ML19210E407

Statement in Support of Wi Environ Decade Petition Objecting to Startup of Facility.Degradation of Steam Generator Tubes Presents Threat to Public.Urges Commission to Grant Hearing.Certificate of Svc Encl

ML19210E407
Person / Time
Site:	Point Beach
Issue date:	11/28/1979
From:	Pollard R, Weiss E UNION OF CONCERNED SCIENTISTS
To:	NRC COMMISSION (OCM)
References
NUDOCS 7912050003
Download: ML19210E407 (4)

Text

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.- yg UNITED STATES OF AMERICA

' BEFORE THE NUCLEAR REGULATORY COMMISSION 9% l

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1. a In the Matter of ) .c

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POINT BEACF NUCLEAR PLANT, UNIT 1 ) 0]'

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Petition of Wisconsin's Environmental ) \F iu'!2I ^H7 Decade, Inc. ) \ sA

\\N, 7 i' .w s @s l UNION OF CONCERNED SCIENTISTS

STATEMENT IN SUPPORT OF PETITION

• The Union of Concerned Scientists supports the petition t,

i, filed by Wisconsin's Environmental Decade to prevent start-up of

.' Point Beach Unit 1 because the degradation of steam generator tubes poses a present threat to public health and safety. In addition, UCS urges the Commission to review the bases for permitting contin-ued operation of all other pressurized water reectors which have experienced steam generator tube degradation and/or which have been granted operating licenses pending resolution of the generic study of this unresolved safety problem on the ground that increased inspection and maintenr. ace programs would detect degraded tubes.

The Commission must keep in mind that there are two separate issues raised by the petition. The first question has to do with compliance with the Point Beach technical specification limiting the percentage of steam generator tubes that can be plugged without restriction on plant operation. This limitation is required so as to ensure the.t the Commission's ECCS criteria are met. The second issue - and UCS believes the more important one - is the justifica-tion for the assumption that all unplugged steam generator tubes would maintain their integrity in the event of a LOCA. This pro-blem is more serious because the rupture of a small number of steam 7912050 0 0 3 p

generator tubes during a LOCA would add heat and steam to th; primary system which would exceed the ECCS design bases. Para-graph 23 of the petition quotes extensively from the American Physical Society report on this subject, which concludes that rup-ture of one to ten tubes could " induce essentially uncoolable con-ditions in the course of a LOCA."

The safety problems associated with steam generator tube degradation constitute one of che generic unresolved safety problems and have been known to the Commission for years.- The petition deals in detail with the various rationales that have been constructed by the staff for permitting plants to go into operation and to continue in operation despite the fact that the problem remains unresolved.

The basic staff argument has been that an "early warning system" of increased inspection would discover degraded tubes so that they could be plugged or other corrective action taken. The petition clearly establishes that this system cannot be relied upon; it failed to detect tube corrosion of up to 50% of the tube wall thick-ness. In the face of this evidence, operation of Point Beach based upon reliance on inspection and maintenance cannot be justified.

The problem does not stop at Point Beach. The same rationale has been cited by the staff as a basis for permitting continued operation of other plants experiencing tube degradation and has also been provided to Atomic Safety and Licensing Boards as a basis for the issuance of construction permits and operating licenses. UCS believes that petitioners' request for a hearing on steam generator tube degradation prior to restart of the Point Beach nuclear plant

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a should be granted. The Commission should also decide whether to modify, suspend, or revoke the operating licenses and construction permits of other pressurized water reactors to compensate for the absence of a valid resoluti a to the generic safety problem of steam generator tube degradation.

Submitted by the Union of Concerned' Scientists By b <. / t_ fk Robert D. Pollard Ellyn R. Weiss DATED: November 28, 1979

UNITED STATES OF AMERICA BEFORE TEE NUCLEAR REGULATORY COMMISSION In the Matter of )

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POINT BEACH NUCLEAR PLANT, UNIT 1 )

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Petition of Wisconsin's Environmental )

Decade, Inc. )

CERTIFICATE OF SERVICE I hereby certify that a copy of the " Union of Concerned Scientis ts Statement in Support of Petition" were hand-delivered this 28th day of November, 1979 to the following parties:

Joseph Hendrie, Chairman U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard Kennedy, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Peter Bradford, Commissioner U. S. Nuclear Regulatory Commission Washington, D. C. 205" John Ahearne, Commissioner U. S. Nucl ar Regulator 3 Commission Washingto.., D.C. 20555

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• Sol Burstein, Executive Vice-President Wisconsin Electric Power Company 231 W. Michigan Street Milwaukee, Wisconsin 53202

• Kathleen M. Falk General Counsel }lgj Q

114 East Mifflin Street ' Madison, Wisconsin 53703 Ellyn\R . ' Weiss

• mailed postage pre-paid}}