ML19326D351

Forwards 751001 Revision of Util Position on Reg Guide 1.31, Re Control of Stainless Steel Welding,Replacing Util 750911 Submittal

ML19326D351
Person / Time
Site:	Midland
Issue date:	10/02/1975
From:	Bauman R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
1823, NUDOCS 8006090773
Download: ML19326D351 (6)

Text

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o.ner , omces: 212 West Michigan Avenue. Jackson, Michigan 49201

• Area Code 517788-0550 Ocrober 2, 1975 FC ,r

]s Mr. Roger Boyd Acting Director g Np Division of Reactor Licensing C- 7

~. ;p,s .-9 Nuclear Regulatory Comissica Washington, D. C. 20555 o 4 ' .::;,

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r 4 k MIDLAND PROJECT DOCKET NLHBERS 50-329, 50-330 '"# E I '  ;

REGULATORY GUIDE MEETINGS FILE: 0505 SERIAL: 1823 Our letter of September 11, 1975 transmitted positions on the various Regulatory Guides relative to the Materials Engineering Regulatory Guide meeting which is scheduled with your staff. The attached October 1, 1975 revision of our posi-tion on Regulatory Guide 1.31, Control of Stainless Steel Welding, replaces the one submitted with our above referenced letter. Your review in preparation for the up-coming meeting should be based on this revised position.

Your cooperation in processing our revised position is appreciated.

R. C. Bauman Project Engineer RCD /t2 C*r ,

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REGULATORY GUIDE l'.31 CONTROL OF STAINLESS STEEL WELDING (Rev.1 June 1973)

RESPONSE TO REGULATORY PCSITION .

The NRC's interim position on Regulatory Guide _.31 as contained in Branch Technical Position MTED 5-1 has been used as the current NRC requirement for Control of Stainless Steel Welding. The Midland Project construction of balance of plant components and installation of the NSS will comply with MTED 5-1 except as noted below (1) Paragraphs la, lb and lc of the Interim Regulatory Guide are complied with to the following extent:

a. The limits for Delta ferrite in austenitic stainless steel. welding materials comply with Interim Regulatory Guide 1.31 since the upper limit of 20 percent Delta ferrite in the Interim Regulatory Guides does not apply for welds that are not heat treated after welding (Paragraph 3B) , except for solution heat treatment.

Solution heat treatment, although not required after

v~5' 4. .s permitted in order to avoid severe sensitization.

Austenitic stainless steel welding filler materials used in the fabrication and installation of ASME Section III, Class 1, 2 and 3 components are controlled to deposit from 8 to 25 percent Delta ferrite (8.5 Ferrite Number minimum) , except for 309 and 309L welding filler materials which are controlled to

' deposit from 5 to 15 percent Delta ferrite (5 to 18 Ferrite Number) and are used only for welding carbon or low alloy steel to austenitic stainless steel.

Use of 309.L welding filler material is further limited to the overlay deposit on the carbon or low alloy steel component nozzles or connecting pipe when postweld heat treatment is required.

b. The procedure for determining the amount of Delta ferrite in each heat or lot of austenitic stainless steel welding material does not comply with the Interim Regulatory Guide. Determir:ation of Delta ferrite is in accordance with ASME Section III, Division 1, Paragraph NB-2433.

(2) Regulatory Dosition C.2 is ccnplied "'.th for all tests and examinations required by the appitcable edition of the ASME Code.

• Revised

( Oct. 1, 1975

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INTERIM REGULATORY GUIDE 1.31 (cont'd)

(3) Paragraph 3a of the Interim Regulatory Guide is not complied with. Magnetic measurcment of production welds for Delta ferrite is unnecessary when austenitic stainless steel welding materials are controlled to deposit 8 to 25 percent Dcita ferrite- (8.5 Ferrite -

Number minimum), based on chemistry, except for 309 and 309L welding materials which are controlled to deposit 5 to 15 percent Delta ferrite (5 to 18 Ferrite Number) based on chemistry.

Three Ecchtel projects are committed to measuring production welds for Delta ferrito in order to collect data and demonstrate that the welding material

. controls described above are more than adequate for the purpose of avoiding microfissuring. The program for measuring production welds for Delta ferrite applies to shop fabricated components as well as field installation welds. Since this represents a sufficient nrmber of welds for the purpose of colla 7. ting data, measurement of production welds for Delta ferrite on this project is not planned.

There is no justification for requiring measurement of production welds for Delta f.crrite as a test of the welding filler metal control program since that is not the purpose of measuring production welds for Delta ferrito. For these reasons, measurement of production welds for Delta ferrite on the Midland

, Project is not planned.

(4) Paragraph 3b of the Interim Regulatory Guide is complied with, except that the upper limit of 20 percent Delta ferrite does not apply to welds that are solution heat treated as described in la above.

(5) Paragrhph 4a, 4b and 4c are not complied with since measurement of production welds for Delta ferrite is not performed.

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INTERIM REGULATORY GUIDE 1.31 (Cont'd)

For equipment in the B&W scope of supply, the degree of compliance with this Regulatory Guide is as follows:

This position applies to stainicss steel reactor coolant

' system components, core flooding tanks, and reactor vessel internals all of which vere ~ built to the requirements of 1968 ASME III Code. Branch Technical Position MTED 5-1 has been used as a guide in preparing the following position.

The chemistry of austenitic stainl'ess steel weld filler material has been controlled so that predicted microstructure of the weld deposit minimizes the probability of microfissure cracking. Except for those weld metals that have demon-strated resistance to microfissuring (e.g. SFA-5.4 type 16-8-2 and filler used for weld cladding), all austenitic stainless delta steel ferrite. weld metals will have a minimum of 5%

Materials used on weld processes other than TIG and plasma are qualified using chemical analysis of an undiluted weld pad sample rather than a chemiczi analysis of the filler pridr to welding.

The undiluted weld depcsit shall contain between '

5 and 20 percent delta ferrite ac determined using the Schaeffler diagram or by magnetic measurement.

Examination of production welds was not performed on depos- '

ited austenitic stainless steel weld metal. Production {

welding performed using the parameters of approved procedure qualifications and properly tested and certified welding materials render delta ferrite measurements on production welding unnecessary.

All pressure boundary welds were examined per the requirements of the 1968 ASME III Code w/ addenda thru Summer 1968. Weld acceptance was based on the use of qualified materials, control of weld variables and the results of non-destructive examinations.

B&W Procured Components In general, delta ferrite control of stainless steel welding was not specified for B&W procured equipment. The following specific information is available on B&W procured equipment:

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INTERIM REGULATORY GUIDE 1.31 (Cont'd)

Reactor Coolant Pumps The reactor coolant pumps were manufactured in accordance with the 1971 ASME III Code. The ferritic content of all aus.

tenitic stainless steel welds were controlled between 5 and 15 percent with the chromium equivalent and nickel equiva-lent within the range specified in ASME II, Part C for SFA-5.4 material. Ferrite content was determined by comparing the chemical analysis with the Schaeffler diagram.

Makeup & Decay Heat Removal Pumps These pumps were manufactured in accordance with the require-ments of 1971 ASME Code w/ addenda through Winter 71. Ferr-itic content of austenitic stainless steel welding was con-trolled between 5 and 15 percent by magnetic permeability measurement.

CRDM .

Ferritic content of SS weld material controlled between 5 and 20 percent as measured by magnetic test.

Auxiliary Eauipment ,

Delta ferrite limits were not specified for B&W procured tanks, heat exchanges, demineralizers, or valves. Comp-onents were manufactured in accordance with the ASME Code which did not require delta ferrite control of stainless steel welding.

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t% P NRC Di RIBUTION FOR PART 50 DOCKET MATl! RIAL

• (TEMPORARY FORM)

CONTROL NO: 1%35 a

3 FILE:

FROM: Consumers Pwer Co. DATE OF DOC DATE REC'D LTR TWX RPT OTHER Jackson,' Michigan R.C. Bauman 10-2-75 10-7-75 m TO: ,

ORIG CC OTHER SENT NRC PDR m Mr. Roger Boyd 1-signed SENT LOCAL PDR m CLASS UNCLASS' PROPINFO INPUT NO CYS REC'D DOCKET NO:

m '8 nd 330 -

DESCRIPTION: V ENCLOSURES: , .

Ltr re their 9-11-75 Itr .....trans the Regulatory G'uidd l'.31 Contrcl Of Stainless following: Steel Welding ( Rev.1 June 1973)

( 1 cy of ene) 1 rec'd)

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