first class, postage prepaid, this

, 1st day of March, 1982, except that Wisconsin's Environmental Decade is being served by deposit with Federal Express, this 1st day of March, 1982.

M F>P Bruc W Churchill LV Dated: March 1, 1982 l

l 1

r-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter'of ) l

)

WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266

) 50-301 *

(Point Beach Nuclear Plant, ) (OL Amendment)

Units 1 and 2) )

SERVICE LIST Peter B. Bloch, Chairman Stuart A. Treby, Esq.

Atomic Safety and Licensing Office of the Executive #

Board Panel Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Wasington, D.C. 20555 Washington, D.C. 20555 Dr. Hugh C. Paxton Richard G. Bachmann, Esq.

1229 - 41st Street Office of the Executive Los Alamos, New Mexico 87544 Legal Director U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Wasington, D.C. 20555 Atomic Safety and Licensing Board Panel Kathleen M. Falk, Esq.

U.S. Nuclear Regulatory Commission Wisconsin's Environmental Decade Washington, D.C. 20555 114 North Carroll Street Suite 208 Atomic Safety and Licensing Madison, Wisconsin 53703 ,

Board Panel U.S. Nuclear Regulatory Commission Francis X. Davis, Esq.

Washington, D.C. 20555 Monroeville Nuclear Center Westinghorse Electric Corporation Atomic Safety and Licensing P. O. Box 355 Appeal Board Panel Pittuburgh, PA 15230 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Barton Z. Cowan, Erg.

John R. Kenrick, Esq.

Docketing and Service Section Eckert, Seamans, Cherin & Mellott Office of the Secretary Forty-Second Floor U.S. Nuclear Regulatory Commission 600 Grant Street Washington, D.C. 20555 Pittsburgh, PA 15219

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