ML20052C689
| ML20052C689 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/04/1982 |
| From: | Danni Smith Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20052C678 | List: |
| References | |
| NUDOCS 8205050394 | |
| Download: ML20052C689 (10) | |
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't UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of LONG ISLAND LIGHTING COMPANY Docket Number 50-322 (Shoreham Nuclear Power Station, Unit 1)
)
J NRC STAFF TESTIMONY OF DAVID E. SMITH ON REACTOR COOLANT PRESSURE BOUNDARY INTEGRITY (SCContention24)
S0C Contention 19 50C Contention 19 i
8205050394 820504 PDR ADOCK 0500032 p
OUTLINE OF TESTIMONY This testimony addresses SC Contention 24 and S0C Contentions 19(c) and 19(d) regarding Regulatory Guides 1.31 and 1.44 and NUREG-0313, Rev. 1, and NUREG-0619.
The NRC Staff in the Shoreham Safety Evaluation Report (SER) and its Supplements (SSER) has determined that the material selection and processing methods allowed in NUREG-0313, Rev. 1, have been followed.
LILC0 has asked for some relief from the augmented inspection requirements of the NUREG. The NRC Staff will consider each situation on a case by case basis after review of all facts and data. The requiremetns of Reg. Guide 1.31, Rev. 1, were met.
Revision 1 is more stringent than Revision 3 and accordingly the contention on this subject is not valid. The requirements of NUREG-0619 were met and the contention on this subject is also not considered valid.
In conclusion, GDC's 1, 4, 14, 30 and 31 have been met.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Hatter of LONG ISLAND LIGHTING COMPANY Docket Number 50-322 (Shoreham Nuclear Power Station,
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Unit 1)
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NRC STAFF TESTIMONY OF DAVID E. SMITH ON SC CONTENTION 24 AND SOC CONTENTIONS 19(c) AND 19(d)
Q.
State your name and position with the NRC.
A.
My name is David E. Smith.
I am a senior materials engineer assigned to the Materials Engineering Branch, Division of Engineering of the Nuclear Regulatory Commission.
Q.
Have you prepared a statement of professional qualifications?
A.
Yes. A copy of my professional qualifications is attached to thistestimony(Attachment 1).
i Q.
What is the purpose of your testimony?
A.
The purpose of this testimony is to address SC Contention 24 and S0C Contentions 19(c) and 19(d) which relate to the integrity of r
the reactor coolant pressure boundary.
Q.
WhatareSCContentions24andSOCContentions19(c)and19(d)?
A.
SC Contention 24 states:
Suffolk County contends that LILC0 has no't demonstrated, and the NRC Staff has not verified,
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0 that Shoreham meets the requirements of 10 C.F.R. 50, Appendix A, GDC 4, 14, 30, and 31, with regard to the adequacy of material selection and control
- and system design as follows:
(a) The use of appropriate materials and processes as specified by NUREG-0313, Revision 1, has not been fully followed in the design and construction of the Shoreham piping systems important to safety.
(b) Recommendations contained in NUREG-0619 (p. C-12) relating to the installation of a low flow controller to be used to control feedwater flow over a range of flow from 0.5%
to 10 percent of rated flow has not been implemnted at Shoreham. Analytical evidence shows that such a flow controller is necessary to limit crack growth in BWR feedwater nozzels over the life of the plant.
S0C Contention 19(c) states:
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Regulatory Guide 1.31. -- The control of ferrite content in stainless steel weld metal by LILCO complies with Revision 1 of the guide rather than Revision 3, with regard to verification of delta ferrite content of filler materials and to examination for ferrite content by a magnetic measuring instrument. Therefore, Shoreham does not comply with 10 C.F.R. Part 50, Appendix A, Criteria 1 and 14.
S0C Contention 19(d) states:
Regulatory Guide 1.44. -- LILC0 has not adequately demonstrated control of the application and proceeding of stainless steel to avoid severe sensitization that could lead to stress corrosion cracking as required by 10 C.F.R. Part 50, Appendix A, Criteria 1 and 4 and 10 C.F.R. Part 50, l
Appendix B in that Shoreham has failed to comply with the NRC Staff position described in NUREG-0313, Revision 1 as follows:
l (1) Portions of the reactor recirculation system l
(B31) and stainless steel to carbon steel l
transition welds between the reactor recirculation system and the reactor water clean-up, core spray, and residual heat removal systems do not meet the guidelines set
forth in NUREG-0313, Revision 1, for ASME Code Class I and II reactor coolant pressure boundary piping.
(2) The commitment to inspect portions of the reactor recirculation system and transition welds that have been classified as "non-conforming" per NUREG-0313, Revision 1, has been conditioned by LILC0 to be limited "to the extent practicable" due to physical interferences in some locations. NUREG-0313 does not specifically allow for such deviations. Also, LILC0 has failed to identify specifically the number, location, and detailed justification for these deviations. Further, LILC0's objection to the
" service sensitive" classification of recirculation riser lines and inlet lines at the safe-end curves demonstrates a failure to comply with the requirements of NUREG-0313.
Q.
Do all parts of the three contentions address the same concern?
A.
No. SC Contention 24(b) concerns NUREG-0619 while all other parts of these contentions concern stainless steel piping and their weldments as covered by Reg. Guide 1.31, " Control of Ferrite Content in Stainless Steel Weld Metal," Reg. Guide 1.44, " Control of the Use of Sensitized Stainless Steel," and NUREG-0313, Rev. 1, " Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping."
Q.
What is the NRC Staff's position concerning SC Contention 24(b) which alleges that Shoreham has not installed a flow controller as recommended in NUREG-0619?
A.
LILC0 has informed the NRC Staff that two low flow control valves have been installed in parallel with split range control. The split range control enables control to below 0.1% of rated flow, extending the lower limit of the range of desired control which has been
described as 0.5%.
The Applicant will monitor temperature variations during start up to evaluate the 'need for additional controls, and has stated he will establish additional controls / procedures if necessary.
Therefore, SC Contention 24(b) is invalid.
Q.
What is the NRC Staff's position with respect to the con-formance of the Shoreham design to the requirements of NUREG-0313? [SC 24(a) and S0C 19(d)(1) and (2)].
A.
NUREG-0313, Rev. 1 outlines several methods to minimize crack susceptibility.
It specifically allows for several materials and processing alternatives with inservice inspection requirements related to the materials and processing variables used in construction. The Applicant has followed the requirements of NUREG-0313, Rev.1, as to material selection and processing. LILC0 has, for practical reasons, asked for relief as permitted hv 10 C.F.R. 50.55a(g)(6)(1) from some of the inservice inspection requirements specified in the NUREG.
The intent of NUREG-0313, Rev. 1 is to prevent the maintenance problem of leaks caused by intergranular stress corrosion cracking (IGSCC) in class 1, 2, and 3 stainless steel piping systems. These leaks due to IGSCC are not regarded as a significant concern to public health and safety because the inherent fracture toughness of the stainless steels used will prevent rapidly propagating pipe failure, and the leaks which occur will remain small for a considerable period of time. The monitoring of fluid accumulation from these type leaks has served as the major detection method for IGSCC.
IGSCC is a system problem in those stainless steel piping systems which are susceptable to this fonn of corrosion; that is, i
it will not be localized to one weld joint, but will occur in several l
weldments at approximately the same time and rate. Accordingly, not all weld-joints in a susceptable system need to be monitored under inservice
.g inspection.
The Applicant has indicated that some welds may not be inspectable because of physical interferences. These situations will be reviewed individually on a case-by case basis. A representative sampling plan is adequate to satisfy NUREG-0313 in service inspection requirements.
Representative sampling allows for some joints in a given piping system to have inservice inspection waived because of physical constraints, or other considerations, such as the radiation exposure as low as reasonably achievable (ALARA) concept. LILC0 will be required to specify their inservice inspection program in~ detail to allow for such considerations. GDC 1, 4, 14, 30, and 31 will be met, as well as relevant portions of Appendix B, when the Staff makes its case by case decisions applying NUREG-0313. This also assures that the actions of LILC0 are satisfactory to the Staff in meeting the recommendations of Regulatory Guides 1.31 and 1.44.
Q.
What is the NRC Staff position concerning LILC0's request to consider recirculation risers and recirculation inlet lines at safe end curves as non-conforming rather than service sensitive? [ SOC 19(d)(2)].
A.
The Staff has not made a judgment at this time for this situation as all of the technical facts have not been determined. At present, however, we do not plan to waive the inspection requirements specified in NUREG-0313, Rev.1, which the Applicant has requested be waived. A satisfactory technical justification for waiving such requirements has not yet been prestnted by the Applicant.
Q.
What is the NRC position regarding LILC0's conformance with Regulatory 6 aide 1.31, Rev. I rather than Rev. 3? [ SOC 19(c)].
A.
Revision 1 of Regulatory Guide 1.31 is more restrictive and has more requirements than Revision 3.
These additional and more i
restrictive requirements which LILC0 has met assures that the Applicant has complied with 10 C.F.R. Part'50, Appendix A, Criteria 1 and 14 as Regulatory Guide 1.31 applies to accomplish these criteria. The differences in these revisions reflect in part the updating of the American Society for Mechanical Engineers Boiler and Pressure Vessel Code under which these systems are built.
Q.
What are your conclusions?
A.
I conclude that SC 24 and S0C 19(c) and 19(d) are without me ri t.
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ATTACHMENT 1 PROFESSIONAL QUALIFICATIONS OF DAVID E. SMITH March 80 Sr. Materials Engineer to Materials Engineering Branch Date Division of Engineering Knowledgeable and experienced in welding, fabrication and inspection of materials and other related engineering aspects of nuclear reactors. Serves as a qualified materials engineer in the Materials Engineering Branch, Division of Engineering. Responsible for reviews, analyses, and evaluation of safety issues related to structural and mechanical components of reactor facilities licensed for power operation.
Participates as a technical reviewer in evaluating applications for construction permits and operating licenses for power and non-power reactors and operational and design modifications of DOE and D0D-owned operating facilities exempt from the licensing process.
Specific assignments include review of operating license applications for compliance with Standard Review Plans for which the Materials Application Section is responsible.
EDUCATION:
Bcchelor of Metallurgical Engineering, Rensselaer Polytechnic Institute, 1959 EXPERIENCE: (PriortojoiningNRC)
May 1967 to Materials Engineer Naval Sea Systems Comand, Code 05E2, March 80 Washington, D.C.
Responsible for materials specifications, Hull material development programs, consultant on weldina, fabrication and inspection of metal structures, material selection, corrosion, machinery materials problems.
The hull material development programs involved basic alloy research, the making and processing of all structural metal forms (castings, forgings, plate, extrusions, weld wire, rolled product), their fabrication (welding, cutting, machining, forming, painting), structural tolerances, and evalu-ation of structural performance, strength, toughness, corrosion, fatique, compatibility with other materials, etc.
I would interface with material manufacturers, suppliers, shipyards, anu designers, and the type desks responsible for providing ships to the fleet.
April 66 to Student. Acquired commercial and instrument ratings for May 67 single engine land airplanes.
I Dec 64 to Manufacturing Engineer for Ling Temco Vought, Centerline, April 66 MI. Developed welding procedures for the LANCE missile tankage assembly.
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D:cument Name:-
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TESTIMONY;0F DSHITH Requestor's ID:
~DARLENEW Author's Name:
repka/sb-Document Comments:
reactor coolant pressure boundry integrity /shoreham test.
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