ML20028H770
| ML20028H770 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1984 |
| From: | Kammerer C NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Wilson P SENATE |
| Shared Package | |
| ML20028H694 | List:
|
| References | |
| FOIA-90-391 NUDOCS 9101290418 | |
| Download: ML20028H770 (5) | |
Text
.. -
Qf)
Y5l
?)
~l.{iQ F
d
(
/0 gh/'d ' 5 M, -
~
June 20, 1984
.j pf
/TheHonorablePeteWilson 1
United States Senate Washington, D.C.
20510
Dear Senator Wilson:
This is in response to the inquiry by Andrew Poat of your staff, requesting our investigation of statements made in Mr. Michael Roark's letter to you concerning Mr. Matthew Jay's patented process for the prevention of naterial sensitization during welding.
The NRC staff has been aware of Mr. Jay's process for some tinc.
In reply to Mr. Elden Hilliams' letter (see Attachnent I) to Chaiman Palladino on January 20, 1982, Mr. Harold Denton, Director, Office of Nuclear Reactor Regulation, sumarized the results of the staff's inquiry into the industry use of the process and stated NRC's position on its acceptability ( Attachment II).
The NRC staff position as stated in Mr. Denton's March 31, 1982 letter renains valid.
To further elaborate, the NRC does not specify specific methods o' joining pipes who
.everal acceptable procedures are available.
There are other acceptable remedies to the stress corrosion cracking problem that may be less costly than Mr. Jay's process.
In fact, the prevailing trend in the industry is to eliminate as many weld.ioints as possible because our regulations require that welds need to be periodically inspected in order to detect any service-induced degradation.
For every joint, Mr. Jay's process would require three (3) welds.
The statements made in Mr. Roark's letter to you, are generally factual, I
but two statements require coment.
The first one pertains to characterizing the current industry practices as unsafe and the second is the acce a of the statement, Recent reports by the NRC reveal that leaks (ench6.s a l
added) in oiping systeras have been found to be much more extensive and dangerous...".
The safety of piping is not solely ensured by joint-fon31ng practice alone.
The NRC review process starts at material selection, design, fabrication, and all quality assurance programs associated with each step along the design and construction chain.
Once a plant is put in service, there are requirements for periodic inservice inspection and testing and leakage monitoring.
This is the fundamental of the
' defense-in-depth" approach to the safety regulation regarding the I
reactor coolant pressure bot.ndary.
This process has been proven d
effective in that the service-induced degradation has been detected
-.m 9aw9ouo 901ou L,
PDR F0IA
- W POTTER 90-391.
. PDR,,,,,,,,
- N l
Y h
Ybh Y$&
'YQ The Honorable Pete Wilson June 20, 1984 and timely corrective actions taken.
As to when a long-tenn fix or replacement should be made, the licensees will have to make a trade-off between the costs of the fix or replacerent and those for augmented inspections and repairs.
in this regarti, we expect that Mr. Jay's process we *d be accepted if it can be demone. rated to be ef fective and econor 1.
Regarding the statement that "... leaks in piping systems have been found to be much more extensive and dangerous...", the NRC has reported that the cracking due to intergranular stress corrosion has been more extensive than~was anticipated.
All recent leaks caused by the stress corrosion cracking in operating boiling water reactors have been very small and were found during repair.
Considering a total of 24 affected plants using a boiling water reactor, there has not been a single instance of inservice leakage that exceeds the plant Technical Specification limit that is attributed to this problen.
In closing, I hope th:s response would help clarify the issue and be helpful to you when you respond to Mr. Roark.
If we can be of further assistance, ple.ase do not hesitate to let us know.
Sincerely,I L5 Carlton Xamerer, Director Office of Congressional Affairs
Enclosures:
1.
Letter (1/20/82),Elden Williams to N. J. Palladino 2.
Letter (3/31/82) H. R. Denton to Elden Williams G/20/84 Wilson Charis c ' "" >.9.C.A..........
"">.f.9.n,t;.c,c,,,,,
mr > 6/20/84
6_.
.x e
ca ca car mm p/j j
~gi i
6 L
v 151b B E. Ecinnt. Lanu Ant. CaMemis 927D$
01a15!,6 B131 January 20, 1982 Mr. Nunzie J. Talladino, Chaire.as Nuclear p,egulatory cc--i ssien k's.shington, D.C.'20555
?$ference: Mr. Jay's pate. t f 4,209,123 for the e14-4:aties of leakage in stainless Steel piping systems in Nuclear p.eactors.
Lear Mr. Palladino Ve received with interest your ceu appointnent.
Ve, like you, have beet ettempt ing to get the attention of those responsible for' preve. ting leakage in Nuclear Stainless piping systems for.several years.
Our retponse has.been iOOi that General Electric hes been us.ing this system.
Ve hu=bly request your new staf f to talk to N-I. Jay and deter =ine ic yourscif if Genere.1 Ilectric has resolved the " leaking" problets or if they are svetping the under the ug. -
Me invite a:y discussions deemed essential to prove the cerits of the subject piping system beyond any shadow of doubt a. d to assu:e st.se cf our integrity and the structu:r.1 integrity of our subject piping.
points to be censidered:
1 i
1.
The subject Patent offers in cLtirely new ec cept, if not a =ettilurgical break-through, of stainless steel pipe usage fe; tratsmitting stea.: vithout the advetse ef fects of occur tng cracks and leaks no::tily asscciated with conventic a1 stainless steel pipe.
2.
Coe vill notice that the eriginal chenistry of the pipe parent metal (type 304) stat:1ess steel does not thange.
Ke: does the.06 c:.04 carbeE cc tent which ever is 'desi:able to satisfy the design allowable.
3 The basic canuf acturing method rer.ains except, two additic:a1 processes are required at in-process stages of manuf acture.
- e..
Notice vill be made that no sensitizatic: in the veld a:ea ever occurs irrespective ef the velding process ee;>1 eyed.
- @ pse+ff L
. _ _ _. ~..
5.
S'ensitization (grain bou:.dary cents::hatica vith chrtelu::~ct: bide.s) centrihetes to interstitial (gnin-boundary) hilvres, thus causing cracks.ed leaks e rideaced 17 the veld a er f ailures in cyclu -re.vetor piping systems for the past tve.nty years.
6.
F,esulting f c:n.ati ras of incondtraatle r, eses and releat cf f ce-electrons (f er.intien 1
cf such gr.ses) is an ithetent charactefistic estociated wit.h ster teneratica thic.h ca.nnot be avoided.
Such gasar in volumes of one pt t per tillion ceupled with l
sensitized veld heat af f ected *eces, vial cause intnstitial f ailures vithout evestien.
- 7. - The subject pipe vill not rust oo: exidize a:d then.f cic.; vill res. sin free of cc.:tn{ nation by iret-exides which ':. cad i.o pipt deterioretien and ec:1y replacements.
E.
Subject pipe of fers lent seidee lif e d optimum c eno:y in servicev.thout undue
=ainte:2.nce considerations.
- 9.. ?t. tent searches revealed that cc othe: ;.ethod, pror.ess en procedure developed to date to prevent s.ensitization have f elled in theit c;ntirety.
Any ether process developed to date vil.1 sininire but not :: event s ent>itica tiet such as the sdbjest process does.
- O. ' Mr. Jay's pro,
- ess has term approved by Cc;ce:d Electric and Kuclear Regula:ery C o=is s i on.
Please corre spond with.Mr., Matthev Jsy At the f c11cvi5g address:
M. C. Jay 5411 Neva Ave.
San Diege, Calif. 92123
~
Thank you fe: your censideratien.
Very truly yours, J
}.,f, Ilden '.lilliams D /)!
cc:
1.
Representative Ed ard J. Markey D-Mass.
(Chai:=an of the House Interier Subcomitee.on oversight a:.d investigatiens.)
2.
Co=issioner Victor Gilinsky O
em 9
6 e=.-w-'-*
~
e
-r.--
ATTACHMENT 11 MAR 3119E2, Mr. Eiden Wi.111ams ELCO 1016-B f. Edinger Sar,ta,Ana, California 92705 Dcar Mr. Willie.ms :
As indicated' to' you-in my letter of March 5,1982, we have continued to review the details of Matthew Jay's patent pertaining to BWR piping. We have concluded that the approach proposed by Mr. Jay would be generally acceptable bgth for initial construction and repair operations, althcugh
/
we would probably recuire some additional controls on minimum celtt ferrite for the cast pipe safe ends.
We have also discussed tbis, matter 'with General Tiectric.
They info-med us r
that the method covered by 3.he Mat'. hew Jay patent has not been used by them.
- either for new construction or repair, and we.- k.now of no instance where it has been used.
General Electric has developed and used an approach that is somewhat similar in which weld overlays and weld buttered pipe weld prepa-ratfons accomplish the same overall purpose.' This is referred to as
- corrosion resistant cladding
- in their documents and in HUREG-0313 Rev.1 '(which you referenced).
.. Although the NRC reviews and approves specific methods used to prever.t intergranular stress corrosion cracking, utilities tre free to select their preference among the several approaches we have stated in NUREG-0313, Rev.1 to be acceptable' Ut111 ties usuall.y consider cast', schedule, materials availability, and their own preference when selecting the approaches they vill use.
Accordingly, if you br.ve an interest in promoting the use of Hatthew Jay's procedure, you should contact the utilities, either directly or through the Electric Power Research Institute (EPRI), Palo Alto, C.al i fornia.
Sincerely, U+a cM y it. L hr.t:a Harold R. Dentori Director Offica of Nuclear Rector Regulation cc:
Congresidan Edward J. Markey bec:
Ivor J. James, Jr., Fatent Counsel Nuclear Energy Business Operations-General Electric Coeper.y 175 Curtner Avenue i
. San-Jow 4M5115-M[
I
(h
.'-g
- Qic, E
June 20, 1984 The Honorable rete Wilson United States Senate Washington, D.C.
20510
Dear Senator Wilson:
This is in response to the inquiry by Andrew Post of your staff, requesting our investigation of statements made in Mr. Michael Roark's letter to you concerning Mr. Matthew day's patented process for the prevention of material sensitization during welding.
The NRC staff has been aware of Mr. Jay's process for some time.
In reply to Mr. Elden Williams' letter (see Attachment I) to Chaiman Palledino on January 20, 1982, Mr. Harold Denton, Director, Office of Nuclear Reactor Regulation, surnarized the results of the staff's inquiry into the industry use of the process and stated NRC's position on its acceptability ( Attachment II).
The NRC staff position as stated in Mr. Denton's March 31, 1982 letter renains valid.
To further elaborate, the NRC does not specify specific nethods of joining pipes when several acceptable procedures are available.
There are other acceptable remedies to the stress corrosion cracking problem that may be less costly than Mr. Jay's process.
In fact, the prevailing trend in the industry is to eliminate as nanv weld.ioints as possible because our regulations require that welds need to be periodically inspected in order to detect any service-induced degradation.
For every joint, Mr. Jay's process would require three (3) welds.
The statements made in Mr. Roark's letter to you, are generally factual, but two statements require coment.
The first one pertains to characterizing the current industry practices as unsafe and the second is the accuracy of the statement, "Recent reports by the NRC reveal that leaks (emohasis added) in piping systems have been found to be much more extensive and dangerous...".
Tha safety of piping is not solely ensured by joint A. ming practice alone.
The NRC review process starts at mterial st.Netion, design, fabrication, and all quality assurance programs associated with each step along the design and construction chain.
Once a plant is put in service, there are requirements for periodic inservice inspection and testing and leakage monitoring.
This is the fundamental of the
" defense-in-depth" approach to the safety regulation regarding the reactor coolant pressure boundary.
This process has been proven effective in that the service-induced degradation has been detected
..........h hhh
~ "'>
........l....
NbA'.7 Edh Si.& g The Honorable Pete Wilson June 20, 1984 4_
and timely corrective actions taken.
As to when a long-tem fix or replacement should be made, the licensees will have to make a trade-off between the costs of the fix or replacement and those for augmented 4
inspections and repairs.
In this regard, we expect that Mr. Jay's i
process would be accepted if it can be demonstrated to be effective and economical.
Regarding the statement that "... leaks in piping systens have been found to be much more extensive and dangerous...", the NRC has reported that the cracking due to intergranular stress corrosion has been more extensive than was anticipated.
All recent leaks caused by the stress corrosion cracking in operating boiling water reactors have been very small and were found during repair.
Considering a total of 24 affected plants using a boiling water reactor, there has not been a single instance of inservice leakage that exceeds the plant Technical Specification limit that is attributed to this problem.
In closing :I hope this response would help clarify the isn+ and be helpful to you when you respond to Mr. Roark.
If we can be of further assistance, please do not hesitate to let us know.
4 Sincerely,,
5, Carlton Kannerer, Director Office of Congressional Affairs
Enclosures:
1.
Letter (1/20/82),Elden Williams to N. J. Palladino 2.
Letter (3/31/82) H. R. Denton-to Elden Williams F
i I
e 6/20/84 Wilson Charis o"*ui.R9.A.....................................................
.............. ~.
~ ~. ~........
........ ~.........
.......... ~...
'*"*"'>.K.e.n.L;.c.c,...,............................ -.. -
. ~...... ~....
- ~ ~.. - -
-. -. - -.. ~
.- ~..~.-
eau > 6/.20/84
_~~
.~
- - -