ML19347A852

Notifies That Util Has Been Served W/Wi Environ Decade, Inc 800808 Ltr to Senator Proxmire & Congressman Zablocki. Ltr Alleges Corrosion Problem in Steam Generator Tubes. Ltr Encl

ML19347A852
Person / Time
Site:	Point Beach
Issue date:	09/25/1980
From:	Oneill J SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Cole R, Grossman H, Leeds J Atomic Safety and Licensing Board Panel
References
ISSUANCES-CO, NUDOCS 8009300410
Download: ML19347A852 (7)

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$$b!$ "$"%"o'!" September 25, 1980 Herbert Grossman, Esq. Dr. Richard F. Cole Chairman Atomic Safety and Licensing Board j Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission '

U.S. Nuclear Regulatcry Commission Washington, D.C. 20555 l Washington, D.C. 20555  !

i Dr. J. Venn Leeds I 10807 Atwell Houston, Texas 77096 Re: Wisconsin Electric Power Company (Point Beach Nuclear Plant Unit 1) Docket No.

50-266 CO (Modification of License)

Gentlemen:

Wisconsin Electric Power Company has been served with copies of correspo..dence to Senator William Proxmire and Congressman Clement Zablocki from William Dircks, Acting Executive Director for Operations, and to Kathleen M. Falk, Wisconsin's Environmental Decade, Inc., from James Murray, Office of Executive Legal Director, regarding letters directed to Senator Proxmire, Congressman Zablocki and the Commissioners from Wisconsin's Environmental Decade, Inc.

dealing with the subject matter of the above captioned proceeding.

Wisconsin Electric has responded to the allegations set forth in  !

the letters to Senator Proxmire and Congressman Zablocki by letters l dated September 24, 1980. The letter to Senator Proxmire is i enclosed with this letter; an identical letter was sent to l Congressman Zablocki.

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SHAW, PITTMAN, POTTS & TROWBRIDOE A copy of this letter and the enclosed letter to Senator Proxmire is being served on all parties to the above proceeding.

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.P Joh H. O'Neill, Jr.

I cou sel for Wisconsi M lectric P wer Company Enclosures cc: Service List

Wisconsin Electncmeacoursur 231 WEST MICHIGAN, MILWAUKEE, WISCONSIN 53201 September 24, 1980 .

The Honorable William Proxmire United States Senate Washington, D.C. 20510 l

Dear Senator Proxmire:

The Nuclear Regulatory Commission (NRC) recently provided us with a copy of a letter to you from Wisconsin's Environmental Decade, Inc. (Decade), dated August 8, 1980, which asserts that a dangerous condition exists at Wisconsin Electric Power Company's Point Beach Nuclear Plant, Unit 1. Of course, such is not the case. Decade, in its opposition to i nuclear power, has over the years become somewhat accomplished '

in linking series of statements out of context, selected facts, half-truths, and outright distortions, and we believe that you should be apprised of the actual facts. We invite you to compare the information in this letter with the hyperbole and alarmist allegations presented to you by Decade.

The two steam generators in Point Beach Unit I have been subject to c form of corrosion, called intergranular attack, on the steam generator tubes within the long. crevice in the' thick (23 inch)' metal boundary (tubesheet) between the reactor coolant and steam generator water. At times this corrosion has resulted in a crack in a tube itself permitting a leak of reactor coolant into the steam generator. All tubes which have exhibited cracks or significant intergranular attack have been removed from service by plugging. All steam generator tubes are now subject to a periodic inspection program to detect evidence of intergranular attack prior to any evidence of a leak. This problem is not unique to Point Beach Unit 1, but has been observed in a number of nuclear plants of approximately the same age and design, both in this country and abroad.

Decade asserted in its letter to you that " Point Beach Unit 1, which previously experienced the single worst tube rupture of any plant in this country, is also presently experiencing the worst observed rate of continuing tube degradation of any of the nation's nuclear reactors." Neither statement is factually correct. Of course, what is important l l is whether there is any safety significance to a tube rupture l or tube degradation -- whether or not it is the " worst", best, I or somewhere in between. There was no health or safety impact l

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The Honorable William Proxmire September 24, 1980 Page 2 i

from the steam generator tube leaks or tube rupture at ' Point Beach. Any radiological releases from steam generator tube leakage was many time below the maximum allowable. Wisconsin Electric, its consultants, and the NRC have considered the safety significance of the steam generator tube degradation problem at Point Beach. Wisconsin Electric has taken certain '

actions with NRC concurrence to insure that Point Beach Unit 1 continues to operate safely while the most effective repair i

program for the steam generators is selected and implemented. '

In its letter to you, Decade engages in a vitriolic attack on the NRC. Decade may be venting its frustration in having failed to convey to the NRC that its position on the steam generator tube degradation problem has any merit. But i again Decade's attack missed the mark by a wide margin. If {

anything, the NRC has become cautious in the extreme since Three Mile Island. Decade's quote from the Kemeny Commission s Report is incomplete--perhaps deliberately so.

In fact, the NRC has been responsive to the steam generator concerns. The NRC Commissioners were formally briefed on the steam generator tube degradation problems at

' Point Beach on two occasions, once by representatives from Decade. Decade raised the safety issues set forth in its letter to you by petitions to the Commission on two separate occasions. After preparing a safety evaluation report, which addressed Decade.'s concerns, the Director, Nuclear Reactor Regulation, rejected Decade's position as unfounded on each occasion. The Director's decision was not overturned by the Commissioners after their review. We should point out that the NRC would have conducte,d its review without Decade's involve-

ment.

Decade cites a 1975 American Physical Society report in support of its allegations. Again Decade quotes material out of context. The purpose of the American Physical Society j

study was to critique the light water reactor safety program in general and the emergency core cooling system (ECCS) interim acceptance criteria established by the Atomic Energy Commission in particular. The American Physical Society report pointed i out areas where it believed additional research or conservation could be introduced in the ECCS analysis. The question postulated by the American Physical Society deals with a loss-of-coolant accident to the reactor followed by a number of steam generator tube ruptures which in theory could result in restricted flow of emergency cooling to the reactor core. I The principal reason that this concern is not applicable to the situation at Point Beach Unit 1 is fairly

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4 i The Honorable William Proxmire September 24, 1980 Page 3 simple. The postulated problem requires a number of

, " double-ended" breaks of steam generator tubes. The tube degradation at Point Beach occurs within the 23-inch tubesheet.

Thus, a tube break would be physically restrained by the tubesheet, and the postulated double-ended breaks of steam generator tubes could simply not occur. To demonstrate the integrity of Lne steam generator tubes, on a periodic schedule, the tubes are subjected to a hydrostatic test--a high differential pressure across the tubes approximating the forces  :

which might be caused by a loss-of-coolant accident. '

Wisconsin Electric has taken a number of steps to insure the plant is being operated safely notwithstanding the  :

steam generator tube problem. The plant is being operated at a

, lower temperature at approximately 804 power level in order to

inhibit the rate of tube degradation, which appears to be

related to temperature. The Company is conducting more frequent periodic inspections of all steam generator tubes and is regularly conducting the hydrostatic differential pressure test described above to insure the integrity of the system boundaries. These measures have been approved by the NRC and, i . in some cases, have been confirmed by an NRC Order. Most recent inspections appear to indicate a reduction in the rate of tube degradation.

Decade's complaints that it has not been afforded an

opportunity for.a hearing on these issues go to the NRC Confirmatory orders confirming the actions taken by Wisconsin Electric. Decade has petitioned for a public hearing regarding these Orders. An Atomic Safety and Licensing Board presently has before it the question of whether, as a matter of law, Decade has a right to such a hearing. The " stinging dissent"

{ by two NRC Commissioners referred to by Decade goes only to the policy question relating to the circumatances as to when a public hearing should be provided. It has nothing to do with the merits of the situation at Point Beach.

Wisconsin Electric has one of the finest operating records of any utility in the country at its Point Beach Nuclear Plant. No one is more interested in the absolute safe operation of the Point Beach Plant than those of us responsible for its opera'lon c and maintenance. The actions that have been taken at Point Beach insure its safe operation until necessary repairs are accomplished.

The Honorable William Proxmire September 24, 1980 Page 4 We appreciate this opportunity to set the fact's straight. We, of course, would be happy to answer any questions that you might have.

Very truly yours,

_ ^D hw tb Exe utive Vice President Sol Burstein cc: Nuclear Regulatory Commission NRC Atomic Safety and Licensing Board Public Service Commission of Wisconsin Wisconsin's Environmental Decade, Inc.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION THE ATOMIC SAFETY AND LICENSING BOARD i

In the Matter of )

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WISCONSIN ELECTRIC POWER COMPANY ) Docket No. 50-266 CO (Point Beach Nuclear Piant, ) (Modification of License)

Unit 1) )

SERVICE TIST Herbert Grossman, Esq. C. F. Riederer, P. E.

i Chairman Public Service Commission

Atomic Safety and Licensing Board of Wisconsin l'

U.S. Nuclear Regulatory Commission Hill Farms State Office Washington, D.C. 20555 Building 4802 Sheboygan Avenue '

Dr. Richard F. Cole Madison, Wisconsin 53702 I Atomic Safety and Licensing Board U.S. Nuclear Regulato;y Commssion Kathleen M. Falk, Esquire j Washington, D.C. 20555 Wisconsin's Environmental Decade, Inc. - Suite 205 i

Dr. J. Venn Leeds 302 East Washington Avenue 10807 Atwell Madison, Wisconsin 53703 Houston, Texas 77096 Docketing and Service Section i

Karen D. Cyr, Esquire Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory I

Office of the Executive Commission Legal Director Washington, D.C. 20555 Washington, D.C. 20555

, Patrick Walsh, Esquire Assistant Attorney General State of Wisconsin Department of Justice 114 East State Capital Madison, Wisconsin 53702 Ms. Jacqueline K. Reynolds Assistant Secretary to the Commission Public Service Commission of Wisconsin Hill Farms State Office Building 4802 Sheboygan Avenue l Madison, Wisconsin 53702 l

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