ML20062H605

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Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard Re Summary Disposition of Jf Doherty Contention 44 on Intergranular Stress Corrosion Cracking. Excerpts of Jf Doherty Deposition Encl.Pp 325-339
ML20062H605
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 08/04/1980
From:
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML19331C559 List:
References
ISSUANCES-CP, NUDOCS 8008190257
Download: ML20062H605 (15)
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Text

{{#Wiki_filter:. k I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1 In the Matter of S S HOUSTON LIGHTING & POWER S CCMPANY S Docket No. 50-46o S (Allens Creek Nuclear S Generating Station, Unit S No. 1) 5 STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD FOR i DOHERTY CONTENTION 44 l (1) Virtually all of the piping in the feedwater, steam supply, residual heat removal, ECCS, containment spray and service water systems will be made of low carbon stainless y ] steel or plain carbon steel, both of which are not susceptible to integranular stress corrosion cracking. -Small segments of open-ended piping in direct contact with the Supression Pool will be made of stainless steel with a slightly higher carbon content. However, this piping will not be subject to the same stress levels as the pressurized piping in which IGSCC has been observed.. (Affidavit, pp. 2-3). (2) The ACNGS will use conservative design practices in accounting for water hammer forces, and will incorporate applicable NRC guidance into fluid system designs as it becomes available. (Affidavit, pp. 3-4). 254 g008190

-325

(3) The ACNGS fluid systems will be designed to eliminate or minimize water hammer. Those systems which have a potential for water hammer will be designed to accom-t modate the associated loadings. These additional design measures all address areas of concern identified by the NRC Staff in NUREG-0582. (Affidavit, pp. 4-7). 1 4 9 4 O E b 326

79-1743C DSH COSTS Ddherty Contention No. 44/ PAlO BY PLF. DEF. IGSCC and Water Hamtr.er 3 i [ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3EFORE THE ATOMIC SAFETY AND LICENSING SOARD IN THE MATTER OF: HOUSTON LIGHTING AND 1 POWER COMP ANY, (ALLENS Docket No. 50-466 CREEK NUCLEAR GENERATING STATION, UNIT 1) { 4 1a 4 a d i DEPOSITION .5 y JOHN F. DOHERTY 1.e } ( m , * *Y-n TE & - fl a 327 N W, (b$l 1 '917 Bank of be Southwes: Suilding. Houston Texas 77002. (713) 552-5911 4

_ m _ _ _.. 336 l l i 1 General Electric took to reg. guide 1.547 2 A. Yes, and that was stated in the earlier i r i 3 reference that I gave you. 4 MR. NEWMAN: If it were to be 5 estaLlished that none of the compounds identified 6 in your contention 43 are used-to clean or coat 7 stainless steel components at Allens Creek, would i 8 enat th~en moot your contention? I l 9 A. Well, the contention lists some elements 10 and some, I've forgotten the term for that, some 11 salts, I guess, but Mr. 14 e w m a n, if those were 12 removed, yes, that would remove the basis. 13 Q. (BY MR. BIDDLE): Would you turn to your 14 contention 447 15 A. Incidentally, I'm not an expert on a 16 cleaning compounds. 44? y a 17 Q. Yes. What is water hammer? o L 18 A. My understanding of it is that it's a y 19 force that emerges when steam condenses in piping L 20-that normally carries steam and then in some way 21 is moved. In other words, water sitting in a o h 22 pipe and the pipe is meant to carry steam and it 23 can move as water in the event the system starts 24 operating, that pipe starts in use. 4 2S If the pipe were sitting idle, for 'I 328 ) 7 4 P r Q M t ? i n N A T. COURT REPORTERS, INC.

-) ____ _ _ s = __ _ u _ a _ __ 2._.= __ _ __ _ _ __ _ _ _ _ _ ___._ _______= _ = =.s =. 337 d i 1 example, it would then cause this water to move 2 and it strikes a part causing a noise and it's dI 3 called water hammer. 4 Q. So water hammer is a nuisance as to u 5 noise? ~ 6 A. It can hit with enough force that in the l' r 7 contention, what I've said that is in the event o 8 the pipes are cracked, the force might be i, r U 9 sufficient to break them open. 9 10 Q. Well, what is the force imparted to the 11 water that's lying in these pipes? it 12 A. Well, it might be an additional r s, I 13 might 'be a force of air moving behind it, pushing i s. 14 it forward. That would be one very common one. 15 The moving air is behind the water, so what J 'E 16 actually strikes at the weakened place is water WI 17 which hits with appreciably harder force than I 13 steam. y 19 Q. So is it your contention that there are .i 20 pipes at Allens Creek that contain a small amount Ch 21 of water so that they are for practical purposes, ? 22 empty and that this water can somehow be .r 23 motivated by the introduction of air with ?i 24 sufficient force to cause problems? e 25 A. Yes, broadly, that sounds about right. S 329 1

1 Q. What causes the air to be.in motion? 2 A. There might be any number of reasons in 3 which that system might have some material such 4 as steam or air driven through it or some 5 emergency purpose or some testing purpose or 6 c. Would you identify the systems in Allens i 7 Creek where these motive forces will be i 8 introduced into partially filled pipes? f 1 9 A. Well, tUREG 0582, pages 2.2 and 2.3 10 state and I believe this is a summary statement, 11 on the basis of reactor operating experience, the i 12 most serious water hammer concerned are pump 13 start-ups with inadvertently avoided lines in the 14 emergency core cooling system and residual heat 15 removal system. 16 Q. So those are the two systems of concern 17 in your contention? I 18 A. No, there is an additional one. And l 19 main feed water line transients caused by flow 6 20 control valves. 21 Q. So the three systems of concern in your 22 contention for Allens Creek are 23 A. Those are the three major concern. 24 Q. ECCS, RRR and main feed water? 25 A. Yes. 1 INTERNATIONAL COURT REPORTERS, INC.

4> l Q. It is these systems you contend are 2 susceptible to water hammer forces? 3 A. Yes. 4 Q. Would you describe the cracking that 5 occurred at Dwayne Arnold has reference in your 6 contention? 7 A. I' do my best. As I understood these 8 cracks, they were sort of in the shape of this, a ) 9 U-shape. They were not longitudinal, but rather 10 around, imagine a horizontal pipe, they were sort 11 of shaped semicircular going around the pipe, 12 rather than down the pipe. 13 Q. What caused these cracks? 14 A. I'm not certain what's caused them. 15 Q. What leads you to believe that these 16 similar cracks can occur at Allens Creek? 17 A. Well, first of all, nuclear plants are m 18 constructed with materials that are as least _i 19 likely to crack as possible and that goes for the 20 Dwayne Arnold plant. Allens Creek probably is 21 based on materials that may represent an 3 22 improvement or may not. 1 23 Q. Is it your contention that Allens Creek I 24 will have incorporated into its pipes, the m 25 material which cracked at Dwayne Arnold? 331 9 d Isr5xNATioNAu cuasi steusrsas, Asu.

._______________________________________________s., 340 , jy Th .a L) 4-1 A. No, but it's my contention that the y E' 2 possibility of pipe cracking will be required, it y 1,..8 3 will be required to deal with it simply because M, .L 4 they nave never created a crackproof pipe. 5 Q. What is the basis of the assertion that

t.

,I t 6 they have never invented a crackproof pipe? [j. tv 7 A. It's never been a announced happily as i.i

44 8

it would be if it were invented. , h. 41 9 Q. Where are you looking for the r ?e 10 announcement? 97 A 2: 11 A. Particularly in NRC publications. -{ 12 Q. Your sole basis for contending that i. n 13 Allens Creek will experience cracks is the fact 1. ~ l .,5 14 that they experienced cracks at Dwayne Arnold? !' 5 15 A. No, that also the NRC will require that }'E a i 16 accidents be analyzed for pipe cracking and pipe j j

r 17 breaking and that if a pipe could not crack or 1

i n l'5. 18 break, they would not require that. 7 1..( 19 Q. What is your basis for that statement? t i ( : Ei 20 A. What is tha t? J I ' ' i j 21 Q. Your last statemenr? Would you like it i [ I5 22 read back to you? 1.. 23 A. Yes, that would be all right. j 24 'r ] l 25 (The answer was read back by the i .i < 332 fj y r u m e n N A ? i n N A r. coua? anpaaTens. I:JC. ll

341 1 reporter.) ] 2 3 Q. Someone at the NRC tell you that to be 4 true? 5 A. No, but I think common sense would cell j l 6 you, don't analyze something that can't happen. f 7 Q. So the sole basis for your assertion 1 I 8 that cracks will occur at Allens Creek is the d 9 fact that a the staff has required analysis 10 assuming that pipes will break? 11 A. There' is a good deal of expensive 12 research financed by the NRC on pipe cracks and y t. 13 on metallurgy to prev.ent pipe crack. 14 Q. What'is the basis of your assertion that 15 that research has not been successful? i 16 A. The fact that it's still ongoing 17 indicates that it's not finished. 18 Q. So the basis for your assertion that i 19 there will be cracks at Allens Creek is the fact 20 that there is con'tinuing research into pipe 3 i 21 cracks? 22 A. Yes. 23-Q. And that's your sole basis for asserting 24 tha t? 25 A. The fact that other plants have p_. 333 s I N T 6 tii4 A f I O N A i, COUni n L e' G it i o n d. 1.1 C.

...____....__ ~.._ w c._. w d2 s.c-1 342 I[ l experienced cracking, also, j Am 2 Q. More specifically, the fact that there er j{ 3 were cracks at Dwayne Arnold? l 4 A. Cracks at Dwayne Arnold or are the { 7t t i =w 1 5 outstanding example. l ~ t r e i ja 6 Q. What similarities exist between the 7 materials that c r r. c k e d at Dwayne ~ Arnold and the g, 4 8 materials used in the design of'Allens Creek? ] 9 A. Well, I don't know that. ^ 10 Q. So you have no real basis for making a p AA i 11 correlation between the cracks at Dwayne Arnold t,o il 12 and the cracks at Allens Creek? 13 A. At this time, I don't have the specific } w{ T4 14 information to tell you p'r e c i s e l y the caterfal 15 that has cracked at Dwayne Arnold, s o?' t h a t if I 16 go to the record of Allens Creek, I can't tell go

L 17 you, this is exactly the same material.

18 Therefore, I cannot tell you. .) 19 Q. If they were of much different materials 20 than the the fact that there were cracks at y 3 21 Dwayne Arnold would say nothing about the ability fg 22 of the material used for Allens Creek to resist ' 12 23 cracks, would it? o s 24 A. Yes. Well, that would depend on what 'much -o 25 difference" would have been. ( '334 q. W INTERNATIONAL C O!! a ? aRanmTraq rw

_. m -. - __. __ _.: r _. _ ~ -. 343 L ._2, t 4 ( 1 Q. But you don' know what the design is ] l so you're not in a 2 for either;of those planth, nl 4 x l i 3-p o s i t i o n',t.o make any judgment as to,whether they i 3 s. di'fferent? f 1 4-are similar or l V A 5 A. I'm in a reasonablo pesition to judge 1, ~ 2th'e p '. p e s - h a v e to do a 5 they are s i m i l a r!, because 7 similar tasks. 8 .Q. Is,su.sceptibility tp, cracking solely a y, 9 " function o,f the TASC they have to perform or is 10 it a frnetion o't sth e metal f.om shich they are ~ ~ w 11 composed?S. 12 ~h.. It's not solely a function of the TASC M '/ s i' 13 that is pirfor'med. [ 1 ,, l'4 'Q.. Is it a function the 'are to perform?

.,3

. 15 A. Somewhat. 16 Q. And to what degree? 17 A. If the temperature and pressure that the L 18 pipes are subjected to are similar and the flow, 1 19 the' amount of material that must move through a 20 them, then they are similar. u 41 .21 Q. So you're contending that because Allens a a' 22 Creek has pipes which will experience the same -e wi 23 pressure and temperature environments as those _.] 24, that cracked at Dwayne Arnold, Allens Creek's /25 pipes will crack? '~" 335 j 4 - - -, m. coua amanas, uc.

344 1 A. Allens Creek's pipes have the same 7 L 2 difficulties to overcome. In fact, Allens 3 Creek's may even be greater in view of the larger ,3 4 capacity of Allens Creek's than Dwayne Arnold. .J 5 Allens Creek's pipes will carry more flow, more 6 material. i 7 Q. So you are contending that the reason J 3 you assert that Allens Creek pipes will crack is l 9 because they will experience the same or. greater ,e 10 or more adverse temperature, pressure and flow i ' 1, 11 environments; is that correct? eh 12 A. As far as I know, they will not , ;3 13 experience greater temperature. I think they i C 11 14 will experience a greater amount of water flow, 15 many of them for the component that they are and 16 that would mean that some pipes will carry more 17 than any pipe at Dwayne Arnold. 18 Q. So you have put together the fact that i r( 19 there was a crack at Dwayne Arnold and the fact 'l 20 that flow rates at Allens Creek will be greater ) 21 tnan that experienced at Dwayne Arnold and 22 conclude F. h a t the cracks at Dwayne Arnold will 23 also occur at Allens Creek? 9A 24 A. There would be similar cracks, it's my d 25 belief. al 338 + l A INTERNATIONAL COURT REPORTERS, I:4C.

345 1 c. 1 Q. Similar cracks will occur because of the e 2 greater flow rates at Allens Creek, is that your l L 7 a 3 contention? i 4 A. No, not entirely, because the materials i m 5 are similar, also. 6 Q. The materials between Dwayne Arnold and i i 7 Allens Creek are similar? m 8 A. Uh-huh. i 9 Q. What is the basis for that statement? have 10 A. Because the materials have to be 9 . 4 11 to do the same job that there is an effort made l7 'q 12 to put the least susceptible to crack materials {g 13 to work in the nuclear power plants. l 14 Q. What was the material used at Dwayne i 15 Arnold? I fy 16 A. Specifically, I don't know. ! %.o l 17 Q. What will be the material used at Allens 1 18 Creek? 19 A. Specifically as I said previously, 1 20 don't know. 21 Q. Then how can you make any statement as i 22 to their similarities? 23 A. Because of the reasons I gave you 24 earlier. 25 Q. You really believe that? r.'. 337 ~1 iWTRRNATIONAL COURT REPORTERS, ING.

346 1 A. Yes. r t S. 2 MR. NEWMAN: Is there a 3 relationship between the rate of flow and 4 intergranular stress corrosion, cracking? I 5 A. I'm not certain there is. 4 1 6 MR-ggwMAN: Are y u asserting that 7 the intergranular stress corrosion cracking at j 8 Dwayne Arnold could occur at the Allens Creek 9 p l a n t? 10 A. It could, yes. i f-f 11 MR. NEhMAN: That's the basis of 12 this contention? i. 13 A. Well, cracking is all I think the AL 14 contention says. Let me see. It it just says f 15 large deep cracks. 16 MR. NEWMAN: What do you mean by 17 that? Your example refers to the intergranular 18 stress corrosion cracking. 19 A. We]l, the example was an example not 2'O meant to include all possibilities. 21 MR. NEWMAN: What, if any other i 22 types of cracking do you postulate 7 23 A. None other at this time. 24 MR. NEWMAN: okay. t 25 Q. (BY MR. BIDDLE): Have you consulted E 338 $I

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..._ ~.- -,-- -J : I ------------~--------~"x 347 0 e %I 1 with any experts on the subject matter of this l ] i 2 contention? I 3 A. No, sir. 4 Q. Do you hold yourself out as an expert on 5 intergranular stress corrosion cracking or the 6 phenomena of water hammer? 7 A. Not at this time. 8 MR. NEWMAN: Can you identify any 9 instance in which there has been a coincidence of [ 10 intergranular stress corrosion cracking and water L 11 hammer, the result of which has been the cracking, e: L 12 breaking of the pipe. 13 A. Not at this time, no. 14 MR. NEWMAN: Again, that's e i 15 something you will inform us of as soon as you're n. 16 able to? / 17 A. Yes, I will. 18 MR. NEWMAN: If there were none ? 19 such, what would the basis of your contention be? s. 20 A. The ACRS concern. = 1 21 MR. NEWMAN: It would not be based T 22 on any imperical data? a, 23 A. That's right. 24 Q. Would feu turn te contention 307 Let's 25 take about a five minute break first. E 339 E i!* T r. n N A T it).'. m s ) e,4 T W r: M a ~e W Y

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