ML20070N088

Statement of Suffolk County Re Sensitization of Reactor Internals Matl Issue - Halapatz Concerns.Proposed Contention Provided

ML20070N088
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/21/1983
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:
Shared Package
ML20070N090	List: ML20070N088
References
ISSUANCES-OL, NUDOCS 8301250417
Download: ML20070N088 (7)

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.. J.pnuary 21, 1983 UNITED STATES OF AMERICA "

NUCLEAR REGULATORY COMMISSION

• 00CHETED l1 UStiRC 3efore the Atomic Safety and Licensing Board

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In the Matter of ) '

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LONG ISLAND LIGHTING. COMPANY ) a

) . Docket No. 50-372 0.L. *

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(Shoreham Nuclear Power Station,- )

Unit 1) )

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' Statement of'Suffolk County Concerning Sensitization of Reactor Internals Halapatz Concerns -

Materials Issue The current status of the parties' attempts to resolve -

the issue initially raised in the Differing Professional Opinion .

(DPO) of NRC Staff member Halapatz is set forth below. .

BACKGROUND Board Notification 82-70, dated July 20, 1982, was issued to disclose certain "new 'nformation relevant and material to f safety issues." (A. copy of Board? Notification 82-70 is Attach-l j

ment 1 hereto). It sets forth the existence of a DPO concerning the adequacy of welding procedures used during the f abrication of SWR. reactor' vessel internals. It revealed that in fabrica-l ting such components, General Electric (and/or i'ts subcontrac-i l .

tor s) had used weld'ing procedures that permitted heat input -

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. levels that could cause " sensitization" of heat affected zones o'f type 304 stainless steel, in violation of Regulatory Guide l.44. Ihe intsnt add purpes,e cf that Guide is to ensure the 1cw prehability o'f intergran'ular stress corrosion cracking.("IGSCC") .

8301250417 830121 S PDR ADOCK 05000322 O PDR {})

One of the thre,e factors necessary to produce IGSCC is Accordingly, prevention of seDsi, sensitization of materials.

tization is clearly desirable. See Attachment 1. -

The Board Notification was issued subsequent to the filing of testimony by the parties on Suffolk County Contention 24.

One focus of that Contention is on the need to prevent IGSCC.

Board Notification 82-70 disclosed new.information that was not known to Suffolk County prior to the preparation of testimony. ,

The parties attempted to r.each an agreement on the resolution

. of the concerns rai' sed in the/DFO'duqing settlement discussions relating to SC.C6ntention 24. However, they were unable to do so within the time frame set for.' resolution of the remainder .

of that contention. The Resolution of SC Contention 24/ SOC i

Contentions 19 (c) and (d) -- Cracking of Materials and Material Selection, sets forth the parties' agreement with respe'ct to -

continued attempts at resolution of the Halapatz concerns, and eventual-litigation should such attempts fail. The Agreement was .

l submi't ted to .the Board on December 1,1982. A copy is Attachment 2 hereto.

On November 16, 1982 a mee' ting was held to' discuss the l

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concerns raised in the Halapatz DPO. The meeting was attended by representa'tives of General Electric, LILCO, theStaff,dnd -

Suffolk County. ,'During tha't meeting, the possibility'of resolving the DPO and the related Suffolk County, concerns,. by implementing at Shoreham an in-service inspectied program similar to that propcsed for the Monticello plant,was discussed. Following consideration of ihe matter by the S aff, its propose'd5 resolution of the DPO was set forth in a December 2 8, 1982, memorandum from

Richard H. Vollmer to ' Joseph Halapatz, a copy of which was

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served on the Board,and parties on December 30, 1982. The Vollmer Memorandum indicates that implementation of a Monticeflo-.

type .inspec~ tion program is' 'decessary and will be required for Shoreham and other plants under licensing review. Later ..

developments, however, indicate that such a program may not be required for Shoreham. ,,

4 Following receipt of the Vollmer Memorandum, the County ,

sent a letter to Staff counsel setting forth several specific

. questions concerning implemehtation of the Staff position with .:

respect to Shoreham. See Status Report on Halapatz Conegrns, filed by the County on January 7, 1983. Based on discussions .

that have taken place since that time, it appears that th'e ,

Staff is not yet prepared to state with certainty its position.

Thus, the Staff has indicated that it is unlikely that the Monticelio-type in-service inspection requirement will be im-

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- plemented at Shoreham as a license co'ndition. The Staff -

further indicates that the Director of NRR has not concurred -

in the DPO resolution. Assuming that Mr. Denton does concur',

1 it is th= County's understanding that the. Staff would then submit the resolution to the generic review committee for infor . .

mation. Following that, the Staff-would issue an' internal letter to the I&E regional offices setting forth the NRC position .

that Monticello-type inspections are necessary. It is~not clear, hclever, that this internal letter wculd require that any action be 7ks. to assyr.e that such inspections are being performed. ,

It is clear th&t the first step of a decision process has "as- cirf erred by the ':RC; hcwever, thers is no present assurance

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'that the process will bs completed o.r the issue satisfactorily resolved at Shoreham. At the present time, LILCO is under no obligation to make a commitment to perform the type of inspection ,

thathasbeendiscubs'ed,althoughLILCOrepresentativeshsve .,,

indicated that LILCO might do.so in order to resolve this issue without litigation.

In order to preserve its rights, given the current situa-tion and the Board's requirement that the County. state today its.. position in this issue, County herEby states its intention t

to litigate the concerns raised in the Halapatz DPO. The County notes, howeve.r, that this issue can be resolved if:

. (1) LILCO commits to implement a Monticello-type inspection program covering the scope of components described in'the Perry FSAR; and (2) the NRC Staff agrees to monitor LILCO's compliance with this commitment as part of its I&E inspection program. ,.

The County believes the issue raised in the DPO is'within the scope'of SC Contention.24. That contention focuses on the adequacy of material selection and control at Shoreham, and .

compliance with GDC.4, 14, 30, and 31 of.10 C.F.R. Part 50, l

Appendix A. As the parties' pre' filed testimony on that contep-tion indicates, one of the major concerns was whether proper l techniques had.been used to avoid sensitization of 304.stai'n-  :

i less steel materials. Th'e ' Resolution Agreement similarly indi-cates the importance of that question to the concerns at issue. .

Admittedly, the term " reactor internal compo'nents" does not appear in SC 24 as it now ex'ists. In fact, however, the L* 'criginal County c5ntention frca which SC 24 evolved,:(Conten-tien 13(a) - Sucl' ear System Material Failures) specifically included an allegation that material selection and control was ci:? respec: te :"e

se of stainless materials in

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reactor internals." .During discussions that procaded the March 8, 19,82 prehearing conference,.LILCO assured the County that no sensitized materials were used in the reactor internals because all ma.terials had been heat-treated and furnace annealing was prohibited by General Electric specifications. Accordingl ;,

based on those assurances the County agreed to narrow the

. original contention to exclude a specific reference to reactor ,

internals. -

Upon issuance of Board Notification 82-70, it became apparent ,

O that LILCO's use of heat treatment and the existence of specifi- [

cations did' not eliminate the potential sensitization problem.

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As Mr. Halapatz pointed out, the, sensitization occurred during ,

the fabricati,on process, prior to the components' reaching LILCO. The disclosure of this newly discovered information clearly brought the issue of sensitization of reactor internals back into prominent focus. Its significance is evidenced by the Staff's proposed resolution of the.DPO. The County submits ,

that .the issues raised by the Halapatz DPO are within the scope of SC Contention 24, and can be, properly and conveniently lit,i-gated within that framework.

Should the Board find otherwise, the County submits, in

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the alternative, that this matter is the pr'oper subject of a .

new contention. It clearly involves newly discovered information that was not known to the County or, apparently,'to the other parties, at the time the or.iginal.Suffolk Ccunty cohtentions

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we're admitted by the Board.' In addi:icn, the concern is a significant cnefre'cau)e the p.otentially sensitized components -

may include feedwater spargers, core spray spargers, the steam

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6 dryer, the shroud head and separator. assembly, jet pumps, upper core support grid, lower core support grid, shroud support, (

. control guide tube, and control rod housings. Many of these }

components have crac ed in service, and there is a strong .

possibility that such failures could have an adverse impact on the safety of the Shoreham plant. Broken ccmponent parts could interfere with the flow and distribEtion of cooling water. Loose

. parts could also damage fuel rods, interfere with the' operation of contro'l rods and, in extreme cases, penetrate the reactor coolant pressure boundary through wear or internal damage.

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o Because the. ..

issue arises from new information and has

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substantial safety significance,.3uffolk County submids~it is the proper subject of litigation.

The new contention proposed by Suffolk County, whose bases and details are described in the foregoing discussion, a is as fol, lows:

c Reactor Internal's Material Sensitization .

Suffolk County contends that the Applicant has not adeouately demonstrated that the Shoreham plant meets the requirement of 10 CFR Part 50, Appen-dix A, Criteria 14, 30, and 31 with regard to adequacy -

of material selection and control used in the design and fabrication of reactor internals, including but not limi.ted to: core spray lines, feedwater'spargers,;

l dryer support pads, LPCI connectors, fuel assembly.

tcp guide, jet pump components, shroud head assembly, shroud, shroud support plate, surveillance sample, core plate hold ldown bolts, steam separator, steam fdryer, CRD housings, shroud support legs, internal core instrumentation piping, in-core housing, Suffolk C' punty CRD further guide tubes and fuel support's.

-contends that the NRC Staffchas net required that appropriate attention be given to the inspection cf these critical components to assure their integrity Suffolk County during the c'perating life of the plant.

ntends that.LILCO must commit to implement an i'nspection ,

program similar to that in place at the Monticello Nuclear F' ant with respect to components identified in the Perry F E AF. in crdc-r to compensa e fcr the defic enc es alleged i i 4 ,1 W$* p l

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Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway taup uge,,New Yory 11788 .,

7 W e ' Max -

LgwrFnce C. Lanph .

Karla J. Letsche ,

KIRKPATRICK, LOC HART.,. HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N. W. , ,

Washington, D. C. 20036 Attorneys for Suffolk County January 21, 1983 -

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AUG 161982 e

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g UNITED STATES  ;

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WASHINGTON, D. C. 20555 k . . . ,./

July 20,1982

• Docket lbs.: 50-322 50-341 50-358 50-466 50-522/523 MEMORANDUM FOR: The ' Atomic Safety & Licensing Boards for:

Shoreham Nuclear Power Station, Unit 1 Enrico Fermi Atomic P6wer Plant, Unit 2 William H. Zimmer Nuclear Power Station, Unit 1

" Allens Creek Hucle'ar Generat'ing Station Unit 1 Skagit/Hanford Project, Units 1 and 2 FROM: R. L. Tedesco, Assistant Director for Licensing, DL

SUBJECT:

BOARD NOTIFICATION - DIFFERING PROFESSIONAL OPINION ~'

RELATED TO SENSITIZATION OF BWR STAINLESS STEEL -

WELDMENTS (B0ARD NOTIFICATION 82-70)

In accordance with present NRC procedures regarding Board notifications, the enclosed information is being provided for your information as constituting new information relevant and material to safety issues.

This informat' ion is generic and has applicability to all dockets with boiling water reactors.

The s'taff is currently in the process of trying to satisfactorily resolve a differing professio.nal opinion (DPO) that relates to the adequacy of welding procedures used during fabrication of BWR reactorc vessel internals.

Specifically, General Electric (and/or their subcontractors) have used welding procedures that permitted heat input levels that could cause sensitization of heat affected zones of type 304 stainicss steel. The : ,

term " sensitization" is used here to mean that the welded joint would n6t

. pass specified' ASTM tests, and th,erefore, would not be in conformance with specific regulatory positions of Regulatory Guide 1.44.

The intent and purpose o.f Reg. Guide 1.44 is. to' ensure that the probability ,

of deleterious i'ntergranular stress corrosion cracking is low. Because

sensitization is one of the three factors (high stress, corrosive environment, and sensitization) that must all be prisent to cause int,ergranular stress corrosion cracking, it is clearly desirable to use welding procedures and

Contact:

J. Kerrigan, ONRR X29788 a,or 4M FOMRrf- ,

ATTACHMENT 1

-2 July 20, 1982 other process controls to prevent it'. Nevertheless, the staff also ..

believes that even with stringent process specifications, sensitization may not be precluded. Therefore, in addition to evaluating the possibility of sensitization, the staff also considers the probable level of the other two necessary factors for cracking-stress level and environment '

corrosiveness. Whi.le the aggressiveness of BWR water chemistry on sensi-tized austenitic stainless steel is still the subject of NRC s.tudy, the -

staff's past position has been that both of these factors are' relatively low at the heat affected areas of welds in BWR internals. Given the ,

limitations of inservice inspection presently invoked for reactor internals, it is not possible to preclude the existence of cracking; however, the staff's judgment at this time is that the probability. of cracking of reactor internals leading to a significant failure is low. The one' possible exception to this,is the recc.it cracking found in core spray -

spargers and related internal piping. Cracks have been found in Oys-ter Creek, Peach Bottom 1, Brunswick 1, and possibly in Pilgrim 1. The staff has determined that the cracking in the affected components does not constitute a se'rious safety concern. ./

It is the belief of the party offering this DP0 that a review of welding pr'ocedures currently used in BWR fabrication and inservice inspection procedures usec' at currently operating plants, would demonstrate the.

need for specific inservice inspection of vessel internals. It is also this person's belief that it is not an issue involving an imediate safety concern, but one which needs resolution to assure long-term integrity of

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sensitized BWR components.

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Attached are ir.ternal NRC metroranda which discuss the subject DPO. We

! will continue to actively pursue this matter and notify you of final resolution.

.O E:f -% w ,a Robert L. Tedesco, Assistant Director for Licensing Division of Licensing ,

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Attachments:

• j As stated i

cci Board Service List l

DISTRIBUTION OF BOARD NOTIFICATION .

I AilensCreekUnit1/ALAB Fermi 2/ASLB Zimmer Unit 1/ALAB Docket t'o. 50-456 Docket No. 50-341 Docket No. 50-358 Dr. John H. Buck Gary L. Milho11in, Esq. John H. Frye III, Esq.

Dr. E. Leonard Cheatum Dr. Peter A. Morris Dr. Frank F. Hooper

• Christine N. Kohl, Esq. Dr. David R. Schink Dr. M.. Stanley Livingston Mr. G'ustave A. Linenberger Dr. Lawrence R. Quarles Alan S. Rosen. thal, Esq. Mr. David E. Howell

'Sheldon J. Wolfe, Esq. Peter A. Marquardt, Esq. Lynne Bernabei, Esq.

. Harry Voigt, Esq. Brian Cassidy, Esq.

Bryan L. Baker Troy B.' Conner, Esq.

Ms. Margaret Bishop -

Andrew B. Dennison, Esq.

Ms. Carolina Conn Skagit/Hanford Units 1&.2/COMM Lawrence R. Fisse, Esq.

J... Gregory Copeland . Esq. Docket No. STN 50-522/S23 W. Peter Heile, Esq.

Stephen A. Doggett, Esq. David Martin, Esq. -

~Mr. John F. Doherty -

Dr. John H. Buck William J. Moran, Esq.

Ms. Robin Griffith Mr. Samuel J. Chilk Mr. Samuel H. Porter Carro Hinderstein Dr.FrankF. Hoofer Deborah Webb, Esq.  ;

Ms. Rosemary N. Lemmer Mr. Gustave A. Linenberger John D. Woliver, Esq.

D. Marrack Alan S. Rosenthal, Esq.

Ms. Brenda A. McCorkle John F. Wolf, Esq. Atomic Safety and Licensing '

Hon. John R. Mikeska Board Panel Jack Newman, Esq. Richard D. Bach, Esq. Atomic Safety'and Li. censing Mr. William Perrenod Ralph Cavanagh, Esq. '

Appeal Panel -

Susan Plettman, Esq. Coalition for Safe Power Docketing and Service Section Region IV, ISE James W..Durham,'Esq. Document Management Branch Mr. Wayne Rentfro Warren Hastings, Esq.

Mr. William J. Schuessler James B. Hovis, Esq.

James Scott, Jr. , Esq. Mr. Nicholas D. Lewis .

Hon. Jerry Sliva Robert Lowenstein, Esq.

Mr. Lloyd K. Marbet .

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Frank W. Ostrand'er, Jr. , Esq. _ACRS Members -

Shoreham 1/ASLB Kevin M. Ryan, Esq.

Docket Nos. 50-322 OL Mr. Terence L. Thatcher Dr. Robert C. Axtmann F. Theodore Thomsen, Esq. Mr. Myer Ber. der.

Lawrence Brenner, Esq. Mr. Timothy Wapato Dr. Max W. Carb'n o '.

Dr. Jame's L. Carpenter Mr. Jesse:C. Ebersole '

, Dr. Peter A. Morris ,

Mr. Ha rold Etherington

,- Dr. William Kerr Edward M. Barrett, Esq. Dr. Harold W. Lewis

' Howard L. Blau, Esq. Dr. J. Carson Mark -

Herbert H. Brown, Esq. Mr. William M. Mathis Hen.' Peter Cohalan Dr.' Dade W. Moeller '

Mr. Jay Dunkleberger 'Dr. David Okrent David H. Gilr:artin, Esq. Dr. Milton S. Plesset Mr. Marc W. Goldsmith ,' Mr. Jeremiah J. Ray Matthew J. Kelly, Esq. -

Dr. Paul G. Shewmon Stephen B. Latham, Esq. Dr. Chester P. Siess MHB Technical Associates Mr. David A. Ward

'.r. Erian ".cCaffrey

... Taylor Re'.eley III, Esq.

Raich Er,apiro, Esq.

P ' Ir;*h

II 36 82-1

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UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION .,

Before the Atomic Safety and Licensing Board '

In'the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

) .-

(Shoreham Nuclear Power. Station, )

Unit 1) ,

RESOLUTION OF ~

SC CONTENTION 24/ SOC CONTENTIONS 19(c) and (d)

CRACKING OF MATERIALS AND MATERIAL SELECTION Suffolk County ("SC") Contention 24 and Shoreham Opponents Coalition.(" SOC") Contentions 19(c) and (d) allegethahLILCO '

has not taken adequate care in the selection and control of ma-terials used in the construction of safety-related systems and components exposed to the reactor coolant environment. Because of this situation, SC and SOC believe that there is an in-creased risk of accidents at Shoreham and.~that increased worker ,

exposure.to radiation is likely.

The parties have discussed these issues and have agreed .

that with the exception of the area of concern des'cribed in Item 1 below, the SC and SOC concerns can be resolved, provided e that the terms. , conditions and actions described in Items 2-9 B301250420 830121 ATTACHMENT 2 PDR ADOCK 05000322 O PDR