ML20062H593

Affidavit in Support of Summary Disposition of Jf Doherty Contention 43 Re Use of Certain Coating & Cleaning Compounds.Ge & Applicant Committed to Follow Reg Guide 1.37 Re Stainless Steel Cleaning Requirements.Pp 276-279

ML20062H593
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	07/29/1980
From:	Shelton W, Wiley J GENERAL ELECTRIC CO.
To:
Shared Package
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References
ISSUANCES-CP, NUDOCS 8008190239
Download: ML20062H593 (4)

Text

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O UNITED STATES OF AMERICA fiUCLEAR REGULATORY CCMMISSION r

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of h

HOUSTON LIGHTING & POWER COMPANY )

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Cocket No. 50 466 l

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(Allens Creek Nuclear Generating )

l Station, Unit No.1)

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AFFIDAVIT CF DR. JOHN S. WILEY AND W. R. SHELTON State of California County of Santa Clara I, Dr. John S. Wiley, Manager Chemical and Radiological Methods Unit, within

'he Nuclear Power Systems Engineering Department of the General Electric Ccmpany, of lawful age, being first duly sworn, upon my oath certify that the statements contained in the attached pages and acccmpanying exhibits are true and correct to the best of my knowledge and belief.

Executed at San Jose, California, l<

July.2f, 1980.

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l I, William R. Shelton, Senior Engineer, within the Nuclear Power Systems Engineering Department of the General Electric Company, of lawful age, being first duly sworn, upon my oath certify that the statements contained in the attached pages and accompanying exhibits a 'e true and correct to the best of my knowledge and belief.

Executed at San Jose, California, July *, 1980.

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Subscribed and sworn to before me this # 3 day of July, 1980.

AkkY-_m NOTARY PUSLIC IN AND FCR SAID COUNTY 278 AND STATE.

I~gy[c My ccmmission expires h

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S

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HOUSTON LIGHTING & POWER S

p COMPANY S

Docket No. 50-466 i

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(Allens Creek Nuclear S

h Generating Station, Unit 5

No. 1)

S Affidavit of Dr. John F.

Wiley and William R.

Shelton My name is John F. Wiley, I am employed by the General Electric Company as Manager, Chemical and Radiologica j

Methods Units, a position I have held since 1971.

A statement of my experience and qualifications is set out as Exhibit I.

My name is William R.

Shelton.

I am employed by the General Electric Company as Senior Engineer, Materials Appli-cation Group, Nuclear Power Systems Engineering Department.

A statement of my experience and qualifications is set out as Exhibit II.

This affidavit addresses the concerns raised by Mr.

Doherty in his Contention No. 43.

Mr. Doherty asserts that General Electric Company (and, supposedly, Applicant) takes exception to the provisions of Regulatory Guide 1.54 which pertains to the cleaning and coating of stainless steels.

This is not the case.

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Regulatory Guide 1.54, " Quality Assarance Require-ments for Protective Coatings Applied to Water-Cooled Nuchear

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power Plants," is concerned primarily with preventing the release of coating materials inside the containment by radia-tion decomposition, chemical reaction or heat in a post-accident y

t environment.

Regulatory Guide 1.54 is also seconydrily in-l-

P volved in other quality assurance requirements sor ' coating ferritic and galvanized steels, aluminum, concrete and masonry, f

k and preparing (cleaning) and coating stainless steel.

The latter requirement forbids the use of certain

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chemical ccmpounds which may contribute to intergranular stress corrosion cracking of stainless steel.

In fact, General Elec-tric does not coat the steinless steel used to fabricate

,t nuclear steam supply components; therefore, General Electric

.r3 ri complies fully with Regulatory Guide 1.54 by avoiding epl coatings and coating preparations.

The apparent source of Mr. Doherty's confusion is the fact that General Electric offered a set of alternate proposals to various provisions in Regulatory Guide 1.54.

He cited references to correspondence on the matter between G.E.

and the NRC.

None of these proposed alternates in any way deal with 4

cleaning er coating stainless steels.

For completeness and i

clarity, copies of the proposals, the NRC response, and further related correspondence are provided in Exhibit A.

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P General Electric's requirements ~1/

for cleaning stainless steci for purposes other than coating preparation is in complete accord with Regulatory Guide 1.37, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated r

Components of Water-Cooled IIuclear Power Plants."

PSAR p.

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C1.37-1 says the Applicant will comply with Section C.4 of r

Regulatory Guide 1.37, which states:

Chemical compounds that could-contribute to intergranular cracking or stress-corrosion cracking should not be used with austenitic stainless steel and nickel-base alloys.

. Examples of such chemical compounds are those containing chlorides, fluorides, lead, zinc, copper, sulfur, or mercury where such elements are leachable or where they could be released by breakdown of the compounds under expected environmental conditions (e.g., by radiation).

In aum, no coatings of any type will be used on stainless steel in the nuclear steam supply system.

General Electric's stainlass steel cleaning requirements are in ac-l cordance with Regulatory Guide 1.37, and Applicant commits in i

the PSAR to follow Regulatory Guide 1.37, l

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G.E. Plant Requirement " Cleaning of Piping and Equip-ment," Doc. Oio. 22A2749, Rev.

2, May 17, 1979.

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E 279 l

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