ML20072H572

Affidavit of SL Hiatt That Ohio Citizens for Responsible Energy Cannot Currently Present Facts to Justify Opposition to NRC Motion for Summary Disposition of Issue 13 Since Info Still Being Reviewed.Certificate of Svc Encl

ML20072H572
Person / Time
Site:	Perry
Issue date:	06/23/1983
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
Shared Package
ML20072H561	List: ML20072H559 ML20072H572
References
NUDOCS 8306290549
Download: ML20072H572 (16)

Text

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AFFIDAVIT I, Susan L. Hiatt, OCRE Representative, duly sworn depose and say that:

A. the statements below.are true to the-best of.my knowledge and belief; and B. Ohio Citizens for Responsible Energy cannot present at this time facts essential to justify its opposition to the Staff's Motion for Summary Disposition.of Issue #13 for the following reasons:

1. OCRE would like to present a direct case on this issue, and is actively pursuing'the acquisition of expert consultants and witnesses in evaluating this complex technical issue;

2. OCRE has only recently received documents requested from Applicants and the NRC, specifically:

(a) documents requested on April 5, 1983 from the NRC's Public Document Room were received on or about May 20, 1983; (b) documents requested from Applicants on April 21, 1983 were received on or about May 26, 1983; (c) both classes of documents above pertain directly to Issue #13;

3. OCRE has had insufficient time to thoroughly review and evaluate these extensive documents because of the recent hearing on quality assurance and because of the time necessary to prepare the proposed . findings related thereto;

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OCRE believes that further discovery will be necessary on this issue, both as follow-up on said documents and to properly prepare its case, especially in light of the Board's statements in the recent^ hearing.that (much to'OCRE.'s astonishment) what was considered cross-examination 1by intervenors was in fact discovery; 5.

As. stated in the preceding brief, OCRE believes that in the interest of developing.a full and complete record, the litigation of Issue #13.should await further data, evidence, and information, including.the submittal of a report by General Electric; 6.

OCRE believes that any delay caused thereby will not prejudice any party and is far outweighed by the benefit of having a complete record in this proceeding; 7.

OCRE further believes that both justice 'and Commission precedent demand that intervenors be given the time needed to properly prepare their case on Issue #13; specifically, the Appeal Board in Southern California Edison.Co. (San Onofre Nuclear Generating Station) ,

ALAB-212, 7 AEC 986, 992-93 (1974) . held that in view .

of the disparity of resources between Staff and Applicant on one hand, and intervenors, on the other, it is ~ proper to allow intervenors additional time for case preparation.

This is not controverted by the Commission's policy 1

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statement, CLI-81-8, 13 NRC 452 (1981), since the Commission continually iterates therein that its pro- =

ceedings are to be conducted in a fair and thorough manner.  ;

-iii-Susan L. Hiatt OCRE Representative nl~

Sworn to and subscribed before me this 8 day of June, 1983.

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- OtNearly all of the turbine generators produced to date by the Large Steam Turbine-Generator Department l . of General Electric for use with nuclear reactor cycles, are tandem compound machines with rotationaP

' L > ' [ speeds of 1500 or 1800 rpm. De cross-section of a typical GE nuclear turbine generatoris shown in Figure 1.

1e 1, he unit shown is a six-flow design, having three low pressure sections. For some applications a four-flow "Ty %, design has been applied, having two low pressure sections. The high pressure turbine rotoris machined from

- J an integral forging and a composite construction is used in the low pressure turbine rotors.

'~q. . ' , Figure 2 is a cross-section of a typical nuclear turbine low pressure section. Le last stage buckets may E have active lengths of either 38" or 43~ at 1800 rpm. Note that in the General Electnc' ,impulse design Wh, i each wheel carries only a single stage. No multiple stage wheels are employed. The wheels are shrunk on to a

_ shaft and are keyed to the shaft using the configuration shown in Figure 3. This configuration has been very

, carefully ~ optimized to limit stress levels. Our design employs an axial rectangular keyway to prevent wheel b.. p rotation during severe transient conditions when shrink may be temporarily lost. In addition, we employ a T.' i 'circumferentiallocking ring to inhibit axial movement during these kinds of trarisients. He keyways and

' ~ locking ring grooves have been carefully designed to minimize the resulting stress concentration factors'and

' the designs which we employin nuclear machines are typical of those which have been used successfully for a number of years in fossil applications.

The design of a low pressure turbine is complex and requires the resolution of a number of design factors. It must, of course, be designed for high reliability; however, proper attention must also be given to steam path efficiency. There are a number of design considerations which must,be reconciled before the wheel configuration, the material properties employed, and resulting stress levels can be established. We have endeavored to produce a design which has reasonably low stresses in the buckets, wheels and shafts, which therefore does not require materials of unnecessarily high tensile strength.to achieve adequate design margins.

Fossil low pressure sections having designs similar to those currently used in nuclear turbines have accumulated a large amount of excellent service experience. There are 23li fossil units in service with shrunk-

. on wheels, some of which have been in service more than 30 years. Designs having comparable stress levels, materials and configurations were introduced into double flow fossil low pressure sections in mid 1960's.

In spite of the excellent service experience of our fossil shrunk on construction, we recognized that it would be extremely desirable to be able to inspect the regions of shrunk-on wheels in place (e.g. without having to remove them from the shaft). Herefore, we initiated a program in the early 1970's to develop wheel boresonic test equipment and procedures which would permit the inspection of shrunk-on wheels in situ.

His development program was completed in 1977, after thorough laboratcry evaluations and successful field trials. After we were convinced that we had viable in service wheelinspection equipment and procedures, we issued Technical Information LetteU857 in early 1978, recommending that all nuclear wheels be inspected at approximate six year intervals. Initially, we had very few requests for in service nuclear wheel inspections. However, problems with the shrunk-on' wheels of another vendor's equipment resulted in a fairly large number of inspections, starting in 1980. The results ofinspections conducted through the end of 1980 are shown on Figure 4. Tne sonic indications which had been detected during these inspections were thought not to be stress corrosion cracks; for reasons to be discussed in the following material. At that t;me, we judged that the indications were due to a " water cutting" mechanism involving a combination of corrosion and erosion. Tests conducted late in'1981, howe.ver, showed quite conclusively that some of the larger j

' indications were indeed stress corrosion cracks.

• A summary ofinspections through 1981 is shown on Figure 5. He depth of these more recently obsemed indications, together with fibes optic photographs taken, and the inspection of a wheel removed from service, j have resulted in our current assessment: '

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• Stress Corrosion Cracks Exist

• They are Concentrated in Regions of 5th LP Stage l r

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4 eGrowth Rates are Faster than We had.Previously Assumed

• The Exact Mechanism is Not Understood The subsequent discussion outlines in greater detail the total inspection results, the to them, and the programs that we have in place to resolve this problem. ",

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,. TECHNICAL REPORT ON THE PERRY NUCLEAR POWER PLANT TURBINE

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y U.7,:f3..e g g. MISSILE ISSUE r 3,: , , ,

Introduction '

The' subject issue concerns protecting safety-related structures, systems and components from potential turbine missiles by requirino a maintenance program '

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that will assure high turbine generator system reliability. The placement '

' and orientation of the Perry turbine generators in relation to other plant buildings are unfavorable, placing safety-related equipment in. those buildings

'within the low-trajectory strike zone of potential turbine missiles. In its

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review of the apolicant's (the Cleveland Electric Illuminating Company or CEI) ~

Final Safety Analysis Recort for Perry, the staff found that. the following plant structures are within the potential turbine missile strike zone: the i

control rooms for Units 1 and 2; the cable spreading room; the HVAC equipment i

room; the intemediate fuel handling building; the electrical penetratiens area; and the Unit 1 and 2 reactor buildings. The estimated damage impact l on safety-related equipment within these areas from turbine missiles includes l the potential for rendering the control rooms inoperable, the collapse of N l building structures onto safety-related electrical cables and equiparent, and the possible penetration of containment. Since the applicant could not demonstrate that its plant design and turbine maintenance program were such as to provide the required protection against turbine missiles, the staff considered.this to be an outstanding (unresolved) issue in Section 3.5.1.3 of the Perry SER (NUREG-0887).

• This issue was the subject of discussion during the 267_th meeting of the ACRS Comittee on July 8-10, 1982,. in considering the CEI application for an operating license for ' Perry Unit 1. (Consideration of a license for Unit 2 l

was deferred by the Comittee to a later time closer to the estimated Unit 2

fuel load date). The Comittee expressed dissatisfaction with progress being

! made at that time by the staff on the resolution of this issue during the ,

l meeting, and in the ACRS letter (P. S. Shewmon) to the Chairman, NRC, dated i

July 13, 1982, the Comittee requested that a technical report be providad which discusses and evaluates the problems involved with the turbine missile s l

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issue. This report specifically responds to that request in regard to the Perry plant, and presents the staffs' findings on this issue, which was docu-mented in Supplement Mo. 3 to the Perry SER.

Summary of Staff Evaluation Findinor.

Since issuance of the SER and Supplements 1 and 2 thereto. the staff has completed its review of the turbine missile issue, to the extent possible at this time, and as indicated above, the staff's evaluation findings have been docurented in Supple"ent Ito. 3 to the SER.

I On the basis,of its continuing ~ review, the staff has concluded that the

! probability of unacceptable damage to safety-related structures, systens and j components.due to turbine missiles is acceptabi'y low (i.e. less than 10 7 per

year) provided that the total turbine missile generation probability is such that conformance with the criteria presented in Supplement flo. 3 to the SER is mcintained throu1hout the life of the plant by an acceptable inspection and test procram. In reaching this conclusion, the staff took into consider-ation the unfavorable orientation of the Perry turbine generators.

The turbine generators at Perry were' supplied by General Electric (GE), who is in the process of completing development of methods and technioues required to l, calculate turbine missile generation probabilities. These methods and tech-

, nioues are to relate turbine ma.intenance (procedures as well as inspection and testing intervals) to the probability of generating missiles. GE intends to

! submit reports describing this work to the staff for review and acceptance by June 1983. Following acceptance by the staff, GE will provide the applicant (CEI) with a report describing the results of analyses specific to the Perry turbines, based on. the PRC accepted methods and techniques. The applicant is i

expected to use the GE report to formulate a turbine maintenance program which it will then submit to the staff for approval.

i In regard to turbine generators in general, the staff is not aware of any i

turbine rotor rupture due to crack propagation (i.e., brittle fracture) that occurred within tnree ' years of plant startup. Furthermore, within three years of startup, no cracks have been observed in a GE turbine wheel with depths greater than one-half the critical crack depth calculated for that wheel. For these reasons, the staff is allowing CEI up to three years from initiation of power output to propose a revised turbine systen naintenance program, which

establishes inspection and test procedures and schedules consistent within

{ HRC accepted methods.: and obtain HRC approval of its program. Accordingly, the staff's approval of the CEI turbine system maintenance program will be made a condition in the operating license issued for Unit 1, and until the i program is approved, CEI will be reouired to volumetrically inspect all low oressure turbines and to conduct steam valve maintenance (following initiation of power output) in accordance with the interim procedure for demonstrating compliance with NP.C regulations delineated in Section 3.5.1.3.1.5 of Supplement omez y ........................ . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . - - - . ~ ~ ~ ~ ~ ~ " ~ ~ ~ ~ - " " " " " " " ~ " " " ~ " ~ " " "

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l Ho. 3 to the SER, at the second refuelina outage and every other (alternative) refueling outage thereafter. (See Attachment A for the staff's evaluation inputs incorporated in Supplement No. 3). In a letter dated March 31, 1983, CEI' committed to provide a turbine system maintenance program and perform the turbine inspection and naintenance required by the staff pending IIRC approval of the Perry turbine system maintenance program.

The rationale and review methodology used by the staff in arriving at this finding is summarized in the section which follows.

Summary of Staff Rationale and Review Methodolooy During the past several years the results of turbine inspections at operating nucicar facilities show that cracking to various degrees has occurred at the inner radius of turoine disks, particularly those of Vestinghouse design.

Within this time period, there has actually been a Westinghouse turbine disk failure at one facility owned by the Yankee Atomic Electric Company, Further-more, recent inspections of General Electric turbines have also resulted in the identification of disk keyway cracks. The Division of Engineering staff has been following this development closely and has (as discussed in Attach-ments A and B) set turbine missile generation probability guidelinas for establishing turbine disk inspection frequencies, and guidance for turbine control and overspeed protection systems maintenance and testing to preclude missile oroducing failures. Both Vestinghouse and GE are in the orocess of establishing models and methods for calculating turbine missile generation probabilities for their respective turbine systems.

1 Although it can be argued that large steam turbines and their auxiliaries are

not safety systems as defined by NRC requiations, failures that occur in these

! turbines can produce large, high energy missiles. If a missile were to strik'e any of the' safety-related structures, systems, or conoonents, it could render them unavailable to perfom their safety function. It is the staff's view that sufficiently frecuent turbine testing and inspection are the most effec-tive means of assuring the protection of safety-related structures, systems, and components. Therefore, it is prudent for turbine manufacturers to perform, and for the HRC to review, analyses of turbine reliability, which include knokn and likely mechanisms, expressed as a function of time; i.e., inservice inspection or test intervals.

Ceneral Design Criteria 4. " Environmental and Missile Design Bases," of Appendix A, " General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, " Licensing of Production'and Utilization Facilities," requires, in part, that structures, systems, and components important to safety be appropriately protected against the effects of missiles that might result from equipment failures. Regulatory Guide (RG) 1.115 " Protection Against Low-Trajectory Turbine Missiles," and Standard Review Plan (SPR) Sections 3.1.5.3, " Turbine Missiles",10.2 " Turbine Generator," and 10.2.3 " Turbine Disk Integrity" l contain present NRC cuidelines for evaluating the turbine, analyzing the plant

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J. J. Ray - 4-layout, and minimizing the risk to safety-related structures, systems, and ccmponents due to potential turbine missiles. However, the staff considers that certain aspects of this Guide and these SRP sections are nn longer sttit-able. Therefore, the staff has altered its review procedure accordingly, l

to place emphasis on maintaining the turbine integrity. f l In view of current experience and the safety objectives of the staff ['they have emphasized the turbine missile generation probability (i.e., turbine i system integrity) in its reviews of the turbine missile issue and ' eliminated l

the need for elaborate and somewhat ambiguous analyses of strike and damage i probabilities given an assumed turbine failure rate. Although straightforward in principle, the latter calculations have to be based on detaile.d facility information and assumptions as to missile shape and size, missile energies, l barrier penetration potential and ultimately to the likelihood of striking

!' and damaging a facility safety system. Generally, there are significant differences between licensee's or applicant's submittals and the final evaluation by the staff. Nevertheless, the staff concludes, based on its

, experience, and on simple estimates for a variety of plant layouts, that the strike and damago probability product can be reasonably taken to fall in a characteristic narrow range which is dependent on the gross features of

. turbine generator orientation; (a) for favorably oriented turbine generators P2 P3 tend to lie in the range 10-4 and 10-3 , and (b) for unfavorably oriented turbine generators P2 P3 tend to lie in the range 103 and 10-2 (this estimate is within the range of the staff's strike damage probability j estimate contained in Supplement Ho. 5, Section 10.2, of the SER related to

Perry construction, issued in February 1977). tiore refined analyses or additional calculations for other facilities are unlikely to change this conclusion. Therefore, expensive and time consuming strike probability analyses on the part of applicants / licensees and/or the HRC staff are judged to be unwarranted.

F With regard to Perry, the staff' acknowledges that the orientation of the

[ PHPP turbine generators are unfavorable; i.e., there are safety-related

structures, systems, and components within the low trajectory turbine missile i strike zones, and that the applicant has not followed NRC reconraendations stated in R.G. 1.115. It is the staff's view that as a result of this design choice (with unfavorable turbine generator orientation), the applicant has taken a penalty of about an order of nagnitude in the probability of unacceptable damage to safety-related systems (compared to a design with favorable turbine generator orientation). The staff does not conclude, however, that this design choice is unacceptable. Rather, as stated in Attachment A, the staff concludes that the turbine missile risk for Ferry Nuclear Power Plant Units 1 and 2 is acceptable provided the NRC recommendations described therein and documented

! in SSER Ho. 3 are adopted by the applicant, which the Perry applicant has agreed to comply with in a letter dated March 31, 1983.

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In conclusion, the staff considers certain aspects of the review procedures

! in R.G.1.115 and SRP Sections 3.5.1.3,10.2 and 10.2.3 to be unsuitable for providing assurances of protecting systems important to safety from turbine j missiles. The regulatory emphasis in the past has been on the evaluation of l the probability that nenerated nissiles will strike safety-related systems, j The staff has proposed ta) a new SRP 5ection 3.5.1.3, " Turbine Generator

System Reliability (Turbine Missile Prevention)" (see Attachment C), which shifts the emphasis to the evaluation of the probability of generating missiles,

, and (b) a new supporting R.G.1.115 " Protection Acainst Turbine Missiles" (see

[ Attachment 3). The proposed SRP Section and Regulatory Guide, which are -

) intended to replace the current SRP Sections and Regulatory Guide, will help improve the turbine generator system reliability, reduce considerably the analytical burden placed on licensees / applicants, and at the same time

)._, maintain the high level of protection of public health and safety. The l procedures described in the proposed new SRP Section 3.5.1.3 and R.G.1.115 were applied by the staff in reviewing the Perry FSAR, the results of which

! are discussed in Attachment A and documented in Supplement No. 3 to the Perry SER, issued in April 1983.

This report completes NRR action requested in paragraph 10 (top of page 3) of the ACRS letter to the NRC Chaiman, dated July 13, 1992. The letter to the Chairman was reproduced in its entirety in Appendix G, Supplement No.1 to the Perry SER, issued in August 1982.

Thomas M. Novak, Assistant Director for Licensing Division of Licensing Attachments:

A. Meno to T. A. Novak fm W. V.

Johnston dated 3/29/03 B. Proposed changes to Regulatory Guide 1.115 C. Proposed changes to SRP (NUREG-0800) Section 3.5.1.3 ,

cc w/ attachments:

H. R. Denton D. G. Eisenhut P.. H. Vollmer W. V. Johnston B. D. Liaw J. O. Schiffgens

' J. M. Cutchin IV P. S. Shewmon --

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Task ES 114-4 DRAFT REGULATORY GUIDE At!D VALUE/ IMPACT STATEMENT o,

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Contact:

T. J. Nicholson (301)427-4585 J

GUIDELINES FOR GROUND-WATER MONITORING / 4d AT IN SITU URANIUM SOLUTION MINES A. INTRODUCTION An applicant for a new license or renewal of an existing /,rl se to receive, e olut Wn A mining

. possess, and use source material in conjunction with uraniu is required to.provioe detaile.d information on the propa ity and its effect on the quality of the environment. General gQ[ cek,or filing an applica-tionisprovidedinS40.31,"ApplicationforSecifY tnses," of 10 CFR Part 40, " Domestic Licensing of Source Materi,al. t n 40.32, " General RequirementsforIssuanceofSpecificLicenfe( ates'that a specific license will be granted if, among other things,' q pmeQt, facilities,andprocedures are adequate to protect health and if mize, danger to life or property and to

. .g protect environmental values. O ne ..o f ~he concerns in uranium solution minina -

,ny s is the potential for contamina ,ing groun water. Therefore, a ground-water monitoring program and ap dria$e umentation of its design, installation, and, implementation are ne d f r in situ solution mining facilities.

This regulatory guice phoVides guidance acceptable to the NRC staf f for l ground-water moni,toring at in situ uranium solution mines.* It provides specific ~~guida6 Din.thefollowingareas:

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1. Preopera lonal, operational, and postoperational surface-water and ground-

. A \; . .

, watery gn. oring locations;

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• Branch Technical Pos,ition,," Groundwater Monitoring at Uranium In Situ Solution Mines," WM-8102, provides.the* basis for this guide. Copies are available on request from Chief,' Uranium Recovery Licensing Branch, Qffice of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission,, Washington, D.C. 20555.

I This regulatory guide and the associated value/ impact statement are being issuer 1 in draft form to involve the pubtlC in the early stages of the development of a regulatory position in this area. They have not received complete sta f f review ar.d do not represent an of ficial NRC staf f position.

Public coments are being solicited on both draf ts, the guide (including any implerentation schedular) and the value/ impact statement. Coments on the value/imoact staternent should be accompanied by support'nq

. data. Coments on both draf ts should be sent toDocketing the Secretary of the Comission U 5. Nuct R and service Branen, n[UC 19 lkh egulatory Comission, wasnington 0.C. 20555, Attention: .

Requests for single copies of draf t guides (which may De reproduced) .or for placement on an automatic rffstribution list for sincie copios mf future draft guides in 58ecific divistuns should be made in

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CERTIFICATE OF SERVICE This is tN. certify that copies of'the foreg'oing OCRE RESPONSE.TO.NRC STAFF'S MOTION,FOR

SUMMARY

DISPOSITION OF ISSUE #13 were served by deposit in,the U.S. Mail, first classt postage rpepaid, this at4*l- day of June, 1983 to those on' the service list below. . <

W W Susan L. Hiatt SERVICE LIST -

Peter B. Bloch, Chairman  !

Atomic Safety & Licensing Board '

Terry Lodge,JEsq.

U.S. Nuclear Regulatory Comm'n .

824 National Bank Bldg.

Washington, D.C. 20555-  ! Tole'do, OH 43604

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Dr. Jerry R. Kline ~

Atomic Safety & Licensing Board .

. U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Mr. Glenn 0. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n g oy

, Washington, D.C. 20555 ,/4

' /

Docketing & Service Section *abf'd' '

Offic'e of the Secretary /2[ '

U.S. Nuclear Regulatory Comm'n 39 1q' l Washington, D.C. ~20555 C3 pS6 ,J2

, o m.e, e~

$s .

3 JamesofM.the Office Cutchin IV Esq.

Exec,utiv,e @4 $.te.t:>c.

495 .Q Legal Director \(y77; l U.S. Nuclear Regulatory Comm'n Jay Silberg, Esq.

1800 M Street, N.W.

Washington, D.C. 20036 .

[ Atomic Safety and Licensing Appeal Board Panel l U.S. Nuclear hegulatory Commission i Washington, D.C. 205S5 l

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