ML19305A923

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Comments on NUREG-0313,Revision 1, Technical Rept on Matl Selection & Processing Guidelines for BWR Coolant Pressure Boundary Piping. Challenges Prohibition of Carbon Steel in Reactor Pressure Boundary.Cast Stainless Steel Is Resistant
ML19305A923
Person / Time
Site: Clinton  Constellation icon.png
Issue date: 03/12/1980
From: Geier J
ILLINOIS POWER CO.
To: Cheng C
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0313, RTR-NUREG-313 U-0127, U-127, NUDOCS 8003180583
Download: ML19305A923 (2)


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.m U-0127 ILLINDIS POWER COMPANY

..}j} g49.g9(93 72)_g 500 SOUTH 27TH STREET. DECATUR, ILLINOIS 62525 March 12, 1980 Dr. C. Y. Cheng Engineering Branch, Division of Operating Reactors Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Cheng:

Intergranular Stress Corrosion Cracking

. NUREG-0313, Rev. 1 We have reviewed NUREG-0313, Rev. 1, " Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping", for comment, and have the following comments:

We believe that Article II.A., paragraph one, should be re-written to include the following provisions: "Where corrosion resistant steel is used in ASME code class 1 or 2 reactor coolant pressure boundary piping, normally exposed to temperatures above 2000F, the materials described in 1. and 2. below, are acceptable to the NRC. Other materials may be used when evaluated and accepted by the NRC."

This change is suggested for the following reasons:

a. We do not believe it warranted to prohibit carbon steel from use in the reactor pressure boundary. Carbon steel has been demonstrated to be highly resistant to oxygen-assisted stress corrosion in the as-installed condition.

However, the paragraph, as written, and the titles for sub-p'aragraphs 1. and 2. , " Corrosion Resistant Materials ," and Corrosion Resistant bafe Ends and Thermal Sleeves," would preclude the use of carbon steel,

b. We do not believe you intended to limit materials used in non-primary coolant containing piping, such as fuel pool cooling and cleanup system, pump suctions from the suppres-sion pool, instrument air systems, and various test and relief valve discharges to the suppression pool. However the wording of the paragraph as written does not limit its application to systems exposed to BWR coolant. O
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.l 9 Dr. C. Y. Cheng March 12, 1980 Finally, we believe that the requirements in article II.A.l.

concerning cast material should permit cast stainless steel, includ- '

ing type CF-8. This alloy has been demonstrated by trouble free service to be highly resistant to oxygen-assisted stress corrosion in the as-installed condition. Its prohibition or requirements for supplemental ISI and leak detection are unwarranted and would be enormously expensive to the industry and our customers.

Sincerely,

- )DC V. D. Geier Manager Generation Engineering Department PEW /jh cc: G. E. Wuller L. J. Koch, B-25 l

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