ML20031H364

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Testimony of La Gunther & Wf Malec Re Tx Pirg Contention 10, Doherty Contentions 44 & 43 & ASLB Question on Reg Guide 1.54
ML20031H364
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/18/1981
From: Gunther L, Malec W
EBASCO SERVICES, INC., HOUSTON LIGHTING & POWER CO.
To:
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ML20031H319 List:
References
NUDOCS 8110270411
Download: ML20031H364 (7)
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  • September 18, 1981 UNITED STATES OF AMERICA 3

NUCLEAR REGULATORY COMMISSION 2 B_EFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 In the Mattor of S S HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S 5 (Allens Creek Nuclear Generating S Station, Unit 1) S g 6 i 7 DIRECT TESTIMONY OF LOUIS A. GUNTHER I.ND WALTER F. MALEC REGARDING: (1) TEXPIRG CONTENTION NO. 10 - IGSCC (2) DOHERTY COMTENTION NO. 44 - IGSCC/ WATER HAMMER (3) DOHERTY CONTENTION NO. 43 - STAINLESS STEEL CLEANING e (4) BOARD QUESTION - REG. GUIDE 1.54 10 11 Q. Mr. Gunther and Mr. Malec ha"e you reviewed your prior affidavit on TexPirg Contention 10, which affidavit is 12 attached hereto as Attachment LAG /WFM-l? A. Yes. 14 Q. Are the statements contained therein still true and 15 correct? 14 A.

Yes,

~~ Y Q. Mr. Gunther, is there any documentation to support t 13 the conclusion in your affidavit that all IGSCC failures 19 produce detectable leakage before the presence of rapidly Propagating cracks? 20 A. In order to understand the statement in the affi-davit it is important to first address the toughness of 11 austenitic stainless steel piping material. Touglaess is a I 23 property of the metal which enables it to absorb energy and 1, 8110270411 810918 PDR ADOCK 0500046o T PDR _ _ - _ _ _ _ _ _ _ _

e a deform plastically before fracturing. Austenitic stainless !9 steels in the soi:1 tion heat treated condition inherently exhibit high material toughness properties. Because of 3 thir '>erty intergranular stress corrosion cracking (IGSCC) 4 is r .y eted to cause rapidly propagating fractures to I Typical notch toughness properties for austenitic l occur. ~ l 5 I stainless steel are published in the American Society for 7 Metals Handbook, 8th Edition Vol. 1, page 420. The general 3 acceptance of ;his material characteristic within the nuclear industry is also demonstrated by the fact that austenitic 9 stainless steels are exempt from the fracture toughness 0 testing requirements contained in the ASME Code Section III 11 Subsection NX-2300, " Fracture Toughness Requirements for 12 Material", for nuclear safety class components. Finally the importance of this property and its relationship to the 9 ~ 9 "* periornance of the material in the presence of IGSCC is 15 stated by the NRC Staff in NUREG-0313, Rev. 1, page 3: "The IGSCC occurs in a small p,ercentage of the welds lg in BWR piping that contains relatively stagnant, intermittent or low-flow coolant. Historically, these cracks have been discovered either by volumetric 3- ~# examination, by visual inspection, or by leakage 9_ S detection systems. The growth pattern of the cracks is such that it is unlikely that these cracks 19 would go undetecteu befo e they grow to significant size whe..e the pipe fu-etion might be compromised. Further, because of the inherent high material 20 toughness of austenitic stainless steel piping, IGSCC is unlikely to cause a rapidly propagating failure resulting in a loss-of-coolant accident." 3 ~~ Is there any 13 consistency between Reg. Guide 1.44 22 Q. i 22 and NUREG-0313 as those documents appl 1 to the components i of ACNGS designed by Ebasco? I 24 i 4

\\ j m ~re- ? < 9 A. Nuclear Regulatory Guide 1.44 was issued in May 1973 and presented the NRC regulatory position concerning 3 material selection and manufacturing process control of 2 austenitic stainless steels intended for use in light water cooled reactors. The regulatory position applied to compo-nents which are part of (1) the reactor coolant pressure ~ 5 I boundary, (2) systems required for reactor shutdown, (3) 7 systems required for emergency core cooling, and (4) reactor 3 vessel internals that are relied upon to permit adequate core cooling for any mode of normal operation or under credible o p stulated accident conditions. O Subsequent to the issuance of Regulatory Guide 1.44 the NRC formed a Pipe Cracking Study Group (PCSG) to investi-12 gate the cause of cracking experienced'in austenitic stainless 91 steel piping and associated components in Boiling Water ~~ 94 Reactor Plants. The PCSG published two reports, NUREG-15 75/067 in October 1975 and NUREG-0531 in February 1979 lg covering the results of their investigation. The NRC Staff issued NUREG-0313, Rev. O. in July 1977 and a revised 3-> i NUREG-0313, Rev. 1, in July 1980 following their reviews of 9, -c NUREG-75/067 and NUREG-0531 respectively, The NUREG-0313, Rev. 19 1, document is the NRC Staff implementation document and 20 l presents the Staff position for implementing the recommenda-n, tions of the PCSG. ~~ 22 Reg. Guide 1.44 is consistent with NUREG-0313, Rev. 1 in 23 recommending the use of low carbon stainless steel materials i 24 such as those used in.ACNGS. The principal difference I 1 ! l 1

9 between NUREG-0313, Rev. 1, and Regulatory' Guide 1.44 as they affect the Allens Creek Unit 1 Project is the change in 3 scope of the material selection requirement. The guidelines for material selection have been extended to cover BWR ASME Code Class 1, 2 and 3 piping systems. The pipe and fitting materials including safe ends, thermal sleeves and weld filler metals specified in the Allens Creek Unit 1 design l comply with the requirements of NUREG-0313, Rev. 1, Part S III A. As indicated by the Staff in NUREG-0313, Rev. 1, o Part IV A, Allens Creek Unit 1 Plant is not, therefore, required pr vide augmented in-service inspection or leak detection t 10 requirements beyond those specified in 10 CFR S 50.55a(g), gg "In-service Inspeccion Requirements" and plant Technical 12 Specifications for leakage detection. 'The NUREG-0313, Rev. 91 1 document also states the Staff conclusion that, pending ~~ 9~4 implementation of the above guidelines, intergranular 13 stress corrosion cracking will not pose an undue risk to the 16 health and safety of the public. 17 Q. Mr. Gunther and Mr. Malec, have you reviewed your prior affidavit on Doherty Contention 44, which affidavit is gg attached hereto as Attachment LAG /WFM-2? A. Yes. 20 Q. Are the statements contained therein still true en ~~ and correct? A. Yes, except for the changes described in the h3 errata attached hereto and labeled Attachment LAG /WFM-3. i 24 Q. M,r. Malec, can you address the two concerns discussed { I l.

1 in the Board's Order of September 1 at page 557 A. Intervenor's concernr, about the carbon content of 3 carbon steel, A106 Grade "B" in relation to NUREG-0313, 3 Rev. 1 are unfounded. A106 Grade "B" is a ferritic carbon steel, rather than an austinitic stainless steel, and as such, is 3 an acceptable material to the NRC, as indicated in part i III.A.1 of NUREG0313, Rev. 1. The footnote in Intervenor's ~ Exhibit A which refers to controlled carbon and nitrogen ~ 3 contents is associated with nestenitic stainless steels, and 9 has nothing to do with carbon steel. Thus, these " seemingly contradictory" positions are not, in fact, contradictory. 10 The August 16, 1979 Submission to the Commission by the ACRS (Intervenor's Exhibit Zero) expressed concern 4 over possible accident initiators on piping that might contain 13 large deep cracks. However, as stated on page 3 of our 1 affidavit, ACNGS will be designed to preclude cracks caused 15 by IGSCC. Furthermore, NUREG-0531 " Investigation and 16 Evaluation of Stress Corrosion Cracking in Piping of Light Water Reactor Plants" did consider transient loading conditions 17 and still concluded that IGSCC ...while generally undesirable, 1-o is not a hazard to public health and safety". g Mr. Malec, with respect to Doherty Contention 43, Q. 20 can you answer the question at page 52 of the Board's ~n ~~ September 1 Order? The portion of th, ECCS within the Reactor Containment A. 23 Building consists only of piping and valves. (The other major i 24 components,are located in the Reactor Auxiliary Building). { 1. - l

With one exception, ECCS piping systems are specified as 1 carbon stee'., and will be primed and coated with materials 3 that meet Reg. Guide 1.54. Carbon Steel Piping Systems which are insulated receive only the primer coat. The two exceptions 4 are short lengths of ECCS piping in direct contact with the suppression pool and flushing drain lines downstream of ~ normally closed block valves, which are nade of low carbon I stainless steel. In these situations, the stainless steel 3 piping will not be subjected to the stress levels seen by the caibon steel piping, and therefore are not susceptible o to the stress corrosion ; istulated in the contention. 10 Coatings are applied to stainless steel surfaces of the ECCS only where conventional encapsulated insulation is used for 12 piping thermal insulation or wnere stainless steel piping is ~3 Stainless steel piping will be coated 5 embedded in concrete. 14 in compliance with Reg. Guide 1.54 as provided in Appendix C 13 to the.'.CNGS PSAR. This is applied as a second line barrier coat to prevent the possibility of certain leachable materials 16 contacting the stainless steel pipe surface from whatever 17 source and is above and beyond the existing insulation

g specification requirements, which limit insulation chemical Thus, the composition in accordance with Reg. Guide 1.36.

20 Applicant has provided a " defense-in-depth" philosophy that exceeds current regulatory requirements and further minimized e, ~~ the low probability of IGSCC. 23 Q. Mr. Malec, can you respond to the question posed 36 of its September 1 Order in which it I i 24 by the Board at p. W requests clarification of the " apparent exception" to Reg. 9 Guide 1.54 which appears at page C1.54-1 of the PSAR? A. The PSAR statement quoted by the Board is not intended 1 to to and should not be construed as an exception to Reg. Guide 1.54. Rather, it is HL&P's position that areas which are not "significant" and which do not have a " direct potential 5 ! post-LOCA debris pathway to the Suppression Pool" are 7 excluded from the coating requirements of Reg. Guide 1.54 because they do not represent a potential source of debris which 3 might clog the ECCS suction filters. By "significant areas", g the PSAR means those areas of the containment which would be exposed to post-LOCA containment spray and/or areas in which a LOCA may occur. By " areas which have a direct potential post-12 LOCA debris pathway to the Suppression' Pool" the PSAR means 93 those areas of the containment which would gravity drain rapidly ~ 14 and with little filtering effect to the suppression pool. 15 15 17 13 e 20 21 22 l I 22 ! 24 ! i i

. l Attachm:nt LAG /WFM-1 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ( BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i In the Matter of ) ) I HOUSTCi' NGHTING & POWER ) Docket No. 50-466 COMPANY ) )

(

(Allens Creek Nuclear ) Generating Station, Unit ) No. 1) ) t AFFIDAVIT OF LOUIS A GUNTHER ~ L - {- State of New Jersey County of Bergen

L I, Louis A Gunther, Welding and Materials Engineer, Allens Creek Project for Ebasco Services Incorporated, of lawful age, being first duly sworn, upon l

my oath certify that I have reviewed and am thoroughly familiar with the 'I statements contained in the attached affidavit addressing intervenor TexPirg's Contention 10 regarding IGSCC and that all statements contained therein are true and correct to the best of my knowledge and belief. u ? o*4 / s o / Subscribed and sworn to before me this -79 '/ day of S f. ,1980. L' (! .? cl. ,7 5.3 M...s 4. - /\\ _ ,3,. CAROL A. OPITENOK /< 2[ NonRY Pll3UC Of Nf?I IfRS'Y IAY COMMISStc,al EXPlRCS SEPT. It 1983 s hoe g(; O E I I iiO6 i 3 gb i ( .C ~r- -i.: 3

Attachm:nt LAG /hTM-1 il UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 'l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

(

In the Matter of ) ) I HOUSTON LIGHTING & POWER ) Docket No. 50-466 CCMPANY ) ) -l (Allt.ns Creek Nuclear ) Generating Station, Unit ) No. 1) )

l AFFIDAVIT OF WALTER F MALEC L

State of New Jersey County of Bergen [ I, Walter F Malec, Supervising Mechanical Nuclear Engineer, Allens Creek Proj ect, for Ebasco Services Incorporated, of lawful age being first. duly sworn, upon my oath certify that I have reviewed and am thoroughly familiar t I.. with the statements contained in the attached affidavit addressing intervenor TexPirg's Contention 10 regardir.g IGSCC and that all statements contained therein are true and correct to the best of my knowledge and belief. r ) f 1) J 0 Subscribed and worn to before me this J F day of <, !~ ,1980. { f.~ (. s I 0 - u.T~,. !. ~/?u.,. CAROL A. OPITENOK g NOTARY PUBUC M Nrw yp3Ey MY COMWssicN EXPIRES SEPT, 13. 1987 f 9 E L u .L

Attcchm:nt LAG /WFM-1 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION' l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L In the Matter of S. S I HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 S I (Allens Creek Nuclear S Generating Station, Unit S No. 1) S \\ AFFIDAVIT ADDRESSING TEXPIRG'S CONTENTION NO. 10 RELATING TO INTERGRANULAR STRESS CORROSION CRACKING t My name is Louis A. Gunther, by business address is t Two World Trade Center, New York, N. Y. I am the Welding and l { Materials Engineer for the Allens Creek Proje'-t employed by Ebasco services Inc6rporated. The statement of my background and ~ L-qualifications is attached as Exhibit I to this testimony. My name is Walter F. Malec. My business address is 160 E Chubb Avenue, Lyndhurst, N. J. I am the Supervising Mechanical p I l Nuclear Engineer for the Allens Creek Project employed by Ebasco services Incorporated. The statement of my background and L qualifications is attached as Exhibit II to this testimony.- This affidavit responds to the Intervenor's concerns about intergranular stress corrosion cracking of austenitic stainless steels supplied by Ebasco Services Ince porated. The m phenomenon of IGSCC is described in the affidavit of Dr. Gerald

s. c-b i

M. Gordon of baneral Electric. r i ~ , t, -s 6' - s f p=s C. ______________1______%

g. i t The piping within the reacto coolant pressure boundary (RCP3) cf the standby liquid control system, instrumentation of I the nuclear boiler system, and instrumentation of the recirculation system will be fabricate i from 304L stainless steels. This ( classification of steel alloy has 18-20 percent chromium and 8-12 1/ g percent nickel, a maximum af 0.0.~ percent carbon,~ some other minor alloying 1clements and the remainder is iron. The resistance I of low carbon steels, such as 304L, to IGSCC is also described in the affidavit of Dr. Gerald M. Cordon. .t 's Despite great confidence in the prophylaxis provided by t. proper ma@erfaly selection aPd processing, ACNGS will also be provided kith a positive leak detection system. ( This system, e j which is des'cribed in PSAR Section 5.2.7, will detect any uncon- -i w~ trolled or unaMi,cipated leakage from the RCP3. Since all IGSCC \\,_ A failuresproduc'ecasilydetectableleakagewellbeforethepresence I [ of rapidly propagating cracks, this detection system provides the ..M final, con.servative assurance that the safety of ACNGS will not be 2 threatened h.' F ~ ~ f. V c, 1/ Some stainless steel A312 piping with a 0.035 percent carbon content, will be used in the ECCS for piping in direct ~ pontact with the Suppression Pool. This is a corrosion prevention a measure. This pip $ng is open-ended and not subject to the (,. c ue-qtress levels ac in the pressurized piping in which IGSCC has been observed. I, i QG~ q*, w% q \\ L. \\ 9 % %f* s g C* ,s {;. k '-N p {- q +J '. 'a ~ C, L w; (, e .r.

'dJMTWDJ L. RESUME - 1,0UIS A GUSTHER Senior Engineer - Materials Applications I. [

SUMMARY

07. I GERIENCE (Since 1968)

N+ Total Exper2cnce - More than 12 years engineering experience in metal-g lurgical and welding engineering in the areas of welding design and =aterial selection, pressure vessel fabricativu and advanced welding ~ process develop =ent for utility, naval nuclear, deep sea submergence I-and aerospace projects. Professional Affiliations - Professional Engineer in the State of New York. 1' Patents - Method of Welding a Tube to a Tube Sheet, Patent No. 3,824,663. ( Honors and Awards - Tau Beta Pi L. Noah A Kahn Memorial Award - ASDi s ( Professional Society Me=berships - American Society for Metals ~.. American Welding Society Welding Research Council Education - BS Metallurgical Engineering (nagua ces laude) i l. Polytechnic Institute of 3'rooklyn - 1968 [.~ MS Mata11urgy - New York University 1970 i MBA Management Systems - New York University 1975 b j Specialized Training - Cc=plcred the following courses: Il ]- (a) TT-4 Practical Nuclear Power Plant Technology l,_ Course / sponsored by Ebasco-1977. (b) B6W Basic Steam Generating Technology Course / sponsored by Ebasco-1926. (c) GE 'BWR Course / sponsored by Ebasco-1975. (d) Titanium and its Alloys / sponsored by the American Society for Metals-1968. C 6 C i

4 LOUIS'A GUNTHER REPRESENTATIVE ESASCO PROJECT EXPEFlENCE

\\

(As Senior Engineer) . I Nuclear Louisiana Power & Light Company Waterford Unit 3 1 Houston Lighting & Power Co=pany Allens Creek Unit 1 Fossil g Noe Terk State Electric & Gas Company Homer City Unit 3 I Pennsylvania Electric Co=pany Iowa Puclic Service Company Neal Unit 4 l Public Service Company of Colorado Pawnee Unit 1 t Houston Lighting & Power Company Limestone Units 1 and 2 .l EBASCO EXPERIENCE (Since 1974) 1; Senior Engineer - (6 years), New York Office Responsible for all matters concerning New York Office welding fabrication and_ materials selection during design and construction phases on assigned projects and for providing technical support"for project site support engineers. Assigned .co special.projec_ts for deyelopment of automatic f.fxed,, position pipe-welding ~ procedures. [ ERIOR EXPERIENCE (6 Years) 7.. Curtiss Wright Corporation Wood-Ridge, New Jersey Senior Engineer (3 years) Assigned to the Walding Technology Department, Nuclear Division. Responsible

  1. or developrent, i=plementation and curveillance of specialized welding procedures e= ployed in the manufacture of Naval Nuclear Co=ponents to NAVSHIPS-250 1.500-1 requira-ants. These procedures included specialized seal welding, auto =atic tube-to-tube sheet welding, and automatic orbital

~ pipe welding processes. Adcicional responsibilities included metallurgical studies for development projects and production support, =anpower and schedule esti=ating for new welding projects, capitz.1 equipment selection, and vendor auditing. I t L a "( L:

.[ Pega 3 of 3 ~ FIST:ME - LOUIS A GtIM.ER l PRIOR EXPEPlENCE (6 Years) (Continue.d) 1 Cur:iss Wright Corporation Wood Ridge, New Jersey Engineer (2 years) I Assigned to the Process Metallurgy Depart =ent, Aerospace Division. Responsible for develop =ent projects concerned vith repair welding and heat trea % nt of turbine blades, plasma arc u.. ding, inertia welding, s .- l and production welding of D6AC srael assemblies for the Gr e mn F14 Progra=. il U S Naval Applied Science Laboratory ~ New York, New York Physical Metallurgist (1 year) t Assigned to the Tf taniu= Develop =ent Progra=, responsible for carrying out welding develop =ent studies and welder training progra=s on heavy section citaniu= alloys in support of U S Navy deep submergence vehicle p ro gra=s. Ebasco Services Incorporared

F Materials Laboratc;7 Technician (S-er E= ploy =ent)

C Responsible for specimen prepar:ation, metallographic work on failure analyses, and brazing and =achining operations performed during laboratory studies for the power industry. F l' .c 4 'l L L .t. 'I

l C

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SUParvi" sing EngintOr EBASCO SERYlCCS - ~ EXHIBIT II 4 YGcrs With EEASCO l nconomuso a=- I Born Philadelphia, Pennsylvania i Education Polytechnic Institute of Technology, degree of Engineer in Nuclear Engineering - 1978 g Mas achusetts Institute of Technology, MS in Nuclear Engineering - 1970 U.S. Coast Guard Academy, BS - 1968 l Member American Nuclear Society Licensed Registered Professional Engineer in the State of New York ( (No. 56673) Experience: 1 1980 Ebasco Services Incorporated, Lyndhurst (NJ) Office; Supervising Engineer, Mechanical-Nuclear Engineering Department: ~ Houston Lighting & Power Co - Allens Creek NGS - Unit No.1 - 1200 >M(e) BWR L Technical and administrative responsibility for mechanical, fire protection, plu=bing, HVAC, stress analysis, hangers and { supports, and inservice inspection activities. Includes schedules, budgets, and client relations. 1978-1980 Ebasco Services Incorporated, Lyndhurst (NJ) Office; Principal Engineer, Mechanical-Nuclear Engineering Department i[ Houston Lighting & Power Co - Allens Creek NGS - Unit No.1 p 1200 }M(c) BWR, Lead NSSS Engineer Responsible for preparation and =aintenance of ECCS and BOP flow diagrams, piping layouts, syste= design descriptions, inservice inspection provisions, Ndelear Island building general arrangements, PSAR and FSAR preparation, equipment l[_ sizing and specification, NSSS vendor interface for corre-r spondence, drawing review, and contract administration. _l { 1976-1978 Ebasco Services Incorporated, New York Office; Senior Engineer, Mechanical-Nuclear Engineering Department including: i -{ Houston Lighting & Power Co - Allens Creek NGS - Unit No.1 - 1200 FM(e) BWR, Lead NSSS Engineer 'l.. Louisiana Power & Light Co - Waterford SES Unit No. 3 - 1-1165 FM(e) PWR. Lead NSSS Engineer ? (Same responsibilities as listed for 1978-1980 above.) p j _

EBASCO SERVICES neeeroa m e g l. 1976-1978 Responsible for preparation and maintenance of ECCS and (Cont'd) BOP flow diagrams, piping layouts, system design descrip-tions, inservice inspection provisions, Nuclear Island { building general arrangements, PSAR and FSAR preparation, equipment sizing and specification, NSSS vendor interface for correspondence, drawing review, and contract adminis-tration. g l 1974-1976 United States Coast Guard, Marine Inspection Office, 1 New York; Lieutenant - Supervisory Boiler Inspector. Responsibility for supervisio., assignment and training of Marine Inspectors in largest Marine Inspection Office g in country. Inspection of hull and machinery material condition of U.S. flag and foreign merchant vessels, and pressure vessels under construction. Application of various laws and regulations of the United States, ASME .I Code, ANSI, TEMA, NEC and NFPA Standards. Review of [ engineering plans and alterations, reports from field and resident inspectors. 1973-1974 United States Coast Guard, USCGC Spencer (WHEC-36), Lieutenant - Chief Engineer. Responsibility for operation, l~' maintenance and repair of hull and engineering plant of 6200 slip twinscrew steamship. Direct supervision of 40 officers and men. Duties included preparation of repair specifications and maintenance of vessel records. Received p-Coast Guard Achievement Medal for supetior performance of ~ duty. [ 1970-1973 United States Coast Guard, Marine Inspa : tion office, 'r New York, Lt and Ltjg - Marine Inspector. Inspection ll of hull and machinery of U.S. and foreign flag merchant vessels. 'E 1968-1969 United Scates, Coast Guard, USCGC Mellon (k' HEC-717), Ensign, l Assistant Engineer Officer. [ lc [ 1,. l E i lF lt !E e b f

Attachment LAG /WFM-2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) HOUSTON LIGHTING & POWER ) Docket No. 50-466 COMPANY ) ) (Allens Creek Nuclear ) Generating Station, Unit ) No. 1) ) AFFIDAVIT OF LOUIS A GUNTHER State of New Jersey County of Bergen r ? I, Louis A Gunther, Welding and Materials Engineer, Allens Creek Project, for m j Ebasco Services Incorporated, of lawful age, being first duly sworn, upon ny oath ceri:1fy that I have reviewed and am thoroughly familiar with the statements contained in the attached affidavit addressing intervenor i John F Doherty's Contention 44 regarding IGSCC propagated by water hamme.: and that all statements contained therein are true and correct to the best of my knowledge and belief, c A , /s m' Subscribed and sworn to before me this.J -F day of Tv/,/ ,1980. / ~{.,, !... M (~_.lt r CAROL A. OPITENOK [ $7~ NOTARY PUBUC OF hm JER.W MY COMMIS$10N EXPIRES SEPT. 18. 1937 Q. .aee, J

~ 1 l' Attachm@nt LAG /WFM-2 j i 1 1 UNITED STATES ,1 AMERICA j NUCLEAR FIGULATORY COMMISSION I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) HOUSTON LIGHTING & POWER ) Docket No. 50-466 COMPANY ) ) ~ -(Allens Creek Nuclear ) Generating Station, Unit )

.s.

No. 1) ) i~ ~ AFFIDAVIT OF WATER F MAIEC ~ State of New Jersey County of Bergen \\ I, Walter F Malec, Supervising Mechanical Nuclear Engineer, Allens Creek { Proj ect, for Ebasco Services Incorporated, of lawful age, being first duly sworn, upon my oath certify that I have reviewed and am thoroughly familiar g_ with the statements contained in the attached affidavit addressing intervenor f John F Doherty's Contention 44 regarding IGSCC propagated by water bemmer 1-and that all statements contained therein are true and correct to the best of my knowledge and belief. ]~ )

r-Subscribed and sworn to before me this

~f

  • day of

,1980. 1 LL ~ l . $ -/,l- .J F CAROL. A. ORITENOK 1 NOTARY POSLIC OF NEW JERSEY MY COMMIS$f0N EXPIRES SEPT. 18, 1983 L. 9 fx Q" T)\\A\\ p g z V ) ~ d 9 _._.,e,.

i l Attachment LAG /WFM-2 l i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC StJETY AND LICENSING BOARD In the Matter of S S HOUSTON LIGHTING & POWER S COMPANY S Docket No. 50-466 5 (Allens Creek Nuclear S Generating Station, Unit 5 No. 1) S 3 AFFIDAVIT ADDRESSING JOHN F. DOHERTY'S CONTENTION NO. 44 ON INTERGRANULAR STRESS CORROSION CRACKING AND WATER HAIGiER l:e My name is Louis A. Gunther. My business address is ^- Two World Trade Center, New York, N. Y. I am the Welding and -:t-- ? Materials Engineer for the Allens Creek Project employed by .L Ebasco Services Incorporated. The statement of my background rt-- 1S and cualifications is attached as Exhibit I to this testimony.

p My name is Walter F. Malec.

My business address is 160 Chubb Avenue, Lyndhurst, N. J. I am the Supervising / } Mechanica' Nuclear Engineer for the Allens Creek Project employed by Ebasco Services Incorporated. The statement of my background and cualifications is attachec as Exhibit II to this testimony. ~ This affidavit addresses the facts raised in Doher.ty's 4 Contention No. 44 which states that the ACNGS piping in the L feedwater, steam supply, residual heat removal, ECCS, containment f f f

~ spray and service water systems are not adequately designed to prevent propagation of intergranular stress corrosion cracks n (IGSCC) by water hammer "orces. A list of these systems describing their function and materials is furnished be.~.ow: A. Feedwater System - This system returns the condensed reactor steam to the reactor vessel through six 12-inch lines. The lines are made of carbon steel, A106, Grade "B". B. Main Steam System - This system transports the reactor tr-j steam through four 26-inch lines from the RPV to the turbine. The main steam pipes are made of carbon steel, A106, Grade "B" and carbon steel, A155, KC65, Class I. [~ C. Residual Heat Removal (RHR) System - This system ( provides a source of l'ong-term reactor cooling after the reactor 7-has been depressurized. The Low Pressure Core Injection portion of the RHR System and the Low Pressure Core Spray System comprise r-the low pressure systems qf the Emergency Core Cooling System. ~~

r--

}] ' The RHR system also contains the Containment Spray System.

r_

Piping for the RER system is made of carbon steel, A106, Grade s.i~ -1/ IL "B"/A155, KCF70 and stainless steel, A312 Grade Typ. 304. 1/ The stainless steel A312 piping in the ECCS systems is only used for piping in direct contact with the suppression pool. This was done as a corrosion prevention measure. This piping is open-ended and not subject to the same stress levels as in the pressurized piping in which IGSCC has been observed. 4L. 7 l-me s ,I

D. High Pressure Core Spray - This Emergency Core Cooling System provides a large source of high-pressure cooling water to maintain reactor water level. Piping for this system is made of carbon steel, A106, Grade "B"/and stainless steel, j_ A312, Grade Typ. 304. E. Essential Services Cooling Water System - This system provides secondary side cooling water to the RHR system, (.j the HPCS, essential HVAC, and Fuel Pool Cooling and Cleanup (_ System. Piping in this system is made of carbon steel, A106, i1E Grade "B". i~ As covered in the affidavit of Dr. Gerald M. Gordon, ~L carbon steel such as the steel used in the ACNGS is not susceptible to IGSCC. Hence, ACNGS will be designed to preclude cracks caused by IGSCC. This eliminates from consideration intergranular l' stress corrosion cracking of all the systems identified by Mr. 37 Doherty. Moreover, even disregarding the measures instituted M for preventing cracks, the suggested water hammer force for ._[ }{_ propagating these nonexistent cracks has been minimized and the unavoidable reduced effects accounted for in all the r referenced systems. l[ Water hammer occurs when forces are imparted to ~ z piping from the acceleration of contained fluids. ACNGS utilizes Etandard industry practice in designing for water y-hammer Ge.g., WHAM code, valve design parameters, vent and ~~ drainage provisions, administrative controls, fill provisions,

- 3

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[ etc.). Additionally, applicable guidance will bo incc cporated into the fluid system designs as it becomes available (e. g., portions of NUREG-0582). The NRC Staff, in NUREG-0582, 4 " Water Hammer in Nuclear Power Plants," has reviewed water ~ hammer events in light-water reactor fluid systems and has classified water hammer problems under nine separate categories. This NUREG is the first of several reports schedulec to be issued by the NRC in seeking generic resolution of Task Action I j~ Plan A-1, " Water Hammer." NUREG-0582 is not a final design i. guidance document and, in fact, the staff has indicated in n [ several instances that no remedial action is required for operating plants at present due either to the limited number y-J i of damaging events reported or the acceptable nature of design solutions incorporated in operating plant systems. The ACNGS fluid systems are designed to eliminate s-k_ water hammer wherever possible. Systems having a potential for water hammer will be designed to accommodate the associated r 1 ,5-loadings. Examples of these commitments, which address various [ aspects of problems identified in NUREG-0582, are as follows: 7-a. The ECC and RCIC systems utilize water leg seal j._ pumps as detailed in PSAR Section 6.3.2.2.5. The use of I the discharge line fill system, administrative controls, a

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filling and venting procedures and the proper location of 1 g vents should effectively eliminate water hammer due to q_ pump startup with discharge lines containing voids. aw _4_ f I WG . ~,

b. ACNGS systems are designed to withstand the dynxnic loads arising from the expected transient flow into empty or partially empty lines, c. Valve operating times (open to close, close to open) will be provided for all active valves. This data will be used to ascertain if any water hcmmer is possible. If it it:. determined that water hammer can occur, the piping will be designed to accommodate these loadings. i d. Control valves will be sized such that they { will be stable through their entire control range. This L subsequently will avoid water hammer phenomena as a result of control valve instability. e. Check valves in which pipe ruptures are postulated upstream of the valve, and the associated piping, will be designed to accommodate the loadings resulting from valve t-closure. For the case of flowing lines, check valves V h will be designed to assure that the valve obturator will remain in a stable condition such that oscillation or intermittent opcning and closing will not occur. Check r Q valves, other than tilting disc check valves, will either rl-be installed in horizontal pipe runs or in vertical runs r [L where flow is upward. Tilting disc check valves will be L' installed in horizontal lines only. Active check valves 1_ will be periodically tested in accordance with ASME q

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Boiler and Pressure vessel Code to assure that they will not stick in the closed or open position (as applicable to safety function). f. The ACNGS has incorporated the traditional design approach for preventing water entrainments or carry-over (and/or condensation) in steam lines. The basic design mechanisms to prevent this event are (a) sloping of horizontal lines downwards in the direction of the steam flow to promote drainage, and (b) provision of drainage features at all low points (automatic or local) where water can accumulate. This drainage feature incorporates .P b steam trapt. automatic leve.1 control valve stations, which ~ .F operate on receipt of level signal from drain pots t located upstream of the level control valves. f g. In addition to the above, ACNGS design also includes vacuum breaker valves in lines that exhaust 9 V-steam below suppression pool water level. This will prevent water.being drawn up into the lines due to "~ / development of low pressure in the line following steam condensation. h. All " solid water" piping systens will have strict administrative controls to satisfy the requirements of venting, and filling and venting. Hence, all pumping a_ systems will be normally started against filled lines .I '1 ?' -S-j l_ g. w =

which will not lead to significant dynamic loads.

Moreover, all centrifugal pumps will be gradually started and will slowly coast down to zero speed due to pump-motor set inertia.

We consider that the loads occurring due to gradual starting / stopping to be insignificant. In summary, the extensive use of carbon steel, which has demonstrated a very high resistance to IGSCC, should alone be sufficient to render the intervenor's allegations groundless. However, the Applicant takes into account that while IGSCC can be resolved primarily on a metallurgical basis, potential water hammer problems can exist in any fluid sysum. The [ Applicant is aware of these potential problems and has taken L engineering steps to assure that they will not adversely ?.1L affect plant safety. Consequently, there is virtually no possibility that propagation of intergranular stress corrosion f) ? cracks due to water hammer forces will occur. .r ?!.' ~ . [ s em- ,m... {' i. W 7-L. g --w y .~ ,.~,e-y q

m = RESUME - LOUIS A GUNTF.ER Senior Enginear - hearials Applications

SUMMARY

07. EXPERIENCE (Since 1968)

Total Experience - More than 12 years engineering experience in =etal-lurgical and welding engineering in the areas of welding design and ~ =aterial selection, pressure vessel fabrication and advanced welding process develop =ent for utility, naval nuclear, deep sea sub=ergence and aerospace projects. Professional Affiliatiens - Professional Engineer in the State of New York. Patents - h thod of Wera*g a. Tube to a Tube Sheet, Fatent No. 3,824,663. Honors and Awards - Ta= 3 eta Pi Noah A Kahn Memorial Award - ASTM. i Professional Society Me=berships - A=arican Society for Metals A=erican Weldi=g Society il-Selding Research Council L Euucatiez - 3S Me =17-p =al Engineering (=agna et=t laude) ?clytec==ic: Institute of Brooklyn - 1968 ~ MS Metal'+- gy - New York University 1970 3 1 E3A &=aga~nt Syste=s New York University 1975 T~ Specialiced Tr'aining - Co=pleted the following courses: (a) TT-4 Fractical Nuclear Power Plant Technology [.{ Course / sponsored by Ebasco-1977. (b) BW 3asic Stea= Generating Technology Course / sponsored by Ebasco-1976. (c) GI-BWR course / sponsored by Ebasco-1975. (d) Titaniu= and Its Alloys / sponsored by de A=erican Society for & tals-1968. C-d f.. [ $i O w O b* 4 en

ERR &n evxtwsm e REPRESENIATIVE ESASCO PROJECT EXPERIFLNCE (As Senior Engineer) ' - ~ Nuclear Louisiana Power & Light Co=pany Waterford Unit 3 Houston Lighting &. Power Co=pany Allens Creek Unit 1 Possil New Yoric State Electric & Gas Co=pany , Homer City Unit 3 Pen =sylvania Electric C%a=y Iowa ?ublic Service.Cc=pany Neal Unit 4 Public Service Co=pany;of. Colorado-Pawnee Unit 1 - Houston. Lighting & Powe-- Co=pany Li=estone' Units 1 and 2 EEASC3 EXPERIENCE (Since 1974) Senior Fgineer - (6 years), New York Office 'i ..r Responsible for all =at=ers concerning New York Office welding fabrication r and = ate:ials selecrion.-during-design and construction phases on assigned projec5 and for p :viding. ter"- ' cal support'for project site" support engineers. Assigne) ~ i ~ .to sper ' e'. projects-for-develop =hnt of automatic ffxed position pipe welding - ~~ ~ procedures. c q L .?EIOR EXPERIENCE (6 Years) i L. Curtiss Wright Corporation c Wood-Ridge, New Jersey Senior Engineer (3 years) Assigned to the Weldi=g Technology Department, Nucl2ar Division. Responsible for develop =ent, i=ple=entation and surveillance of speciali=ed welding procedures e= ployed in the manufacture of Naval Nuclear Cc=ponents to NAVSEIPS-250-1500-1 require =ents. These procedures included specialized seal velding, auta=atic tube-to-tube sheet velding, and auto =atic orbital pipe welding processes. Additional responsibilities included =etallurgical studies for development projects and produe:Lon support, =anpower and schedule esti=at'ng selection, andvendoraudi:fng.fornewweldingprojects,capitalequipment L 6 yo l 6 w W

Pag 2 3 of 3 RESUME - LOUIS A GUhTdER PRIOR EZ?ERIENCE (6 Years) (Continued) Curtiss Wright Corporation Wcod Ridge, New Jersey ~ Engineer (2 years) Assigned. to the Process Metallurgy Depart =ent, Aerospace Division. Responsible for develop =ent projects concerned with repair welding and hea: crea ~ n: of turbine blades, plasca are welding, inertia weldi=g, P14 and production velding od D6AC sreel asse=blies for the Grt P ro gr*- U S Naval Applied; Science Laboratory ~ New York, New Yo ric Physical Metallurgistn (L year) Assigned to the Tite = ~ - Development Program, responsible for carrying out velding develep-a

  • studies and velder trai=ing programs on heavy see:1,n titani=. alloys-f= support of U S Navy deep sub=argence vehicle programs.

r Ebasco Services Incorpe=ated Materials Laboratory Technician (S-er E= ploy =ent) F Responsible for spee' -n-preparation, =etallographic work on failure 1. analyses, and braring and =achining operations perfor=ed during laboratory ~ studies for the power industry; y i .F

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o Born Philadelphia, Pennsylvania ~ Education Polytechnic Institute of Technology, degree of Engineer in Nuclear Engineering - 1978 Massachusetts Institute of Technology, is in Nuclear Engineering - 1970 U.S. Coast Guard Academy, 35 - 1968 Member American Nuclear Society Licensed Registered Professional Engineer in the State of New York +- (No. 56673) Experience: 1980 Ebasco Services Incorporated, Lyndhurst (NJ) Office; Supervising Engineer, Mechanical-Nuclear Engineering / Depart =ent: Houston Lighting & Power Co - Allens Creek NGS - Unit No.1 - _j 1200 MW(e) BWR i.. l Technical and administrative responsibility for mechanical, i~ fire protection, piumbing, HVAC, stress analysis, hangera and 1 supports; and inservice inspection activities. Includes schedules, budgets, and client. relations. (:i L 1978-1980 Ebasco Services Incorporated, Lyndhurst (NJ) Office; Principal Engineer, Mechanical-Nuclear Engineering Department 4-Houston Lighting & Power Co - Allens Creek KGS - Unit No.1 -- 1200 MW(c) BWR, Lead NSSS Etigineer Responsible for preparation and maintenance of ECCS and BOP flow diagrams, piping layouts, system design descriptions. inservice inspection provisions, Ndelear Island building general arrangements, PSaR and FSAR preparation, ecuipment sizing and specification, NSSS vendor interface for corre-9~ spondence, drawing review, and contract administration. 1976-1978 Ebasco Services Incorporated, New York Office; Senior Engineer, Mechanical-Nuclear Engineering Department including: H' uston Lighting & Power Co - Allens Creek NGS - Unit No.1 - o v_ I200 MW(e) BWR, Lead NSSS Engineer q._ [_ Louisiana Power & Light Co - Waterford SES Unit No. 3 - 1165 MW(e) PWR. Lead NSSS Engincar (Same responsibilities as listed for 1978-1980 above.). e ~

thtCADDG4TES ~ ' ' ~ l 1976-1978 Responsible for preparation and =aintenance of ECCS and (Cont'd) B0p flow diagrams, piping layouts, system design descrip-tions, inservice inspection provisions,' Nuclear Island building general arrangecents, pSAR and FSAR preparation, equipment sizing and specification, NSSS vendor interface for correspon'dence, drawing review, and contract ad=inis-r- tration. i m. 1974-1976 United States Coast Guard, Marine Inspection Office, New York; Lieutenant - Supervisory Boil,er Inspector. Responsibility for supervision, assignment and training [~ of Marine Inspectors in largest Marine Inspection Office e in country. Inspection of hull ar.d machinery material condition of U.S. flag and foreign merchant vessels, and g-pressure-vessels under construction. Application of various laws and regulations of the United States, ASME Code, ANSI, TEMA, NEC and NFPA Standards. Review of g cngineering pir.ns and alterations, reports from field and (( resident inspectors. 1973-1974 United States Coast Guard, USCGC Spencer (WHIC-36), [ Lieutenant - Chief Engineer. Respor.:ibility for operation, maintenance and repair of hull and engineering plant of 6200 slip twinscrew s'teamship. Direct supervision of 40 l-j officers and men. Duties included preparation of repair i;L specifications and maintenance of vessel records. Received Coast Guard Achievement Medal for superior performance of ~ ci duty. i ~ 1970-1973 United States Coast Guard, Marine Inspection Office, New York, Lt and Ltjg - Marine Inspector. Inspection of hull and machinery of U.S. and foreign flag merchant vessels. 1968-1969 United States Coast Guard, USCGC Mellon (WHEC-717), Ensign, Assistant Engineer Officer. e 9 i t-J t ke -b-( o a-7- ... -.. ~ _. -, ,_r.._.

J r Attachment LAG /WFM-3 UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S (Allens Creek Nuclear Generating S Station, Unit 1) S ERRATA Page 2, last sentence, - revise"..... Grade Type 304 1/." to "..... Grade Type 304L 1/." Page 2, footnote 1/ - delete in its entirety. Add the following in its place: "l/ The stainless steel A312 piping in the ECCS' systems is used only for open-ended piping in direct contact with the suppression pool, and in the flushing drains downstream of normally closed block valves. In neither case will the stainless steel piping be sub-jected to the same stress levels as the pressurized carbon steel piping." Page 3, first paragraph, last sentence - revise "..... Grade typ. 304." to "..... Grade Type 304L 1/." Page 6, last sentence, item f. - delete in its entirety. Add the following in its place: "The automatic features on low point drains include the use of steam traps, restriction orifices to allow a continuous drainage flow, level control valves which operate on receipt of level signals in drain pots upstream of the valves, and drain valves which open on receipt of a low load signal." ? 1 .-_.-_____.__k__._- . _ _ _ _}}

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