ML20062H609
| ML20062H609 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 07/29/1980 |
| From: | Gunther L, Malec W EBASCO SERVICES, INC. |
| To: | |
| Shared Package | |
| ML19331C559 | List:
|
| References | |
| ISSUANCES-CP, NUDOCS 8008190263 | |
| Download: ML20062H609 (14) | |
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CIITED STATES OF AMERICA NUCLEAR REGULATCRY CCMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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HOUSTON LIGHTING & POWER
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Docket No. 50-466 COMPAW
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(Allens Creek' Nuclear
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Generating Station, Unit
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No. 1)
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3 AFFIDAVIT OF LOUIS A GUNTHER State of New Jersey County of Bergen i
l I, Louis A Gunther, Welding and Materials Engineer, Allens Creek Project, for Ebasco Services Incorporated. of lawful age, being first duly sworn, upon my oath certify that I have reviewed and as thoroughly familiar with the statements contained in the attached affidavit addressing intervenor John F Doherty's Contention 44 regarding IGSCC propagated by water hammer and that all statements contained therein are true and correct to the best of my knowledge and belief.
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7, Subscribed and sworn to before me this.,'
day of._
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,1930.
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l CAROL A. CPITENCK
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?M COWiSSICN EXP!953 SEPT.13. M3}
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 30APO In the Matter of
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HOUSTON LIGHTING & PCWER
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Docket No. 50-466 CcMPANY
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(Allens Creek Nuclear
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Generating Station, Unit
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No. 1)
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AFFIDAVIT OF WATER F MALEC State of New Jersey County of Bergen I, Walter F Malec, Supervising Mechanical Nuclear Engineer, Allens Creek P roj ec t, for Ebasco Services Incorporated, of lawful age, being first duly sworn, upon my oath certify that I have reviewed and as thoroughly familiar with the statements contained in the attached affidavit addressing intervenor John F Doherty's Contention 44 regarding IGSCC propagated by water ha==er and that all statements contained therein are true and correct to the best of my knowledge and belief.
f ATULPdt Subscribed and sworn to before me this
~' day of
,1980.
CARCL A. CPITENCK NCURY PUSUC GF '4W 'F.aggy MY COWFWCN D.?' PES 3EPT.12,1333 341
4 UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSICN BEFORE THE ATOMIC SAFETY AND LICENSIh3 BOARD In the Matter of S
S i
HOUSTON LIGHTING & POWER S
COMPANY S
Docket No. 50-466 5
(Allens Creek Nuclear S
Generating Station, Unit S
No. 1)
S AFFIDAVIT ADDRESSING JOHN F.
DOHERTY'S CONTENTION NO. 44 CN INTERGRANULAR STRESS CORROSION CRAC4ING AND WATER HA>DIER My name is Louis A.
Gunther.
My business address is Two World Trade Center, New York, N. Y.
I am the Welding and Materials Engineer for the Allens Creek Project employed by Ebasco Services Incorporated.
The statement of my background and qualifications is attached as Exhibit I to this test.mt3y.
My name is Walter F.
Malec.
My business address is 160 Chubb Avenue, Lyndhurst, N. J.
I am the Supervising i
Mechanical Nuclear Engineer for the Allens Creek Project employed by Ebasco Services Incorporated.
The statement of my
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l background and qualifications is attached as Exhibit II to this testimony.
This affidavit addresses the facts raised in Doherty's Contention No. 44 which states that the ACNGS piping in the feedwater, steam supply, residual heat removal, ICCS, containment
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'1 spray and service water systems are not adequately designed to prevent propagation of intergranular stress corrosion cracks f
(IGSCC) by water hammer forces.
A list of these systems describing their function and materials is furnished below:
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A.
Feedwater System - This system returns the condensed reactor steam to the reactor vessel through six 12-inch lines.
3 The lines are made of carbon steel, A106, Grade "B".
B.
Main Steam System - This system transports the reactor 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 long-term reactor cooling after the reactor has been depressurized.
The Low Pressure Core Injection portion l
of the RHR System and the Low Pressure Core Spray System comprise the low pressure systems c f the Emergency Core Cooling System.
I The EHR system also contains the Containment spray System.
Piping for the RHR system is made of carbon steel, A106, Grade "B"/A155, KCF70 and stainless steel, A312 Grade Typ. 304.-1/
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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 =casure.
This piping is open-ended and not subject to the same stress levels as in the pressurized piping in which IGSCC has been observed. 343
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b-D.
High Pressure Core Spray - This Emergency Core Cooling System provides a large source of high-pressure cooling e
water to maintain reactor water level.
Piping for this system is made of carbon steel, A106, Grade "B"/and stainless steel, A312, Grade Typ. 304.
E.
Essential Services Cooling Water System - This' L
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system provides secondary side cooling water to the RHR system, the HPCS, essential HVAC, and Fuel Pool Cooling and Cleanup f
System.
Piping in this system is made of carbon steel, A106, Grade "B".
As covered in the affidavit of Dr. Gerald M.
- Gordon, carbon steel such as the steel used in the ACNGS is not susceptible t
to IGSCC.
Hence, ACNGS will be designed to preclude cracks caused y
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by IGSCC.
This eliminates from consideration intergranular i
stress corrosion cracking of all the systems identified by Mr.
Doherty.
Moreover, even disregarding the measures instituted for preventing cracks, the suggested water hammer force for propagating these nonexistent cracks has been minimised and l
the unavoidable reduced effects accounted for-in all the referenced systems.
Water hammer occurs when forces are imparted to piping from the acceleration of-contained fluids.
ACNGS utilises standard industry practice in designing for water hammer Ga.g., WHAM code, valve design parameters, vent and drainage provisions, administrative controls, fill provisions, ~
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etc.).
Additionally, applicable guidance will be incorporated i
into the fluid system designs as it beccmes available (e.g.,
portions of NUREG-0582).
The NRC Staff, in NUREG-0582,
" Water.*ammer in Nuclear Power Plants," has reviewed water hammer events in light-water reactor fluid systems and has
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classified water hammer problems under nine separate categories.
This NUREG is the first of several reports scheduled to be j
i issued by the NRC in seeking generic resolution of Task Action
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i Plan A-1,
" Water Hammer."
NUREG-0582 is not a final design i
b guidance document and, in fact, the Staff has indicated in several instances that no remedial action is required for I
operating plants at present due either to the limited numbe-of damaging events reported or the acceptable nature of design l
solutions incorporated in operating plant systems.
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The ACNGS fluid systems are designed to eliminate water hammer wherever possible.
Systems having a potential for l
t water hammer will be designed to accommodate the associated
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loadings.
Examples of these commitments, which address various aspects of problems identified in NUREG-0582, are as follows:
i a.
The ECC and RCIC systems utilize water leg seal pumps as detailed in PSAR Section 6.3.2.2.5.
The use of I
the discharge line fill system, administrative controls, filling and venting procedures and the proper location o#
1 vents should effectively eliminate water hammer due to pump startup with discharge lines containing voids.
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b.
ACNGS systems are designed to withstand the j
1 dynamic loads arising from the expected transient flow into empty or partially empty lines.
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c.
Valve operating times (open to close, close to i
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open) will be provided for all active valves.
This data j
will be used to ascertain if any water hammer is possible.
If it is determined that water hammer can occur, the piping will be designed to accommodate these loadings.
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Control valves will be sized such that'they will be stable through their entire control range.
This subsequently will avoid water hammer phenomena as a result of control valve instability.
Check valves in which pipe ruptures are postulated e.
upstream of the valve, and the associated piping, will be designed to accommodate the loadings resulting from valve closure.
For the case of flowing lines, check valves will be designed to assure that the valve obturator will remain in a stable condition such that oscillation or intermittent opening and closing will not occur.
Check valves, other than tilting disc check valves, will either be installed in horizontal pipe runs or in vertical runs where flow is upward.
Tilting disc check valves will be installed in horizontal lines only.
Active check valves will be periodically tested in accordance with ASME 348
r Boiler and Pressure vessel Code to assure that they will not stick in the closed or open position (as applicable to safety function).
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The ACNGS has incorporated the traditional
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design approach for preventing water entrainments or
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carry-over (and/or condensation) in steam lines.
The l
basic design mechanisms to pre. vent 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) l where water can accumulate.
This drainage feature incorporates j
steam traps / automatic level control valve stations, which operate on receipt of level signal from drain pots located upstream of the level control valves.
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In addition to the above, ACNGS design also includes vacuum breaker valves in lines that exhaust i
steam below suppression pool water level.
This will j
prevent water being drawn up into the lines due to development of low pressure in the line following staum condensation.
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All " solid water" piping systems will have l
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strict administrative controls to satisfy the requirements of venting, and filling and venting.
Hence, all pumping systems 3111 be normally started against filled lines 347.
which will not lead to significant dynamic loads.
- Moreover, i
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 system.
The Applicant is aware of these potential problems and has taken engineering steps to assure that they will not adversely affect plant safecy.
Consequently, there is virtually no possibility that propagation of intergranular stress corrosion cracks due to water hammer forces will occur. Cb18
EXHIBIT I Paga 1 of 3 RESDIE - LOUIS A GU;iTHER e
t Senior Engineer - Materials Applications
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SC2'JLPI 0F. EZ?ERIENCE (Sinca 1968) i Total Experience - More than 12 years engineering experience in =ecal-lurgical and welding engineerl.ng in the areas of welding design and caterial selection, pressure vessel fabrication and advanced welding process developcent foz utility, naval nuclear, deep sea submergence 3
4 and aerospace projects-
?:ofessional Affiliations - ?:ofessional Engineer in the Sta::a of New York.
Patents - Method of TeIding a Tube to a Tube Sheet:, Patent No. 3,324,663.
Honore and Awards - Tc= 3 eta 21 Noah A Kahn Memorial Award - AST>i s
?:ofessional Society Me=berships - A=crican Society for Metal American Welding Society Welding Research Council Education - 3S MetaP gical Engineering (=agna ce= laude)
?olytechniclnstitute of Brooklyn - 1968 j
MS Metalb gy - New $ork University 1970 2
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M3A Manage =ent Systems - New York University 1975 Speciali::ed Training - Co=pleted the following courses:
(a)
TT-4 Practical Nuclea: Power Plant Technology
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Coursa/ sponsored by Ebasco-1977.
(b) B6W Basic Stea= Generating Technology Course /
sponsored by Ebasco-1976.
(c)
GE-3WR Course / sponsored by Ebasco-1975.
(d)
Titaniu:2 and I::s Alloys / sponsored by the A=erican Society for Metals-1968.
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q LOUIS *A cli:trHER RErRESE TrATIVE E3ASCO PROJECT EX?ERIENCE (As Senior Engineer)
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Nuclear Louisiana Power & Light Co=pany Waterford Unit 3 Houston Lighting & Powe: Co=pany Allens Creek Unic 1 Fossil New York State Electric & Gas Co=pany
,Ho=er City Unic 3 f
Pennsylvania Elect:te C6=pany Iowa Public Servica Cc=pany Neal Unit 4 Public Service Co=pacy_of_ Colorado-Patroce Unit 1 i
Houston. Lighting & Power Co=pany Li=estone' Units 1 and 2
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E3ASCO EXPERIENCE (Since 1974) i i
Senior Engineer - (6 years), New York Office Responsible for all =ac e:s concerning New York Office velding fabrication j
and,=atarials seleccion.during design and construction phases on assigned projects and for providing. tech =ical support 'for project site ' support engineers. Assigned l
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.to specia.l.o. rojects.- fo.r-de.velop=ent of auto =atic ff.xed.. position pipe-welding i
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PRIOR EXPERIENCE (6 Years)
Curtiss Wright Corporation Wood-Ridge, New Jersey Senior Engineer (3 years)
Assigned to the Welding Technology Depart =ent, Nucliar Division.
Responsible for develep=ent, !=ple=entation and survelliance of speciali. zed welding proceduras e= ployed in the manufacture of Naval Nuclear Co=ponents to NAVSHI?S-250 -1500-1 requirements. These procedures included specialized seal velding, auta=atic tube-to-tube sheet velding, and auto =atic orbital pipe velding processes. Additional responsibilities included cetallurgical studies for development projects and production support, =anpower and schedule esti=at'ng for new welding projects, capital equip =ent selection, and vendor auditjng.
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l RESDS - LOUIS A GISTdER PRIOR EXPERIENCE (6 Years) (Continued)
Curtiss Wright Corporacica Wood Ridge, New h_:sey Engineer (2 years)
Assip.ed to the ?rocess Metallurgy Depart =ent, Aerospace Division.
Responsible for develop =ent projects concerned with repair welding and heat ::ca :en: of turbine blades, plasca are welding, inertia welding, and p:nduc: ion welding of C6AC steel asse=blies fo: the G t-na 711
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U S Naval Applied Science Laboratorv.
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New York, New York Physical Metallurgis n (1. year)
Assigned to the '~'-*- Developcent ?:ogra=, responsible for car ying out welding develop =ent studies and welder ::aining programs on heavy section titaniu= allcys 1.= support of U S Navy deep sub=c:gence vehicle progra=s.
Ebasco Se: vices Inco:pon2:ad Materials Labora: cry Technicia.. (Su==e: E play =ent)
Pasponsible for spad preparation, retallographic work on failure f
analyses, and braning and =achining operations perforced during laboratory studies fan the power indust:y.
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WALTER F MALEC Supervising Engineer E B 15 C 0 SCR V ICP*S EXHIBIT II 4 Years With E2ASCJ
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Born Philadelphia, Pennsylvania Education Polytechnic Institute of Technology, degree of Engineer in Nuclear Engineering - 1978 Massachusetts Institute of Technology, >$ in Nuclear Engineering - 1970 U.S. Coast Guard Academy, 33 - 196S 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:en t :
Houston Lighting & Power Co - Allens Creek NGS - Unit No. 1-1200 Z;(e) B"R Technical and adninistrative responsibility for techanicaj.,
fire protection, plumbing, HVAC, stress analysis, hangers and supports, and inservice inspection activities.
Includes schedules, budgets, and client relations.
1978-1980 Ebasco Services Incorporated, Lyndhurst ("J) Office; Principal Engineer, Mechanical-Nuclear Engineering Department Houston Lighting & Power Co - Allens Creek NGS - Unit No. 1-1200 }M(c) EWR, Lead NSSS Engineer Responsible for preparation and maintenance of ECCS and 30P flow diagrams, piping layouts, system design descriptions, inservice inspection provisions, Nuclear Island building general arrangements, PSnR and FSAR preparation, ecuipment sicing and specification, NSSS vendor interf ace f or corre-spondence, drawing review, and contract administration.
12,5-1973 Ebasco Services Incorporated, New York office; Senior Engineer, Mechanical "uclear Engineering Department including:
H' uston Lighting & Power Co - Allens Creek NGS - Unit No. 1-o I200 M1(e) 3"R, Lead NSSS Engineer Louisiana Power & Light Co - Waterford SES Unit No. 3-1165 MW(e) PWR. Lead NSSS Engineer (Same responsibilities as listed for 19 78-19 30 above.)
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EBASCO SERYlCES 8 4C6aPG A LTE 3 1976-1973 Responsible for preparation and caintenance of ECCS and (Cont'd)
BOP flow diagrams, piping layouts, systen design descrip-tions, inservice inspection provisions,' Nuclear Island building general arrange cats, PSAR and FSAR preparation, equipment sizing and specification, SSSS vendor interface for correspondence, drawing review, and contract adainis-tration.
P 1974-1976 United States Coast Guard, >Srine Inspection Office, New York; Lieutenant - Supervisory Boil,er Inspector.
Responsibility for supervision, assignment and training of Marine Inspectors in largest Marine Inspection Of fice 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 Code, ANSI, TEMA, SEC 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, caintenance 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 Coast Guard Achievement Medal for superior perfor=ance of duty.
1970-1973 United States Coast Guard, 1 brine Inspection Office, New York, Lt and Ltjg - } arine Inspector.
Inspection of hull and nachinery of U.S. and foreign flag merchant vesscis.
1968-1969 United States Coast Guard, USCCC Mellon (WHEC-717), Ensign, Assistant Engineer Officer,
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