ML20054C281

Testimony of RA Wiesemann in Response to ASLB 820325 Questions.Release of Test Results Would Provide Useful Info to Westinghouse Competitors Re Nature of Sleeving Process. Certificate of Svc Encl

ML20054C281
Person / Time
Site:	Point Beach
Issue date:	04/14/1982
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML20054C270	List: ML20054C269 ML20054C281
References
ISSUANCES-OLA, NUDOCS 8204200305
Download: ML20054C281 (7)

Text

.

r 4/14/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

Before the Atomic Safety and Licensing Board In the Matter of )

)

WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266-0LA and 50-301-OLA

)

(Point Beach Nuclear Plant, )

Units 1 and 2) )

TESTIMONY OF R. A. WIESEMANN ON BEHALF 0F ,

WESTINGHOUSE ELECTRIC CORPORATION AND APPLICANTS IN RESPONSE TO ASLB 00ESTIONS DATED MARCH 25, 1982 My nace is Robert A. Wiesenann. My business address is Westing-house Electric Corporation, Nuclear Technology Division, P.O. Box 355, Pittsburgh, Pennsylvania 15230. My qualifications are as stated in uy testimony served on parties on February 25, 1982 and as auended in my Supplementary Testimony on Behalf of Applicants Served on the parties on March 23,1982. 7 This testimony is in response t6 the first question raised by the ASLB and contained in the Meaorandua and Order (Concerning Confiden-tial Information) dated March 25, 1982 in this proceeding. As we read the second question, it is directed to NRC Staff.

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i-82042003o5 820414 f yDRADOCK 05000266 PDR l 20580: 1

_2 Question (1)(a) "Would the release of the ,results of the tests' that Mr. Murphy numbers 1(a-d), 2, 3, 4, 5, 6, 8 and 11 ' provide any useful information to Westinghouse competitors concerning the nature of its sleeving process?"

Yes. As indicated in ny affidavits filed in connection with our Application for Withholding, it is our judgment that the release of this infomation would reveal distinguishing aspects of the process itself, the competitive advantages accruing to the process including the demon-strated reliability and licenseability and how we achieved and verified such competitive advantages. Hence, the release of this infomation to our competitors vould reveal aany facets of the nature of our process.

Question (1)(6) "Hou would the data from'each of these tests be useful, or potentially useful, in deducing the nature of the Westing-house process?"

Westinghouse has reviewed the non-proprietary report entitled,

" Steam Generator Sleeve Test Progran", R. E. Ginna t!uclear Power Plant, NRC Docket flo. 50-244 dated March 17 , 1981 for the purpose of comparing the Babcock & Wilcox (B&W) sleeving process and program with our own. A copy of the B&W report is attached as EAhibit A. This' report was obtained from NRC records and we have no reason to believe it to be inaccurate. This review indicates that B&W has done auch less testing over a auch narrower range of conditions in support of their sleeving process. In particular, it appears to us that tests (Tests 1 and 2 in the Board Question) perfomed by B&W were not nearly as comprehensive in scope and range of conditions as those perfomed by Westinghouse. For example, in Section IV, DESIGN VERIFICATI0tl, there is no mention of testing to demonstrate the capacity of the sleeving joint to withstand accident conditions. On the bottom of page 11 the report states only that structural adequacy under "seisaic and all normal operating events anticipated for the entire plant design life" have been demonstrated by analysis and tests. We assuue from this that B&W is choosing to rely on other means acceptable under the ASME Code to ensure safe operation.

l 2058Q: 1

Furthermore, u'e have already released auch more informatio'n to the pub-lic concerning our process and prograa for steam generator sleeving than has B&W, our principal competitor.

Our experience with our tuo sleeving prograas conducted to date

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indicates that [ __

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_ . . . _ _ _ . _ . 3 It is clear to us that such testing and the results thereof aay be applicable in whole or in part to the B&W process. As a result, the release of this information could enable B&W to rely upon our testing results rather than performing their own tests over the saae range of conditions and even where they had, in fact, already performed limited testing could provide corroboration of their results, thus, removing uncertainties which otherwise night require further testing.

Three of the tests (Test flos. 3, 4, and 5) are required by Section IX of the ASME Code. Attached as Exhibit B, are the applicable excerpts from Section IX of the ASME Code. An inspection of this inforaation shows that the Code does not provide a " cookbook" for how to perfora these tests. It only provides certain limits to be met and prescribes acceptance criteria. If Westinghouse proprietary information detailing how the tests were actually done was disclosed to B&W, it could assist that coapetitor in designing test equipment and establishing test procedures. It also would be helpful to B&W in its application of the results of our tests to their prograu. Results of these tests, furthermore, provide useful information as to the level of quality we are able to achieve in our brazing process from which B&W and other competitors cay'be able to deduce sone of the ways we achieve that qual i ty. [

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i 20580: 1

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>e The results of the metallography tests of the brazed Joint (Test No. 6 in the Board Question) would reveal iuportant characteristics of the brazed joint which would disclose our capability to control the

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process. L' ._ _ _ _, _

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]a,c,e The results of the Huey (modified). and reactivation / polarization tests (Test No. 8 in the Board Question) woulo reveal our aDility to control the degree of sensitization and' thus L 3a,c,e B&W apparently aid not perform this test. The results of this test coulo be applicable to the i B&W process depending upon the amount of information B&W has learneo

! about our process and the similarities between the caterials.and processes used. [

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l ja,c,e Thus, they could obtain

, the additional assurance of [ 3a,c,e

'. without expending the tice and expense of running the tests.

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- . 5 Releasing the results of the evaluation of ECT inspectability of sleeves (Test No.11 in the Board Question) would reveal important aspects of the inspectability of completed sleeving installations. B&W according to Exhibit A,Section V.A. Baseline Eddy Current Inspections, is relying on eddy current testing utilizing standard techniques. Tests performed by Westinghouse utilized a number of special eddy current test probes and techniques. Releasing the results of our tests would indicate the [ . . _ _ _I_ _ I - - - - - -

3*'

I swear that the foregoing testimony is true and correct to the best of my knowledge and belief.

/

Y% 00lbflbiMV Robert A. Wieseraann t

, Subscribed and sworn to before ce 6

! this 14th day of April,1982 I

)c DlttfLv NOTARY PUBLIC L Sul/ w PAutillE SLDhSKA. NOTARY PUBilC MONR]EVlut 20RO AutGHEMY COUNTY

,MY COMMISSION EIP:tE3 MAECH 10. IN My Coani ssion exp1re s: ""'*" **" A55cm* of 8***

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NRC Docket No. 50-244 .

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March 17,1981 SadCCC.\ &Y/ilCOX M.

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STEAM GENERATOR SLEEVE TEST PROGRAM R. E. GINNA NUCLEAR PC4ER PLANT b'

NRC DOCKET NO. 50-244 (10/5/80)

! Babcock and Wilcox Power Generation Group Nuclear Power Generation Division

P. O. Box 1260 l

Lynchburg, Virginia 24505 l

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4

- TIE _E 0: CT. ENTS -

Paae

' 1

. INTP.0 DUCTION 1

A. Sackaround 4

B. Overview of Sleeve Development Procram 1 I 2 SLEEVE DESIGN

~

II.

General Design 2 A.

Upper End Attachment 3 B.

3 C. Lower End Attachment 4

f III. SLEEVE INSTALLATION

<. 4 A. Tubes to be Sleeved o

Installation Sequence 4 B.

6 I C. Procedures a 7 D. Mock-up Demonstration and Training Radiation Exposure Control and Estimates 8 E.

8 IV. DESIGN VERIFICATION

' 8 A. Tests 10

B. An alyses 12 I C. Conformance with License Conditions

' 13

!. V. POST-INSTALLATION INSPECTIONS Baseline Eddy Current Inspection 13 A.

l 13 i 8. Follow-on Inspection

) 13 VI. GOAL OF TEST INSTALLATIONS l 13 l A. Fall, 1980 14 B. Later Installations I

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30:UENT AT: 0N 12-1120821-00 Sccumen: Identifie-:

Steam Generator Sleeve Test Program Titie:

R. E. Ginna Nuclear Power Plant -

NRC Docket No. 50-244 March 17, 1981 Date:

Rochester Gas and Electric Company Customer:

BE-09253

n. Customer Order Number:

582-7174 Contract Number:

A-19 Case File Number:

Prepared by: O L' .' ,

M. W. Henig O

eM I

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77

.. 'N R03U:7 ION A. Eackcround Ginna Station is a Westinchouse two (2) loorIt o-essu-ized water is licenseo for 1520 reactor plant owned by Rochester Gas and Elec'.ric.

mecawatts the mal and has a net electrical capacity of 490 mecawatts.

The steam generators are Westinghouse series 44 vertical shell and .

U-tube units each rated at 3,130,000 lbs/hr steam flow at The 725tubes osig.

The steam generator tubing is Inconel 600 (55-163-61T).

are partially rolled into the tubesheet and seal welded.

Phosphate secondary water chemistry control was utilized from initial In December 1974 secondary water operation throuch November 1974 AVT chemistry control' was converted to all volatile treatment ( AVT).

was maintained through condenser integrity and steam generator From January 1978 until the present blowdown until December 1977.

~ full flow, deep bed condensate demineralizers have been in operation.

b Stern generator tube wastage, caustic cracking, and ID cracking have Between March 1974 and October 1980, 121 been experienced at Ginna.

tubes were plugged in the A-steam generator and 68 in the. B for these reasons. The total number of tubes which During have been pluoged is 122 in tne Spring 1979 refueling the A generator and 112 in the B.

outage, OD cracking of tubes in the tubesheet crevice region was first d iscov ered'.

A total of 44 tube.s now have been plugged in the B steam No such indications generator due to crevice cracking indications.

have yet been discovered in the A steam generator. The crevice The cracking occurs 2 to 3 inches below the top of the tubesheet. -

cra'cking appears to be the result of general intergranular The cracking seemsato.be

. tackvery due to the presence of alkaline elements.All of the indications to date have occurred temperature dependent.A detailed description of the results of the Spring in hot leg tubes.

1980 eddy current examinations, and a discussion of the crevice cracking phenomena, were provided in the Rochester Gas and Electric letter of April 29, 1980 to Mr. Dennis L. Ziemann, USNRC.

Since the Spring 1980 inspection, Rochester Gas and Electric has initiated several proorams directed towards resolution of the crevice cracking phenomena.

The existing programs are all in the areas of chemistry and plant operation and are directed towards eliminating crevice crackino. Sleeving could provide an alternative to tube plugoing and thereby extend the life of the steam generators.

B. Overview of Sleeve Development Prooram The sleeve development program consists of a three phase program with Babcock and Wilcox Company of Development, Design Verification, and Implement ation. Specifically, the objectives of each phase of the progran are:

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- . .. ..-_ . .. . ,_ - ~ - - - . . - . - . - _ .

2 . .

E. Dveev iew o#* Sleehe Devel00 Tent ~0C*at 'C09tinue: .

l. Develo3 ment Du-inc this phase. the sleeve design was develooed. Mate-i al s were selected and laboratory testing and analytical work were -

performed. Licensino issues were assessed and the impact of sleeve installation on outace schedules was cetermined. All necessary materials, eouipment and procedures needed for Phase 2

,i Design Verification have been developed and are being demonstrated.

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2. Desion Verification Durino this phase 10 sleeves will be installed .in the Ginna steam generators to verify the adeouacy of the sleeve desian developed durino the development phase. Further laboratory testino and .

qualification work will be performed leading to the implementation phase.

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3. Implementation ,

Durino this phase, sleeves will be installed on a large scale in tubes having unacceptable tubesheet crevice eddy current (EC) indications. Schedule for implementation has not been developed and will be dependent on confirmation of design through the Design .

Verification program.

II. SLEEVE DESIGN A. General Design The Babcock and Wilcox sealable sleeve design to be employed (see Figure 1) is 36 inches long, thin walled, composite alloy sleeve attached to the steam generator tube at both the upper and lower ends.

Inconel was chosen for the base sleeve material to provide the same structural and thermal chracteristics as the original tube.

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[ PROPRIETARY ]

[ 3 The upper end of the sleeve will be expanded and brazed. The length of the sleeve (36 inches) will insure -the braze ioint being above the sludge affected region atop the tubesheet. The tube sheet is 22 inches thick and the sludge affected zone extends approximately 3 to 6 inches above the tubesheet.

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[ PROPRIETARY ]

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L. General"De'sice f"ontirsed)

• Tne 'ower end of ine C3 eve will be exciosively welded t: tr.s t re g y tne tucesheet roil exoanced recion. :xp ios ive wt dihc v.- Il substant .aily educe tne time -eouired te install sleeves aa.:

pe-sonnei exoosure to radiation. Althouoh not anticipate: to be use:,

as a back-uo to the explosive technique, a GTAW weld pro: educe has also been developed.

B. Upoer End Attachment ,

The upoer end of the sealable sleeve is designed to be attacned to the steam generator tube by brazing.

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[ PROPRIETARY ]

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5 elections of the braze joint configuration, parameters, procedural technioues and filler material were made based on the results of laboratory brazing trials and mechanical property tests.

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[ PROPRIETARY ]

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The joints were cut apart and evaluated by metallographic examination and bend and pull tests were performed to select the best joint configuration. The leak tightness of the joints was. verified by hydrotest.

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[ PROPRIETARY ]

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Oxides will be removed from the steam generator tube ID prior to the brazing operation to assure a good bond. About 0.001 inch of metal will be removed from the surf ace to get a surf ace suitably clean of oxide for subseouent brazing.

< C. Lower End Attachment

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j the lower end of the sealable sleeve will be attached to the steam -

cenerator tube by explosive welding. B&W has considerable experience I with explosive welding in steam generator tubes - holding U.S. Patent 3,590,877 for explosive plugging. This weld proven plug design and explosive method provides the basis for the explosive procedure for attachment of the lower end of the sealable sleeves.

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[ PROPRIETARY ]

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i Page 3

Enc Mte: rent (~orunuec)

. C. _c..e- ,

J. Tnis weld conficura . ion was cevelocec :.;-in: i series of ests until Mn ne cesired confiouration 6.as acnievec. InE tic joints were 9 '

sectionec, polishec onoto cicrograpns taken and evaluated by metall ograpny.

B&W is licensed by the ATF Bureau of tne U.S. Treasury Department as both a manuf acturer and importer of hign explosives (license numoers 40H0762001-00048 and 40H07620Cl-00052 respectively). For transportation purposes, the B&W explosive plugs are classified as -

class "C" explosive by the Bureau of Explosives. B&W has requested a similar classification for the Ginna explosive welding device.

As a back up procedure to the lower end attachment a Gas Tungsten-Arc (GTAW) seal weld was developed utilizing the same semi-automatic weiding equipment used by B&W at Florida Power's Crystal River Unit #3 during tne April 1980 shutdown.

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[ PROPRIETARY ]

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This equipment can be utilized on flush or fillet welds and can be placed in any position, including overhead.

III. SLEEVE If4STALLATION A. Tubes to be Sleeved Tubes Ten tubes in the "B" steam generator hot leg will be sleeved. In to be sleeved will be selected by Rochester Gas and Electric.

order to provide for a good test, sleeves will be installed either in tubes which have indications of intergranular attack in the tubesheet crevice region, or in tubes which would be expected to be subject to, intergranular attack based on past inspection results. In addition, a sleeve will be installed in one tube with a through-wall defect.

B. Installation Seauence The following installation sequence will be used to install sleeves in the preselected steam generator tubes.

1. Tube Preparation (a) After locating the subject tube (tubes) the tube I.D. will be checked with a "G0 Gauge". Insertion of the gauge should be made freely without force. If the gauge cannot be inserted another steam generator tube will be selected.

(b) Steps will be taken to insure that the tube ID is dry.

Pag.e 4

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!. . Irstall'a: ion Secuer:e Zor.:;nued) -

) (c) Tuoe :: c1 ther ce ,easure: using profilometry or die tes

gauge.

(d) Final cleaning of the tube ID will be ac:cmplished.

! [ ]

[ PRO?RIETARY ]

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[ ] .

(e) After completion of cleaning, the tube ID will be flushed and swabbed. Cleaning will continue until swab is free from dirt or particles.

2. Sleeve Brazing (a) After completion of tube cleaning the hydraulic expansion tool will be' inserted into the sleeve from the expanded g end.

(b) The sleeve will be inserted into the tube.

(c) The sleeve will be hydraulically expanded at the braze region of the sleeve to deform the tube.

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[ PROPRIETARY ]. .

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(d) After completion of hydraulic expansion, the induction i heating coil will be inserted into the sleeve and the brazing operation will be performed.

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[ PROPRIETARY ]

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The heater will then be removed.

4

3. Leak Test (a) Tube and sleeve leak test plugs will be installed and a leak test will be performed.

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[ PROPRIETARY ]

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:til't$u r Secuence (;cntinued) ,

y Er.:lo:ive ~,ieicing jt (a; Explosive cartridge will De insertet into the sleeve and clamped' into acjacent tube until the cartrioge flange contacts the tube.

(b) The explosive cartridge will then be detonated.

(c) Af ter detonation, the sleeve will be visually inspected to examine the sleeve deformation at the explosive weld region to ensure no degradation of the structural integrity of the steam generator tube. .

5. System Pressure Test (a) A primary system pressure test will be perfoamed prior to return to full power to fu-ther demonstrate sleeve to tube attachment structural integrity.

e.

C. Procedures

1. Detailed procedures have been developed for installation of the sleeves. These procedures include and provide detailed step-by-step operations for tube preparation (gauging, cleaning),

hydraulic expansion and brazing, explosive welding and leak test.

The installation sequence is detailed in Section B. Prior to installation of the sleeves, the following requirements will be met:

(a) Water in the primary system must be drained below the centerline of the reactor vessel outlet nozzle.

(b) Water must be drained from the secondary side prior to brazing and explosive welding.

(c) Both primary manway covers and inserts will be removed.

(d) The channel head area and tubesheet must be dry.

(e) Air samples from inside the steam generator will be analyzed.

(f) Radiation levels inside the channel head area will be mapped and general levels and hot spots identified.

2. Gauging Tube I.D.

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[ PROPRIETARY ]

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. Cro:ecures (Continue:i .

2. 'Cleaninc i

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4 Expanding i

Af ter the tube I.D. surf ace has been adeouately cleaned, the pre-brazed sleeve with an expanding tool in position will be inserted into the tube. The sleeve is tnen hydraulically expanded into the tube.

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[ PROPRIETARY 1

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l -- 5. Brazing

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6. Pressure Test of Braze

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7. Explosive Welding i

.'As described above, the sleeve will be explosively welded to the tube in the rolled region of the tube sheet.

D. Mock-UD Demonstration and Trainino i

Sleeves will be installed in the Ginna steam oenerator mock-uo to demonstrate the tools. technioues and eouiDment under realistic condition _s. This is considered an integral and necessary part of the program to minimize delays and radiation exposure during prototype i

sleeve installation in the operating steam generator. Mockup installation will also serve as personnel training.

Complete procedures for tube cleaning, sleeve installation, expansion, brazing and welding will be demonstrated on the mock-up prior to use in the operating steam generator.

! The chosen NDE technique and procedure will also be used on the full-size mockup.

l Page 7 I

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E. RaciatiErE7:osureC:.rolandEstima.es ,

j All :e-sonnel to be e . gaged in the stelT generatec sleevinc wil receive instructions and traininc ir. and unoerstanc the radiati:n or :ection rules and guicelines in e"ect at the pl ant site. The radiation exacsu*e for test sleeve installation has been cetermired based on previous measurement of radiation levels at Ginna. The croiected exposure is:

Ooeration Estimated Exposure .

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[ PROPRIETARY ]

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-4>= 2.25 R/ Sleeve x 10 Sleeves 22.5 man-rem Gauging tubes for selection 1.0 man-rem General exposure outside generator 2.0 man-rem Install and remove ECT eauipment

', for sleeve testing 3.0 man-rem TOTAL 28.5 man-rem TyDically, the radiation exposure is accumulated for plugging 10 stern generator tubes is 4 man-rem. It should be noted that radiation exposure for sleeving will be substantially reduced in the implement'ation phase when, it is expected, more mechanization will be employed.

IV. DESIGN VERIFICATION A. Tests During process development, a number of tests were performed including hydrostatic, tensile and peel, and metallographic examinations on the upper and lower attachments. Additionally, design verification testing will be performed prior to and subsequent to installation of test sleeves in a Ginna steam generator. Testing performed prior to installation of test sleeves is directed primarily at providing aceouate assurance of the mechanical inteority of the test sleeves.

The testing completed prior to test sleeve installation includes: .

(1) Mechanical Integrity Testina

~ ~

))de.' &A4P w *

'.ch M h .

The mechanical testing in support of the test sleeve installation is being conducted on a simulated tube / sleeve assembly. The five test specimens are constructed of adeouately representative materials using the same brazing process to be utilized in tne test sleeve installation. A limited number of these simulated tube / sleeve assembly specimens are being tested as follows:

Page 8 I

A. Tests (~cr.inuet) ,

(a) Primary Sice Hycre Test

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[ PROPRIETARY ]

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(b) Secondary Side Hydro Test

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[ PROPRIETARY ]

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(c) Structural Fatigue Testing

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[ PROPRIETARY ]

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e' (d) Primary Side Hy'dro Test

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[ PROPRIETARY ]

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(e) Tensile Test

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[ PROPRIETARY ]

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(2) Corrosion Testing

[ Proprietary] is the material most often used for caustic corrosion resistance. Data on actual corrosion rate. was not adequate in the range needed for sleeve application. To obtain data coupons of [ Proprietary] were tested in a 50% caustic solution at 550*F.

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[ PROPRIETARY ]

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Qualification testing will be performed to insure appropriate design verification of the final production of tube / sleeve l

assembly to be used in the large-scale production installatin.

t The specific testing that will be perfomed is to be defined subsequent to installation of the test sleeves; however, it is presently expected that testing will address, as appropriate, the j following areas:

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i

A. Tes s cntinuei .

(a) "e:h :a'. *. nte;-i ty Test ing The ae:r.ar/ cal 'r.tegrity testino is expec ec tc include tests simC,ar :. that concucted in support of tne limi ed test s'.eeve ins allation. However, the tube / sleeve assembly test s;ecimens will be constructed of the actual materi als.

Additi:nally, appropriate thermal and pressure cyclic testir.; followed by tensile testing and metallurgical examiration will be performed. .

(b) Corrosion Testing Corrosion testing will oe conducted in a caustic environment at abo;; 600 F to . demonstrate the expected superior corrosion resis:ance of the sleeving material (bi-metallic) as wei' as the integrity of the tube / sleeve assemoly end attact. ents. Upon completion of a reasonably long test exposu-e, these specimens will be subjected to a

1. metallJrgical examination. It is anticipated that about four full configuration specimens will be tested.

(c) Vibration The aralysis corducted in support of the sleeve installation identified the need to further evaluate the response of a severed tube / sleeve assembly to flow irduced and seismic excitation. While this issue may be addressed analyt.ically, some vibrational testing may also be required.

B. Analyses A review has been performed of al_1 events analyzed in the Ginna Station Steam Generator S ress Report. The results of this review provided the basis for an evaluation demonstrating the structural integrity of the sleeved tube configuration for all anticipated normal operating events._

Calculations were performed which demonstrate that the tube sleeve design meets the internal design pressure and temperature requirements of paragraph NB-3324 of the ASME Code. Additional calculations have been performed wnich demonstrate that the sleeve has a greater external pressure load carrying capacity than the original tube.

A thermal stress analysis of the tube / sleeve assembly has been

• performed to determine the thermal and pressure loadings and the associated temperatures for the critical normal operating events analyzed in the sinna Station Stress Report. Loadings at 100% power and transient ccnditions such as plant heatup and cooldown, pl ant Page 10 l

.- L. 2"i.' ..ts [ 2 r .lued) 1:,a:-.; anc unicading, Step load transient were consice ed. By

Cr.:a~.a ;vely comoining transien; conci . ions, a limi .ec sccpe fa igue es. ;.-og a:- has been structured wr.ich takes into accourit tne ac;Ual ver!.s .est temperatures, design versus actual geometry, numoer of tes saecimens in accordance with the intent of Appenc1x II to Section II: Of the ASME Code. Successful completion of this fatigue test program wil further demonstrate the adequacy of the tube / sleeve -

or. figuration for all normal operating events anticipated during the design life of the plant.

An analysis has been performed to determine the ef fect of 10 sleeved tubes and full steam generator sleeving on the thermal / hydraulic performance of the Ginna Steam Generator. A design point of 90,000 GP.*'. and a total design pressure drop of the Reactor Coolant System of 82.0 psi was considered in the analysis. Sleeving 10 tubes in one stea generater has negligible effect on the overall primary-side pressure drop and the average overall heat transfer coefficient

^ remains practically unchanged. No adverse effects due to cavitation / erosion are expected to occur due to sleeving of 10 tubes in :he generator. For a case with sleeves installed in all generator tubes, the primary side pressure drop is expected to increase by approximately 7 percent over that in the unsleeved generator. With this 7 percent pressure drop across the steam generator, the effect on the total primary system pressure drop is small. Considering this increase the effect on the RC pump flow and thus the heat transfer is negligible.

Maximum crass-flow velocities in the steam generator vary from 8.1 feet /second at the tube bundle periphery (feedwater inlet at the edge of the tubesheet) to 2.0 feet /second in the ~ interior region of the tube bundle. Resonant frequency and mode shape calculations have been performed which demonstrate that sufficient frequency separation exists between tube resonant frequencies (34 cycles /second for a sleeved tube which has not been completely severed) and vortex sheading frequencies (8.4 cycles /second in the interior region of the bundle) to ensure that a vibrational instability will not occur.

A review has been performed utilizing the Ginna Station Steam Generator Stress Report to assess the impact of a seismic event on the tube / sleeve assembly. The installation of a sleeve in a tube increases the lowest resonant frequency from 31 cycles /second to 34 cycles /second. This change in resonant frequency will have a negligible impact on the seismic loading'; therefore, the original tub design analyses confirm the adequacy of a tube / sleeve assembly.

In support of the limited test sleeve installation, analyses and tests have been conducted which demonstrate the structural aceauacy of hte tuce/ sleeve assembly for seismic and alI normal operating events

, N tt M hl A- +c WN {*d b Page 11 I b um64 A . wb

. -E. *r, alyses '.:cc:inueci ,

anticipa:ec for :ne entire plan: design life. ' Ca' culations nave beer.

e formec com;aring

ne s reng:n of a tuce wi-h nat of a sleeve.

Inese comparisons inclucet ne burs strength of :ne tuoing consicering :ne hoop stres: of the existing tube with full wall

nickness ( .050 -inches) and witn degraced wall :..ickness (.030 intnes). In both cases the sleeve has a lower hoop stress than the existing tube verifying that the 40% of wall degracation plugging criteria for existing tubes is also applicable for the sleeves. Also, the comparisons of :ne section moduli and cross sectional areas of the -

sleeve with th1se of the tube demonstrate that the sleeve performs in bending as well as or better than a tube (with acceptable wall thickness).

I C. Conformance with License Conditions The Technical Specifications and their bases have been reviewed to catermine whether changes are required to employ steam generator

,_, sleeves. Technical Specification 3.1.5 establishes a limit on primary or secondary leakage of 0.1 gpm. This limit, which was reviewed and -

approved by the NRC in Amendment No.16, transmitted on May 14, 1975, ensures steam generator tube integrity under postulated accident conditions. A comparison between hoop stresses in a steam generator tube, and stresses in a sleeve has been performed. Because of the smaller diameter, a sleeve can withstand the differential pr.essures better than a steam generator tube. Thus, a sleeve with a through-wall crack superimposed upon wastage will perform as well as, j or better than, a steam ' generator tube with a through-wall crack' superimposed upon wastage of the same magnitude (in terms of percent wastage). Therefore, since in either case the through-wall crack length is monitored by monitoring primary to secondary system leakage, the current Technical Specification and its Bases remain valid for sleeved tubes.

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Specification 4.2 governs the Inservice Inspection of steam generator tubes by references to the Ginna Station Inservice Inspection Program.

No changes are required in the Specification. The Inservice Inspection program is being revised to allow steam generator tube sleeving in lieu of plugging. This document is not a part of the

plant Technical Specifications and may be revised pursuant to 10CFR 50.59. Indeed, changes and subsequent implementation pursuant to 10CFR 50.59 may, on some occasions, be required to conform to 10CFR 50.55a. Inus, the change to the Inservice Inspection Program does not necessarily require NRC review and approval.

l Page 12 l

. i.". ?C5 '.'isTF__t, ;0" *:iSPECT:0NS A. Easeline Eccy Current *nsoections .

Tne 'M system inclucing eody current techniques, -obes anc driver' will be asec as follows for inspection to the test sleeves. The entire sleeve with the exception of the rolled area in the tubesheet will De scanned using a .610 inch diameter conventional annular differen-ial type probe. The probe will be inserted into the proper tube / sleeve using the positioner and pulled from the tube / sleeve at approximately 0.5 feet per second using the probe driver. The -

information will be obtained using the Zetec M1Z-12 multifrequency eddy current instrument. Data collected simultaneously at four frequencies will be stored on an 8 channel magnetic tape recorder.

The reason for using four' separate frequencies is to concentrate the inspection at specific areas, namely, the sleeve itself, the tube all in a single scan.

behind the sleeve, and the tubesheet component, Calibration curves constructed after initial system calibration will then be used to estimate the percentage of tube wall and percentage of sleeve wall extent of any flaw which may be detected.

m Af ter scanning with the annular probe, a radial absolute probe, with centering collars and spring loaded coil, will be used to interrogate both the brazed joints ani expanded areas of the sleeve. Once again, the probe will be driven using the SM-6, but this technique calls for rotating the probe while pulling. An apprcrimate scan rate of .5 inch per minute and 12 rpm will be used. Again multifrequency eddy current

~

will be used to allow simultaneous inspection of sleeve, tube and Instead, a rough tubesheet. No calibration curves will be used here.

estimate of flaw depth can ~be made by referring to calibration signals of flaws of known depth. Baseline inspection will incorporate the annual coil technique and the radial absolute technique.

B. Follow-On Inspection Follow-on eddy current inspections for the installed sleeves will be conducted during the planned Rochester Gas and Electric outage time's.

The next outage is planned for April,1981.

Follow-on inspections will continue to use the annular coil and radial l

absolute techniques as described above.

VI. G0AL OF TEST INSTALLATIONS A. Fall, 1980 f

1 t en sleeves are planned to be installed in the "B" steam generator on November 14-16, 1980. Mockup testing, demonstration and training is expected to be conducted November 3-13, 1980.

Page 13

Fali. 190.0 ':entinued)

The panary purpose of tne test i teve ins.i:ilation is to show that sleeves can be installed in an 0:a ational :.er: cenerator This wili confirm field aoplication of the 'aboratory :evel3Ded technioues, crocesses and oroceoures. Also, a. importa purpose is to orovide actual operational information as a part of the design verification process for the sleeves. This will provide a few sleeves with several months operational time lead over sleeves i stalled on a larger scale

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later to provide early warning if a time de:endent problem should develop.

B. Later Installations Substitution on a full scale of s'eeving fc pluccing of tubes with unacceptable tubesheet crevice eddy current indications will be determined based on field test evaluation c' the ten test sleeves to be installed in "B" steam cenerato and on 'urther desion verification

" efforts over the next few months. Based or. this evaluaEion, Rochester Gas and Electric will determine the numoer f tubes and the schedule for sleeving.

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FT.*o 'JP:. 1 - ST_AV G_ N D..AT OF*___V_:._

r PROPRIETARY s

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E0!IBIT B 3 Summer 1980 Addenda Date ofissue: June 30,1980

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ASME BOILER AND PRESSURE VESSEL CODE An American National Standard SECTION IX Welding and Brazing Qualifications 3..

1980 Edition Addenda to the loo >e-leaf version of the 1980 Edition of the Code are i>>ued in the form of replacernent pages. Revisions, additions, or deletions are incorporated directly it.to the af-fected pages. It is advisable, howevei, that these title sheet > and all replaced pages be retained for reference.

SUMMARY

OF CHANGES This is the first Addenda to be published to the 1980 Edition of Section IX.

Replace or insert the pages Inted. Changes gnen below are identified on the pages by a margi:i note, S80, placed next to the atfected area. The pagy> not li>ted are the reverse sides of the listed pages and contain no changes.

Page location Change xxiv Part QB Contents Entry for QS-410 added 3 QW-141.5 Revised S QW 161 Revned Footnote 2 Deleted QW-161.1 Third paragraph deleted QW-161.2 Second paragraph de!cted QW-161.3 Second paragraph deleted QW 161.6 Second paragraph deleted 6 QW-161.7 Second paragraph deleted 8 QW 192.4 Revised 10 QW-194 AdJed 11-14 QW-200.1 Revised QW-200.2 Revised QW 201 Fifth paragraph added QW-201.1 Delekd in its entirety QW 201.2 Deleted in its entirety Copyri6h t C 1980 THE AMERICAN SOCETY OF MECHANICAL ENClNEER$

All R 6 hts Reserved

e GENERAL RLQUIREMENTS -

QL1 1 WJlh Qil 140 TYPES AND PURPOSES OF gisen in QB-462.l(b) may be used for tensmn test-> on TESTS AND EXA.\11NAT10NS all thicknesses of pipe or tube basing an outade diameter greater than 3 m. The specimens may be s Qll 141 Tests . tested m a support tixture m substantial accordance Tests used in brazing procedure and performance with QB-462.l(f).

quahncations are as follows: -'-

11 151.3 Full Section Specimens - Pipc. 5pect- S80 Q11 141.1 Tension Tests. Tensmn tests are used to . . formmg to tne dimenuons given m QB- .l determme the ultimate strength of brazed butt, scarf, , 462.l(e) Juay be used ior tension tests on all thiek- {

lap, and rabbet jomts in pipe and plate. pipe or tube havmg an outside diameter of 3 QB 141.2 Guided Bend Tests. Guided bend tests -

are used to determme the soundness and ductility of butt and scarfjomts.

QB 152 Tension Test Procedure Sao k Qll 141.3 Peel Tests. Peel tests are used to The tension test specimen shall be ruptured under

, deternone the quahty of the bond and the number of

' temde I ad. De tenule strength shall be computed by unds in lap jomis.

dividing the ultimate load by the least c ros s-Qll 141.4 Sectioning Tests. Sectionmg tests, i.e., sectional area of the specimen as measured before i the sectioning of test coupons, are used to determme the load is applied.

j the soundness of workmanship coupon or test speen-N e i mens. Sectioning w.ts are also used as a substitute for QB 153 4 Acceptance Criteria Tension -T7sts the peel test where the strength of brazmg filler metal

{'

is equal to or grener than the strength of the base Q B.153.1 Tensile dtrength. In order to pan the metals. tenuon test, the specimen shall have a tensde strength~

~

' "" ' '* " L '"" L h"

• QB 141.5 Workmanship Coupons. Workmanship coupons are used to determme the soundness of jomts (a/ the specined mmimum tenule strength of the base metal m the annealed condition, or other than the standard butt, scarf, lap, and rabbet (b) the specitied mimmum tensde strength of the tomts. ,

v weaker of the two m the annealed condition, it metals S80 Q B-141.6 Visual Examination. Visual examma- ' of durereat specified mmimum tensde strengths are tion of brazed joints is used for estimatmg the used; or soundness by external appearance, such as contmuity (c) if the specimen breaks m the base metal outside S80 of the brazmg tiller metal, ute, contour, and wettmg of the braze, the test shall be accepted as meetmg the of tillet along the jomt and, where appropri:.te, to requirements, provided the strength is' not more than determme if fdler metal !! owed through the joint from 5% below the mmimum specined tensde strength of the side of application to the opposite side. the base metal in the annealed condition.

Qil 150 TENSION TESTS Qll-151 Specimens 00' '

Q11161 Specimens Sao Tenuon test specn-Meonform to one of the types dlustrated irQB-462.1}and shall meet the! Guided-bend test specimens shall be prepared by requnements ot yu-Ra. _

cuttmg the test plate or pipe to form specimens of approximately rectangular eross section. The cut Qll 151.1 Reduced Section - Plate, Reduced I surfaces shall be designated the sides of the specimen.

scetion specimens conforming to the requirements The other two surfaces shall be designated the first given in QB-462.l(a) and (c) may be used for tension and second surfaces. Guided-bend specimens are of tests on all thicknesses of plate. The spectmens may be

,Se types, dependmg on whether the axis of the jomt is tested in a support fixture in substantial accordance transverse or parallel to the longitudmal axis of the with Qll-462.1(c). specimen and which surface (first or second)is on the S80 QB 151.2 Reduced Section - Pipe. Reduced convex (outer) side of the bent specimen. The five section specimens conformmg to the requirements types are denned as follows.

139 1 "

• m :t*2 @ g NE.vs.7 %+D % r e p *~ w = e y W --] e W IR e W _ W , M

• 9 -

'* DATA - GRAPHICS Qts.462.ac), yts462.1(c)

Q L).462 Test Specimens (Cunt'd)

As specified to in, approx. (Note till by cesign 2in.R

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1 For raubet goints -

h 4 As specified by desegn --.

l This section machined l lj i

pr.fer.oiv by mining g v. in. i- x - '- x -  ; ,

i ii i r e,n 2 As specified I Il 1r

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..- x

.t.

x = 4 T min. or as specified by design r .

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For lap joints Alternate designs NOTE:

(1) Length may vary to fit testing machine.

Sao QB 462.1(c) TENSION REDUCED SECTION FOR LAP AND RABBET JOINTS PLATE

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o m,n.

4 i o min.

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--- " i._L.j i 2 0 min.

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• V Jaws of Testing Alternate for butt goents

,j f i vacnine [,\ l o min.

t l-4 Plug \ o min.

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For sep ,oints SSO ;8 462.'M . TE!. sic'. FULL SECT GN FOR LAP AND BUTT JOINTS - SMALL DIAMETER PIPE 177

j <>n.it.s.sufn.i72 SLL*llON IX - l'An !' Qu.111(AZ1. O Ull Ifil.1 't runnene l'irst Sur face llend. The Qll102 Guided Bend Test Procedure nint is transverse to the longitudmal .ixas of the spccancn winch is bent so that the first surface

" * * "' " 'E"""'"* ""

hecomes the conses surface of the bent specimen. In

"* 3 "## # *" * " " " "" #"

acacial the tirst suiface a defined as that surface from '""""E '" M * * "" """*""

U# " '" *E# '"#"#

which the brazmg tiller metal is apphed and is fed by t ward the gap of the jig shall be the u. *" face for rst sur camilarv attraction mto the jomt. Transverse tint "N"" *"

" * " * * ~

surface bend specimens shall conform to the dimen-Surface f r see nd surface bends dermed m QB-161.2.

uons shown m QB402.2(a).

The specimen shall be forced into the die by applymg Qll 161.2 Transverse Second Surface llend. The load on the plunger until the curvature of the jomt is transverse to the longitudinal axis of the specimen is such that a K in. (3.2 mm) diameter wire specimen which is bent so that the second surface cannot be inserted between the specimen and the die becomes the convex surface of the bent specimen. In of Q9-466.1 or the specimen is bottom ejected, if the gneral the second surface is defined as the surface roller type ofjig. QB 460.2. is used.

opposae to that from which the brazmg tiller metal is pla.ed or fed. but derimtely n the surface opposne to When usmg the wrap around jig. OB466.3. the side of the specimen turned toward the roller shall be the lint surface for first surface bends, and the second h

that Jesignated as the tirst surface irrespectne of how the hratmg tiller metal n fed. Transvene second surface for second surface bends.

surface bend specimens shall conform to the dimen-sions shown in Qll462.2(a)- Qll 163 Acceptance Criteria - Bend Tests Qll- 161.3 Subsiec Transverse llend. In those The jomt of a transvene bend specimen shall be cases where the wall thickness of the tube or pipe is completely withm the bent portion of the specimen less than % in. (10 mm) and the diameter to-thickness after tesung.

rano does not permit the preparanon of full-uze The guided bend specimens shall have no open rectangular guided bend specimens, the IZ m. (38 defects exceeding Z m. (3.2 mm) measured m any mm) wide standard guided bend specimen shown in direction on the convex surface of the specimen after Qll462.2(a) may be replaced by three subuze speci- bendmg. except that cracks occurrmg on the cornen mens havmg a width of % m. (10 mm) or 4t, of the specimen dunng testmg shall not be considered, whichever a less. unless there n delimte evidence that they result f rom Qll-161.4 Longitudinal llend Tests. 'Longitudmal bend tests may be used m lieu of the transvene bend tests for tesung brate metal or base' metal combma-oons which dufer markedly m bendmg properties .

D"'*"

(a/ the two base metals, or Qll-170 PEEL TESTS (b/ the braze metal and the base metal. Qll-171 Specimens Qll 161.5 Longitudinal l'irst Surface llend. The The dimenuens and preparanon of the peel st jomt n parallel to the longitudmal axn of the specimen s c men shall conform to the requirements of Qll- .,,

u tuch is bent so that the first surface becomes the 2 3-convex surface of the bent specimen. The delimuon of lint surface is as gnen m Qll 161.1. Longitudmal first Acceptance Cnteria '

Qll 172 Peel Test Saa surface bend specimens shall conform to the dimen-sions gnen m QB-462.2(b). In order to p.m mc sees test, the specimens shall show evidence of brazmg tiller metal along each edge Qil161.6 Longitudinal Second Surface llend. of the jomt. Specimens shall be separated or peeled The jomt a parallel to the longitudmal axn of the enher by clampmg Secuon A and sinkmg Secuan B specimen which n bent so that the second surface wah a sunable tool such that the bendmg occurs at the becomes the convex surface of the specimen. The fulcrum pomt (sec Qll-462.3), or by clampmg bection denmtion of the second .urface is given in Qll-16L2. A and Secuon B m a machme sunable for separatmg Longitudmal second surface bend specimens shall the sections under tension. The separated faying conform to the dimensions given m QB-462.2(b). Surfaces of jomts shall meet the followmg entena.

140

% .e* W. - . , . . g.mqmst ' ' . ~.".' '; - *' ' - ' ' * - - ' ~ *~~ ' * ' ^ ' ***

/ t)ll-305 4)ll J51 SliCrlON IX - PART QB, llRAZING-Qll 305 liraeing Opcotors prescribed in QU-452 may be retested under the

's followmg conditions:

.r.ue brazing operator who prepares brazing proce-

'~; dure quahiieauon test specimens meeting requirements Qll 321.1 Immediate Rctest. When an immediate of ()ll-451 is thereby qualified. Alternatively, each retest is roade, the brazer or braemg operatur shall brazing operator who brazes on esels constructed make two consecutive test coupons for each pwtion under the rules of this Code shall be examined for which he has failed, all of which shall pass the test each brazing procedure under which he does brazing requirements. <

by semiautomatie or automatic processes (such as the QB 321.2 Further Training. When the brazer or resistance, induction, or furnace processes) as follows:

brazmg operator has had further traming or practice, (a) A typical joint or workmanship coupon em- a complete retest shall be made for each position on bodymg the requirements of a qualified brazing which he failed to meet the requirements.

procedure shall be brazed and sectioned. Typicaljoints are shown m QIl-462.5.

(b) in order to assure that the operator can carry Qll.322 Renewal of Qualification s out the provisions of the brazing procedure, the test Renewal of quahtication of a performance qual-sections required m (a) shall meet the requirements of itication is required.

Q B'4" "" (1) when a brazer or brazing operator has not used the specilie bratmg process for a pened of 0 Qll 310 QUALIFICATION TEST COUPONS (2) when there is a specific reason to quesuon his QIl-310.1 Tcst Coupons. The test coupons may be ability to make brazes to meet the specification.

plate, pipe, or other product forms. The dimensions of Renewal of qualificauon for a spectric brazmg proecss the test coupon and length of braze shall be sutlicient under (1) may be made with specific brazing proechs to provide the required test specimens. by making only one test joint (plate or pipe) with all the essential vanables used on any one of the brazer's Qil-310.2 liraze Joint. The dimensions of the or brazmg operator,> previous quahficauon test joints.

braze joint at the test coupon used in making This will re-establish the brazer's or brazing operator's qualification tests shall be the same as those in the qualification for all conditions for which he had Braze Procedure Specification (BPS). previously qualified with the specific brazmg process.

t.

Qll 310.3 Dase .\letals. When a brazer or brazmg operator is to be qualified, the test coupon shall be base metal of the P Number or P-Numbers to be jomed in production brazmg. QB 350 BRAZING VARIAllLES FOR BRAZERS AND BRAZING OPERATORS QB-320 RETESTS AND RENEWAL OF cnera 80 Q

QUALIFICATION

^ ***# # ***"E E##" ' "" '"4"*

Qll-321 Rctests whenever a change is made m one or more of the e

'E A brazer or brazmg operator who fails to meet the essential variables for each brazmg process, as hated m requirements for one or more of the test specimens QB-352 througn QB-357.

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,a GENhKAL REQUIREMLNTS yu-872-qtslM2 r

{ w I he intal as ca of der.:ets (unbrated areas. Ilux Q U-462.4 3 ch side of the speennen shall be pohshed

{ melusinns. etc.) shall not exceed 30CL of the total area ano exammed wah at least a four-power magmfung bf any mdividual faymg surface. glass. The sum of the length of unbrazed areas on s F bi The sum of the lengths of the deicets measured either sale, considered mdividuaily, shall not exceed {

I on any one hne m the direction of the lap shall not .ug of the iengin of thejoint overlap.

exceed 25cb ef the lap. .-

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(c/ No defect shall extend continuously from one .

Qll.182  %.orkmanship Coupons S80 cdge of the jomt to the other edge, irrespective of the .

direction of the defect. The dimensions and conGguration of the workman-L ship coupon shall conform to the nearest approxima-tion of the actual application. Some typical workman.

Q11 180 SECTIONING TESTS AND ship coupons are shown in Qll-462.5. Each side of the WORK.\lANSill!' COUl'ONS specimen shall be polished and examined with at least a four-power magmfymg glass. The sum of the length S80 Qll-181 Sectioning Test Specimens q of unbrazed areas on either side. considered individu-

1. The dimensions and con 6guration of the sectioning ally, shall not execed 200b of the length of the jomt test specimens shall conform to the requirements of overlap.

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h 140.!

M." Q q Q ?& W E< Q ) R M L W f % f 1- m_mr: ~- AWK WW5S!'  ?

/ Oll.462.3-Qil-462.4 SECTION IX - pal (T QB, BRAZING QB 462 Test Specimens (Cont'd) 10 in, approx.3 t

7 NOTES: .

ll l 11) Fiange y may be omitted from lI l 1 1/2 in. Section 6 wnen " peeling ** is to be l Ecomphshed in a swatable t i isns.on m. chin..

(2) Specimen shall be brazed f rom sade marked 2.

Z N Section A (3) Length may vary to fit Section 8

\ ll l testing machene.

l  ?

X = 4 T min. or as required by casagn *

[ d Approximately. or suf f acient -

Fu.crum Point for peehng purposes S80 08-462.3 i.AP JOINT PEEL SPECIMEN

^

Descard i This Piece ' 1/3 W s W " 1 I/2 in. Sec tion V Specimen w==

[1/3W l Descard

,  ! This Piece , I/3 W 2 '

X -

Section A l l Section 8 l 7 l l l l l

! l l l l X = 4 T min. or es recuared by design "

1 1/2 in. r l

i Alternate for raccet joint NOTE:

(1) Specimen sheil De brated f rom sade marked 2.

08 462.4 LAP JOINT SECTION SPECIMEN (SEE 08-181) 180 l

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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-OLA

) 50-301-OLA (Point Beach Nuclear Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE Copies of Testimony of R. A. Wiesemann on Behalf of Westinghouse Electric Corporation and Applicants in Response to ASLB Questions Dated March 25, 1982 in the above-captioned proceeding was served upon the persons listed on the attached Service List by deposit in the United States Mail, First Class, postage prepaid, this 14th day of April, 1982.

)

1. 4 . Vi ohn R Kenrick A ey for Westinghouse Electric Corporation, Appearing Specially I

, c--- w ,- , ~

n- , -_.

Servico List WISCONSIN ELECTRIC POWER COMPANY (Point Beach Nuclear Plant, Units 1 and 2)

Potor B. Bloch, Esq., Chairman Stuart A. Treby, Esq.

Atomic Safety and Licensing Board Office of the Executive Legal Director Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline Westinghouse Electric Corporation Atomic Safety and Licensing Board Nuclear Energy Systems Division Panel P. O. Box 355 U.S. Nuclear Regulatory Commission Pittsburgh, Pennsylvania 15230 Washington, D.C. 20555 Bruce W. Churchill, Esq.

Dr. Hugh C. Paxton Gerald Charnoff, Esq.

1229 - 41st Street Shaw, Pittman, Potts & Trowbridge Los Alamos, New Mexico 87544 1800 M Street, Northwest Washington, D.C. 20036 Atomic Safety and Licensing Board Panel - Barton Z. Cowan, Esq.

U.S. Nuclear Re'gulatory Commission John R. Kenrick, Esq.

Washington, D.C. 20555 Eckert, Seamans, Cherin & Mellott 42nd Floor, 600 Grant Street Atomic Safety and Licensing P,ittsburgh, Pennsylvania 15219 Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. S. Scott Central File Room Docketing and Service Section U. S. NRC Office of the Secretary Phillips Building U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Washington, D.C. 20555 Bethesda, Maryland 20014 Charles A. Barth, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Kathleen M. Falk, Esq.

Wisconsin's Environmental Decade Suite 208, 114 North Carroll Street ,

Madison, Wisconsin 53703 Richard G. Bachmann, Esq.

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

_.