ML20054H993
| ML20054H993 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/22/1982 |
| From: | Patricia Anderson WISCONSIN'S ENVIRONMENTAL DECADE |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8206250297 | |
| Download: ML20054H993 (2) | |
Text
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Mr.
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Denton, Director m 22om Office of Nuclear Reactor Regulation U.
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Nuclear Regulatory Commission Washington, D. C. 20555 Re: Point Beach Nuclear Plant Unit 1 Docket 50-266 (Steam Generator Replacement)
Dear Mr. Denton:
Reterence is made to the Licensee's letter dated May 27, 1982, stating its intention to replace the two steam generators at Point Beach Nuclear Plant Unit I without requesting a license amendment from the Commission under 10 C.F.R. S50.59.
This is to state our objection to the Licensee's intention and indicate our opinion that a license amendment is required for tnis major overhaul.
Replacement of steam generators poses unresolved safety questions in view of the fact that tubes in the new steam generators will be subject to rupture in normal operation and during a large loss-of-coolant-accident.
With respect to normal operation, the January 25, 1982 steam generator tube rupture at Ginna Nuclear Plant demonstrated that tne interaction of a large tube rupture during normal operation in a facility suffering from brittle reactor vessel wall can lead to uncoolable conditions that was never contemplated in the Point Beach final safety analysis report.
Witn respect to LOCA conditions, the interaction of tube ruptures followed by steam binding during a large LOCA has never been evaluated in the Point Beach PSAR.
Replacement of steam generators also poses unresolved safety problems, among otner things, from the standpoint of worker exposure and non-permanent disposal of the old steam generators.
For the foregoing reasons, the Licensee should be required to apply for a license amendment before proceeding with replacement of the two steam generators at Point Beach 1.
This letter may not be treated as anything but an objection to the Licensee's May 27 letter of intent to not apply.
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,y1 PETER ANDERSON Director of Public Affairs PA/mt-P:50266NRC.L43 cc:C. W.
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