ML20054L986

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Response to First Interrogatories & Request for Production of Documents Re 820416 Ler.Certificate of Svc Encl
ML20054L986
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 07/07/1982
From: Churchill B
SHAW, PITTMAN, POTTS & TROWBRIDGE, WISCONSIN ELECTRIC POWER CO.
To:
WISCONSIN'S ENVIRONMENTAL DECADE
References
NUDOCS 8207090126
Download: ML20054L986 (12)


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, t h' July 7, 1982 fh3[E3 s T2 J -9 rg r-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r-7, vv n ,

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L:au.;,i Before the Atomic Safety and Licensing Board In the Matter of )

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

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

(Units 1 and 2) )

LICENSEE'S RESPONSE TO DECADE'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS ON LICENSEE RELATIVE TO THE APRIL 16, 1982 LICENSEE EVENT REPORT i

Licensee herein responds to "Dec'ade's First Interrogatories and Request For Production of Documents on Licensee Relative To The April 16, 1982 Licensee Event Report,"

served on June 23, 1982.

!. Decade's discovery request is made pursuant to the Board's I

Order of June 18, 1982 which permitted Decade to conduct discovery about information contained in Licensee Event Report l

No. 82-007/OIT-0, dated April 16, 1982 ("LER 82-007"). In that l

l Order, the Board expressly prohibited Licensee from objec. ting to such discovery requests "on the ground of lack of general 8207090126 820707 PDR ADOCK 05000266 PDR G

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I relevance." Accordingly, Licensee refrains herein from making such objections. Licensee does, however, object to each and every one of the interrogatories on the ground that noia relates to information contained in LER 82-007.

LER 82-007 is a report of a detailed visual inspection of the Unit 1 steam generator tube sheet which noted minor leakage in some steam generator tubes, including some leakage from explosive plugs. Six of Decade's seven interrogatories relate

' solely to decontaminati.on of steam generators; LER 82-007 neither mentions nor relates to steam generator decontamina-tion. The seventh interrogatory relates solely to the inspec-tion of tubes from which mechanical plugs have been removed; LER 82-007 includes reference only to tubes which contain explosive plugs or from which explosive plugs have been removed.

Notwithstanding the total irrelevance of the interroga-tories to the document which formed the basis of the Board's decision to allow Decade to file special out-of-time discovery requests on Licensee, Licensee is voluntarily providing an attachment to this response which contains answers to the interrogatories. Li.censee is answering the interrogatories for the sole purpose of avoiding a time-consuming discovery dispute which could potentially jeopardize the extremely important hearing schedule. Licensee's answers should in no way be construed as an acknowledgment of any obligation on Licensee's E

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part to answer the interrogatories or as a waiver of Licensee's rights to object to answering the interrogatories.

Respectfully submitted,

. SHAW, PITTMAN, POTTS & TROWBRIDGE f(#C) (

By: ,e , t e W e W. W urchill Delissa A. Ridgway Counsel for Licensee

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1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: July 7, 1982 s

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

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

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

Units 1 and 2) )

Attachment LICENSEE'S VOLUNTARY ANSWERS TO DECADE'S JUNE 23, 1982 INTERROGATORIES

1. State whether any alternative steam generator decontamination processes have been formally or informally considered other than the one identified in the proprietary portion of S 2.1 to the Point Beach Nuclear Plant Sleeving Demonstration Report (" Point Beach decontamination process").

If so, describe all facts and/or information relating to such consideration.

RESPONSE

As stated in the Point Beach Nuclear Plant Sleeving Demonstration Report, the decontamination process to be used in full-scale sleeving will use a different decontamination medium than was used in the demonstration program. The equipment and tooling of both processes are essentially ~ identical. These decontamination processes are described in Sections 8.1-8.4 of

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the Point Beach Steam Generator Sleeving Report, WCAP-9960, Revision 1, February 1982 (" Sleeving Report") and Section 8.1 of the Steam Generator Repair Report for Southern California Edison San Onofre Unit 1, March 1981 ("SCE Repair Report").

Licensee has been informed recently of the potential for consideration of a chemical decontamination method which may be applicable to Point Beach steam generators. Licensee has no informa*.Aon regarding the details of this process, other than that it utilizes a chemical substance that is in no way harmful to steam generator tubes. Licensee has no present intention of using this process for the Point Beach sleeving program .

2. Describe any information relating to the effects of the Point Beach decontamination process on the steam generators, or any other part of the plant.

RESPONSE

The effects of the Point Beach decontamination process on the steam generators and systems are discussed in Sections 8.1-8.4 of the Sleeving Report and Appendix C, Part D, of the SCE Repair Report. There are no adverse effects on the steam generator tubes, tube ends or other plant systems and compo-nents.

3. Describe any information relating to the effects on steam generators of any other nuclear facility of the Point Beach decontamination process.

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RESPONSE

A discussion of experience at other operating nuclear

. plants with decontamination processes the same as, or similar to, the process to lxt used in full-scale sleeving at Point Beach is provided in Section 8.5 of the' Sleeving Report and Section 8.5 of the SCE Repair Report. In no case was there any indication of damage to steam generator tubes, tube ends or other plant systems or components.

4. Describe any information relating to the effects on steam generators of any other nuclear facility of any other steam generator decontamination process, whether preparatory to sleeving or to any other inspection, test or repair.

RESPONSE

See response to Interrogatory 3. Licensee has no.addi-tional information regarding decontamination of steam genera-tors at other facilities.

5. Describe in complete detail the Point Beach decontamination process, except as specifically described previously in the Westinghouse Sleeving Report or the Point Beach Nuclear Plant Sleeving Demonstration Report.

RESPONSE

In addition to the detail provided in the Sleeving Report, the decontamination process is also described in Sections 8.1-8.5 and Appendix C, Part D, of the SCE Repair Report.

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6. State whether any deformation, damage or other impairment of the tube ends has ever been observed in the steam generators of the Point Beach Nuclear Plant, except as spe-cifically described in the November 13, 1981 Licensee Event Report.

RESPONSE

No deformation or damage of tube ends has been observed in the Point Beach steam generators. Minor restrictions of tube ends have been occasionally observed in the steam generators of the Point Beach Nuclear Plant during eddy current inspections and during the Unit 1 eleeving demonstration outage. The restrictions are of no significance and can be removed by honing or by dissolving boric acid crystalline deposits in the primary coolant. To allow the passage of a tube sleeve, the O.D. of the sleeve can be machined if honing does not clear the restriction. In no case has the integrity of the subject tubes been affected by the restriction or clearing of the restric-tion. The restrictions are documented,in Licensee Event Reports and Westinghouse Field Service' Reports previously reported to Wisconsin's Environmental Decade in response to previous interrogatories.

7. State the eddy current test results or any other test results of the tubes with mechanical plugs removed during the Point Beach Sleeving Demonstration Program as referenced in the Westinghouse Field Service Report of the October 15 to November 23, 1981 site visit, or any other results not referenced in said Report. Also state whether any steam generator tubes, previously plugged by mechanical means, have at any other time subsequently been tested or inspected to determine whether the tube wall integrity has changed following the insertion of the mechanical plug. Include the results of the test or inspection following inspection in comparison to m
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the latest test or inspection results prior to plugging.

(Note: this interrogatory is revised from 1 10 in the Decade's Second Interrogatories.)

- RESPONSE Licensee has responded previously to an earlier version of this interrogatory. See Licensee's Response to' Decade's Second Interrogatories and Request for Production of Documents on Licensees Relative to Full Scale Sleeving' Program at-response to Interrogatory No. 10. Licensee is not aware of results other than those referenced in that response.

e UNITED STATES OF AMERICA .,

~ l NUCLEAR REGULATORY COMMISSION

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Before the Atomic Safety and Licensing Board

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WISCONSIN ELECTRIC TOWER COMPANY ) Docket Mos.'50-266

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

Units 1 and 2) ]) ,.

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AFFIDAVIT OF DAVID K. PORTER

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County of Milwaukee ') '

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State of Wisconsin )' .-

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 Department of Wisconsin Electric Power Company.

I graduated from the University of Illinois with a bachelor of science degree in electrical engineering in 1965. I then spent four years in the U. S. Navy's Nuclear Power Program which included one year in training and three years of reactor operator experience as an engineering officer aboard a nuclear-powered cruiser. I joined the Nuclear Projects Office of Wisconsin Electric in 1969 and have been involved in various engineering assignments relating to the Point Beach Nuclear Plant and preconstruction nuclear projects since that time. As Manager of the Nuclear Engineering Section, I am responsible for providing

technical, licanning, and engin:cring cuppert to the Point Beach Nuclear Plant. These responsibilities include the technical

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, review of plant equipment and repair specifications, and implemen-tation of U. S. Nuclear Regulatory Commission ("NRC") licensing actions involving Wisconsin Electric's operating nuclear facilities.

I am personally familiar with repair of the Point Beach Euclear Plant steam generators and our applic,atiori before the NRC with

't respect to these activities.

2. I have prepared or participated in the preparation of

" Licensee's Voluntary Answers'to Decade's. June 23, 1982 Interro-gatories", dated July 7,1982; the information contained in those responses is true and correct to the best of my knowledge and belief. _.

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Subscribed and sworn to before me this 7th day o July, 1982.

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July 7, 1982 G

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

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WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266

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

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to Decade's First Interrogatories and Request for Production of Documents on Licensee Relative to the April 16, 1982 Licensee Event Report" and " Licensee's Voluntary Answers to Decade's June 23, 1982 Interrogatories" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 7th day of July, 1982, except that those whose names are marked by an asterisk were served by deposit with Federal Express, this 7th day of July, 1982.

AAa . 0m 7 y delisstr' { Ridgfay ()

Dated: July 7, 1982

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

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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 Westinghouse Electric Corporation Atomic Safety and Licensing P. O. Box 355 Appeal Board Panel Pittsburgh, PA 15230 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Barton Z. Cowan, Esq.

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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