ML20100G699
| ML20100G699 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/05/1984 |
| From: | Range J LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-473 OL, NUDOCS 8412070351 | |
| Download: ML20100G699 (13) | |
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,@}1ATED CORRESPON0 LILCO,sDecember.5, 19
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0FICE C~ SECRETARY
.Before the Atomic Safety and Licensi'$nc ? Board.G a sEav:ct; edACH In the Matter.of
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LONG ISLAND LIGHTING COMPANY
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DocEEE'So*IS0 322 '(OL)
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(Shoreham' Nuclear Power Station,
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Unit 1)
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LILCO'S RESPONSE TO SUFFOLK COUNTY'S MOTION TO COMPEL LILCO objects to performing an x-ray crystallographic ex-amination on the surface.of the cam gallery crack on the grounds that (i) the test is unnecessary, (ii) there is no assurance that the test will narrow the issues in dispute be-cause substantial uncertainty exists concerning whether it will yield re-liable quantitative results, and (iii) the County's Motion is untimely.
In the event, however, that the Board orders the test, LILCO believes that the potential for narrowing the issues can be maximized by requiring the test procedures outlined in this Re-sponse.
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The Test Is Unnecessary
'Both'LILCO and the NRC Staff testified that x-ray crys-tallographic examination of the fracture surface is unneces-sary.
(Tr. 26531-32).
LILCO has, in its view,. carried its burden of proof and established that the cam gallery cracks are casting induced based on the color and thickness of the o.xide layer and the lack of an oxide layer of comparable thickness on the weld shrinkage cracks.
FaAA testified that the crack could not have been formed during operation since the oxide is much thicker on the casting shrinkage crack below the weld shrinkage crack.
Had the crack been operationally induced, both the crack surface beneath and the weld shrinkage crack surface would have been similarly oxidized.
(E.o., Tr. 26469-70, 26498).
The observation of no operationally induced crack propa-gation is consistent with the prediction of no crack growth based on hand calculations and strain gage test results.
These results show that the vertical stresses in the cam gallery area
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are fully compressive.
Accordingly, additional testing of the cam galleries to verify that the cracks are non-propagating and fabrication rather than operationally induced is unnecessary.
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No Assurance Of Reliable Results Or-Narrowino Of Issues LILCO believea that precise' quantitative interpretation
- ofix-ray analysis of the crack surface with oxides formed over a range of temperatures-is difficult and indeed may not.be pos-
-sible.-- 'FaAA's-previous experience with attempts at such analy-
- ses by. independent laboratories confirms this.- Moreover,-FaAA'
'has contacted a number of laboratories which perform x-ray crystallography, including McCrone Associates, Inc. and Camet,
,Inc., regarding this specific analysis.
Comments received from' these' laboratories have further confirmed LILCO's concern that.
x-ray-analysis may not produce.quantifiable, reproducible re-sults.
Rather, the results mayLwell be ambiguous or conflict-
.ing, and thus not dispositive of the issue.
Indeed, such re-sults may lead to more litigation rather than less.
i Dr. Robert Muggli, who is in charge of the x-ray analysis I
department at McCrone, advised that he could not be sure he could obtain any results at all, or that results he did obtain vauld be quantifiable.
Dr. Muggli indicated that he would have to perform an x-ray scan of the crack surface in order to de-termine whether it was possible to obtain any meaningful re-sults.
Further, Dr. Muggli indicated that if the initial test indicated that the oxides were non-stoichiometric (i.e., not of i
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.one" precise chemicalfor crystallographic form), the analysis of the oxide would require; additional testing with uncertain prospe' cts forLobtaining.quantifiable1results.
In LILCO's view, these problems,l combined with the absence of any necessity for performing-the test and the County's untimeliness, dictate that
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the test should not be performed.
C.-
The Motion Is Untimely The County received.LILCO's. Supplemental Testimony on the cam gallery cracks on September 20.and knew at that time that LILCO contended the oxide layer on the fracture surface oc-curred during the fabrication process.
In September, the Coun-ty also examined all of LILCO's photographs and documentati,on on the cracks, and examined the actual crack samples.
At no time during this discovery period did the County seek to per-form any. test on the samples.
Indeed, the County apparently did not consider that an x-ray crystallography test was neces-sary or desirable until substantially all of the testimony on u
the blocks was completed.
The County's long delay in seeking the test. reflects that it is not of vital decisional impor-tance.
Moreover, the delay suggests that the County's-interest in the test arose only after the County had an opportunity to evaluate the course of litigation.
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' Protocol'Recuired If Test Ordered If'the Board orders the' test,.it'should also order the
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following procedure-for conducting'the test.in order to maxi-mize the potential for meaningful results.1/
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'(1)- fro verify. that the test results are capable of cre-pr6 duction, LILCO may elect to have the test performed by a
- second independent laboratory.
LILCO has determined that
- Camet, Inc., a Santa Monica, California. laboratory, is quali-
-fied to perform x-ray crystallography.
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To allow for independent verification of results ob-tained by McCrone, LILCO will retain custody of the' specimen and take it to McCrone for the test to be conducted at the County's expense.
If inoependent verification is required,
.LILCO.will take the specimen to Camet for the test to be per-formed at LILCO's expense.
All parties will be permitted to observe the tests at both laboratbries.
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-1/. Although the County has requested that x-ray crys-tallography be performed on the specimen, LILCO does not neces-sarily cor. cede that x-ray crystallography is the only or even the most appropriate technique for performing a quantitative analysis of the oxides on the crack surface.
LILCO reserves the right to utilize other, techniques to evaluate ambiguities that x-ray testing may generate.
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y (3). 'Since:neither McCrone nor Camet can assure that the' x-ray: crystallography will provide teaningful results,
. nondestructive testing and data reduction will be performed in
'two phases.' In phase one, the crack surface will first be cleaned with acetone and acetate replicas.2/
Next,'the left and right sides'of the fracture surface in comparable locations will be interrogated by;the x-ray.
Only the nondestructive t'echnique of back: reflection from the fra.:ture surface will be utilized during the.x-ray crystallography tests.
No physical-grinding, chemical treatment, removal of the oxide from the crack surface, or other destructive testing will be permitted since this has the potential of changing the oxide form,-dis-
'torting the test results, and preventing independent duplica-tion of~the oxide analysis by x-ray test.or other test method.
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Furthermore, if interrogation with the x-ray back reflect.on technique does not produce meaningful, interpretable results, no further testing should be conducted.
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(4)
After the first portion of the test described above
'is comple ed, the data vill be examined to determine whether l
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Cleaning is necessary to remove any oxides that might have formed on the fracture surface recently.
Dr. Anderson has testified that such oxides might prevent the x-ray from reliably determining the original structure of the oxides on i
the fracture surface.
(Tr. 26474).
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the~ oxides are-stoichiometric and whether well-defined intensi-ty peak' spectra-appear in accepted patterns and_ positions. -If the-data indicates clearly defined x-ray peaks, then-readily available' oxide reference spectra, such as those published by the International Center for~ Diffraction on' Data, will be used to define all the chemical compounds present and to provide a baseline for subsequent quantitative analyses.
(5)
However, if the x-ray peaks are irregular, i ll-defined, or complex (i.e., the'x-ray peak ~ pattern contain ex-
. traneous peaks and/or relative peak magnitudes which are not clearly associated with defined oxides), then a second phase of testing'should be initiated.
For phase two of the test, the d
- standards for analyzing the x-ray spectra will be based on fracture surfaces of the original EDG 103 block that have been oxidized under controlled conditions.2/
The laboratories'will fabricate these standards by creating fresh fracture surfaces by breaking three pieces of the original EDG 103.provided by f
FaAA.
Then, under controlled temperature, time and 3/
LILCO disagrees with the County's suggestion that classi-cal.x-ray spectra found in the catalog published by the Inter-national Center for Diffraction on Data are accurate and reli-4 able for the purpose of analyzing complex mixtures of oxides on this crack surface.
This is because the oxide in contention is thin and the crack surface is irregular.
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.. environmental' conditions,-the laboratories.will produce a sepa-rate wustite, magnetite and hematite standard on the' fracture surface by holding the samples in a. furnace at the appropriate-temperatures necessary to_ create the' relevant oxides in a thickness of.2'to.5 mils.
The standards created from the new
-pieces-of'the original.EDG 103 block will then be tested using the same x-ray protocol.
These results_will be compared to the results generated from the cam gallery fracture surface to es-tablish which oxides are present on the fracture surface.
-(6) _All parties will be provided with the test results, including raw diffractometer data that shows the entire spec-tral plot of x-ray intensity at each angle, and copies of all references used to reduce the data.
(7)
In order for the test results to be meaningful in narrowing the issues in contention, it is critical that the evaluation criteria be established in advance.
Therefore, based on Dr. Anderson's testimony,i/ the laboratories will re-port their conclusions using the following criteria:
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Dr.-Anderson testified that if 10-15% of the oxides on the fracture surface were wustite or magnetite, that would mean the crack formed during the casting process.
(Tr. 26862).
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-(a)
The x-ray crystallography has de-
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tected, to a reasonable degree.of en-gineering certainty, the presence of high temperature wustite and/or mag-netite oxides in concentrations of 10% or greater.
(b)
The x-ray crystallography has de-tected, to a reasonable degree of en-gineering certainty, the presence of high temperature wustite or magnetite oxides, but-it cannot quantify the concentrations of these oxides.
(c)
The x-ray crystallography has de-tected, to a reasonable degree of en-gineering certainty, that there are no high temperature wustite or magne-tite oxides.
(d)
The x-ray crystallography cannot de-termine, to a reasonable degree of engineering certainty, the form or quantity of the oxides present on the fracture surface.
With respect to the results of the test, if ordered, the County has indicated that it would not contend that the blocks are unqualified on the basis of cam gallery cracks if the re-sults show the presence of high temperature oxides in concen-trations in excess of 15%.
This is certainly warranted, but it does not go far enough.
First, the correct concentration fig-ures, based on Dr. Anderson's testimony, are 10-15%, not 15%.
(Tr. 26862).
Second, a finding of wustite and magnetite in concentrations greater than 10-15% should eliminate any request that LILCO monitor the cam gallery with wire gages or strain
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. gages.
The estensible basis for requesting such monitoring was some residual ~ uncertainty concerning whether the cam gallery
. cracks were process or operational cracks and whether such
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cracks would propagate during operation.
Even if such doubts are. warranted, and the record shows they are not, x-ray test results showing magnetite and wustite in concentrations greater than 10-15% removes all such doubts and renders the monitoring unnecessary and unwarranted.
Adequate assurance concerning the cracks can be obtained by depth gauge measurements taken at the first refueling outage.
Conclusion For the reasons stated herein, LILCO respectfully submits that the County's request to conduct an x-ray crystallography test be denied on the grounds that it is unnecessary and un-timely and on the ground that there is no assurance that it will lead to a narrowing of the issue in litigation.
Should the Board order the test, however, LILCO also respectfully re-quests that the Board order the test protocol and acceptance criteria set forth in this Resporse.
1 Respectfully submitted, LONG ISLAND LI ING COMPANY P
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l W. Taylor Reveley, III T. S. Ellis, III Anthony.F. Earley, Jr.
Hunton & Williams P. O. Box'1535 Richmond, Virginia.23212 John Jay Range Hunton & Williams P. O.-Box 19230 Washington, D.C.
20036 Odes L. Stroup, Jr.
David Dreifus.
Hunton & Williams P. O. Box 109 Raleigh, North Carolina 27602 DATED: ' December 5, 1984 i
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CCCKETED USNRC '
'84 DEC -5 P4 :57 CERTIFICATE OF SERVICE
'0FFICE OF SECadiAM" In the Matter of 00CKETihG & SERVICI.
BRANCH LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station,. Unit 1)
Docket No. 50-322 (OL)
I hereby certify that copies of LILCO's. Response..tos Suffolk County's Motion to Compel were served this date upon the following by first-class mail, postage prepaid, or by hand as indicated by an asterisk:
Lawrence Brenner, Esq.*
Secretary of the Commission
- Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing
. Washington, D.C.
20555 Board-Panel U.S. Nuclear Regulatory Commiss' ion Atomic Safety and Licensing 4350 East-West Highway Appeal Board Panel Fourth Floor (North Tower)
U.S. Nuclear Regulatory.
Bethesda, Maryland 20814 Commission Washington, D.C.
20555 Dr. Peter A. Morris
- Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 4350 East-West Highway Fourth Floor (North Tower)
Robert E. Smith, Esq.
Bethesda, Maryland 20814 Guggenheimer & Untermyer 80 Pine Street Dr. George A.
Ferguson*
New York, New York 10005 Administrative Judge School of Engineering Herbert H.
Brown, Esq.*
Howard University Lawrence Coe Lanpher, Esq.
Room 1114 Alan R. Dynner, Esq.
2300 - 6th Street, N.W.
Joseph J. Brigati, Esq.
Washington, D.C.
20059 Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.
8th Floor Washington, D.C.
20036
3 1
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, Bernard M.
Bordenick, Esq.*
Stephen B.
Latham, Esq.
David A..Repka, Esq.
Twomey, Latham & Shea Richard J. Goddard, Esq.
33 West Second Street U.S. Nuclear Regulatory Post Office Box 398 Commission Riverhead, New York 11901 Maryland National Bank Bldg.-
7735 Old Georgetown Road Ralph Shapiro, Esq.
Bethesda, Maryland 20814 Cammer and Shapiro, P.C.
9 East 40th' Street Martin Bradley Ashare, Esq.
New York, New York 10016 Attn: Patricia A. Dempsey, Esq.
County Attorney James Dougherty, Esq.
Suffolk County Department
- 3045 Porter Street of Law Washington, D.C.
20008 Veterans Memorial Highway Hauppauge, New York 11787 Jonathan D.
Feinberg, Esq.
New York State Mr. Marc W. Goldsmith Department of Public Service Energy Research Group Three Empire State Plaza 4001 Totten Pond Road Albany, New York 12223 Waltham, Massachusetts 02154 Howard L.
Blau 4
MHB Technical Associates 217 Newbridge Road 1723 Hamilton Avenue Hicksville, New York 11801 Suite K San Jose, California 95125 Fabian G. Palomino, Esq.
Special Counsel to the Mr. Jay Dunkleberger Governor New York State Energy Office
' Executive Chamber, Room 229 Agency Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223
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fodp dy ang Hunton & Williams k%
2000 Pennsylvania Avenue, N.W.
Suite 9000 Post Office Box 19230 Washington, D.C.
20036 DATED:
December 5, 1984 gr--,
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