ML20106A165
| ML20106A165 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/05/1985 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20106A167 | List: |
| References | |
| CON-#185-492 OL, NUDOCS 8502110060 | |
| Download: ML20106A165 (9) | |
Text
l February 5, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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0 :55 Before the Atomic Safety and Licensing Board In the Matter of
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THE CLEVELAND ELECTRIC Docket Nos. 50-440 ILLUMINATING COMPANY, _E_T _AL.
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50-441 Oc_.
(Perry Nuclear Power Plant,
)
Units 1 and 2)
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APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF ISSUE NO. 15 The Cleveland Electric Illuminating Company ("CEI"),
Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company and The Toledo Edison Company (" Applicants") hereby move the Atomic Safety and Licensing Board,-pursuant to 10 C.F.R. 5 2.749, for summary disposition in Applicants' favor of Issue No. 15, concerning steam erosion.
As discussed herein, there is ru) genuine issue of material fact to be heard with re-spect to Issue No. 15; and Applicants are entitled to a deci-sion in their favor on-this contention as a matter of law.
This motion is supported by:
1.
" Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard on Issue No. 15;"
2.
. " Affidavit of Richard A. Pender," dated February 1, 1985 ("Pender' Affidavit");
3.
" Affidavit of Donald H. Stevens," dated February 1, 1985 ("Stevens Affidavit");
i 8502110060 B60205
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4.
Section II.A of " Applicants' Motion for Summary Disposition of Issue 14" (January 14, 1985) (articulating the legal standards applicable to a motion for summary disposition).
I.
PROCEDURAL BACKGROUND Issue No.15 was-admitted as a contention in this proceed-ing in the Licensing Board's Memorandum and Order (Concerning Ohio Citizens for Responsible Energy's Late-Filed Contentions 21-16), LBP-82-98, 16 N.R.C. 1459 (1982).
Ohio Citizens for Responsible Energy ("OCRE") is the lead intervenor on this issue.
As admitted by the Licensing Board, Issue No. 15 states:
Applicant has not yet demonstrated that it is prepared to prevent, discover, assess and mitigate the effects of steam erosion on components of the Perry Nuclear Power Plant that will be subjected to steam flow.
Id. at 1471.
On November 18, 1982, Applicants filed a motion for di-rected certification to the Atomic Safety and Licensing Appeal Board challenging the admission of this contention.1/ The mo-tion, which was supported by the NRC Staff (" Staff"),2/ was de-nied by the Appeal Board on December 15, 1983 as interlocutory.
Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2), ALAB-706, 16 N.R.C.
1754 (1982).
1/
Motion for Directed Certification of the Licensing Board's Memorandum and Order of October 29, 1982 (November 18, 1982).
8 Motion for 2/
NRC Staff Response in Support of Applicants Directed Certification of the Licensing Board's Memorandum and Order of October 29, 1982 (December 8, 1982). __
5 Discovery'on this issue was conducted from January 1983 to June 1983,-and included:
OCRE's Ninth Set of Interrogatories to the NRC Staff, dated January 31, 1983, to which the Staff
- responded on March 1, 1983; OCRE's Ninth Set of Interrogatories to Applicants, dated January 31, 1983, to which Applicants re-sponded~on March'8, 1983; Applicants' Interrogatories and Re-quest for Production of Documents'to OCRE (Third Set), dated January 31, 1983, ix) which OCRE responded on March 18, 1983; and Applicants' Interrogatories and Request for Production of Documents to OCRE (Fourth Set), dated April 8, 1983, to which OCRE responded on June 1, 1983.3/
In addition, Applicants filed supplementary answers tx) OCRE interrogatories on
['
' September 23, 1983, February 29, 1984, and November 1, 1984.4/
II.
ARGUMEKT A.
Standards for Summary Disposition 1Nie general standards by which motions for summary dispo-sition are judged are set forth in Section II.A of Applicants' 3/
On, November 16, 1983, OCRE filed a motion to reopen dis-covery on four, issues, including Issue No. 15.
That motion was denied in the Licensing Board's Memorandum and Ordet (OCRE Mo-tion.to' Reopen' Discovery),~ dated December 20, 1983, without prejudice to OCRE's filing late discovery requests subject to
. good cause. OCRE has filed no subsequent discovery requests on Issue No. 13.
4/
Letter'from Michael A. Swiger to Susan L. Hiatt (September 23,.1983); Applicants' Supplemental Answers to Interrogatories on Issue Nos. 6, 8 and 15 (February 29, 1984); Letter.from Michael A. Swiger to' Susan L. Hiatt (November 1, 1984).
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Motion for-Summary Disposition of Issue 14, dated January 14, m
1985, which is incorporated herein by reference.
B.
There is No Genuine Issue of Material Fact With Respect to Issue No. 15 Issue'No. 15' contends that Applicants have not addressed the effects of steam erosion at the Perry Nuclear. Power Plant
.("PNPP").
As discussed in the Pender Affidavit and Stevens Af-fidavit, attached hereto, Applicants have addressed the poten-tial effects-of steam erosion; and there is no reasonable basis to believe'that steam erosion at PNPP, if it occurs,' will af-fect the health or safety of the public.
OCRE's contention is based on two NRC Information Notices.
'IIL Information Notice No. 82-22 (July 9, 1982) described fail-ures at several-nuclear plants in steam and steam line drain piping which apparently-resulted-from steam erosion., IE Infor-4 mation Notice No. 82-23-(July.16, 1982) reported excessive leakage rates during testing-of Main Steam Isolation valves
("MISVs") at a number of plants.
A few of these failures were attributed to steam erosion.5/
- 5/
In its original contention, OCRE further noted that Appli-cants at that time had not yet submitted their inservice testing ~ program for pumps and valves for the Staff's review, as L
_ reflected in Section 3.9.6 of the PNPP SER.
Ohio Citizens.for-Responsible Energy Motion'for Leave to File its Contentions 21 through 26, dated August.18, 1982, at 5.
OCRE offered no basis for believing pumps =are subject to steam erosion; neither'was any such basis identified in the course of discovery.
The only relevant valves were MSIVs; however, as discussed below, the Pender Affidavit demonstrates that nteam erosion is not-a contributing factor to MSIV leakage.
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d 4
Applicants have long been aware of the potential for steam erosion in certain piping systems.
Pender Affidavit at 1 3.
Steam-erosion in-steam and steam line drain piping systems is the degradation of piping due either to the high velocity im-pingement of condensed steam droplets on the piping (erosion-corrosion), or the repeated growth and collapse of steam bubbles in the process fluid (flashing fluid erosion).
4 Id. at 11 7-8.
The erosion-corrosion type of steam erosion oc-
- curs only.in steam piping systems with certain combinations of low quality steam, low temperatures (within a narrow range),
and.high-velocities.
Id. at 11 9-14, 22.
Flashing fluid ero-sion normally occurs downstream of control valves in steam line drain systems, where pressure in the system is usually below the saturation pressure.
Id. at 1 16.
Because steam erosion is a relatively slow process, continuous flow for substantial
?
periods of time is considered a minimum condition of steam ero-
- sion.-
Id. at 1 22.
Based on industry experience, as well as CEI's experience with fossil fueled plants, Applicants implemented certain de-sign features in the PNPP steam line drain systems to mitigate the effects of steam erosion.
Id. at 1 18.
These design fea-tures were incorporated well before OCRE's raising of its steam
- erosion contention.
Id. at 1 4.
The design features included using pipe tees with stainless steel target plates and tell tale valves (instead of pipe elbows) at directional changes downstream of control valves, where steam erosion is most l
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likely to occur in steam line drain systems.
They also includ-ed replacing piping downstream of control valves with erosion-resistant materials.
Id. at 11 19-21.
In addition, Applicants have performed a comprehensive as-sessment of steam piping systems at PNPP and have identified those systems in which significant steam erosion may occur.
Id. at 11 5, 22-23.
Steam systems potentially subject to sig-nificant steam erosion, along with the steam line drain systems in which special design features were incorporated, will be in-cluded-in a steam erosion inspection program.
Id. at 11 5, 25.
The steam erosion inspection program is based on a prio-ritization of potential inspection locations to assure periodic
. inspection of those locations where steam erosion, should it occur, is likely to be most. severe.
Id. at 1 26.
For the steam-line drain systems (N22, N25 and N26), inspection points are identified downstream of selected control valves.
The in-spections are expected to confirm the effectiveness of the de-sign 1 features incorporated in these systems to mitigate steam erosion.
Id. at 1 27.
Inspection locations for the two steam systems (Nil and N36) are based on predicted erosion-corrosion rates using the Keller Equation.
Id. at 11 29-33.
. Inspection points are selected which represent the worst case locations for steam erosion.
Should inspection indicate significant steam erosion rates at these locations, the inspection loca-Ltions will be expanded,-as appropriate, to ensure maximum [
coverage of susceptible areas of pipe within the system.
Id. at 1 34.
Prior to fuel load, an inspection will be conducted to provide baseline information on actual pipe wall thicknesses.
The-first operational inspection will be conducted within the first three years after plant start-up.
This inspection inter-val will assure that any steam erosion effects are detected be-fore significant degradation can occur.
For subsequent inspec-tions, the inspection interval will be based on the results of the previous inspection.
In no case will an inspection inter-val exceed the expected life of a piping system.
Id. at 11 36-38.
The method used to determine pipe wall thickness for the inspection program is ultrasonic inspection.
Id. at 1 35.
Lo-cations inspected will be considered acceptable if the pipe ex-ceeds its minimum wall thickness and the expected life of the piping is greater than the time until the next scheduled in-spection.- Id. at 1 39.
If necessary, piping will be repaired or replaced to ensure that wall thickness is at least as great as the minimum wall thickness required by the applicable piping code.
Id. at 11 39, 31 at n.5.
Even if a piping failure due to steam-erosion were to occur at PNPP, industry experience has shown that such failures do not pose a threat to niant safety systems or otherwise af-fect the health or safety of the public.
Id. at 1 24.
The.. - -
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I PNPP Steam Erosion Hazards Analysis, described in the Stevens Affidav3t, confirms that steam erosion at PNPP is not a concern with recpect to the public health or safety.
See Stevens Affi-davit at 11 3, 10.
The Steam Erosion Hazards Analysis was an extensive study which evaluated the design of PNPP in order to determine ef-
-fects of postulated piping failures due to steam erosion on the ability of the plant to achieve and maintain safe shutdown. The study reviewed all safety-related systems and components in plant areas containing steam and steam line drain piping'.
Id.
at 11 3-5.
In each area identified, piping failures were pos-tulated which were assumed to prevent the safety-related sys-tems and components within the area from performing their safe-ty functions.
Id. at 1 6.
As a result of,the reviews of individual systems and com-ponents, the Steam Erosion Hazards Analysis determined that in each case, either (1) failure of the item could not prevent safe shutdown or maintenance of safe shutdown at PNPP, or (2) the pipe failure postulated for the item was not a credible event.
Id. at 11 6-8.
The conclusion of the study was that the design of PNPP assures the ability'of the plant to achieve and maintain a safe shutdown condition in the event of any credible failure resulting from the effects of steam erosion.
Id. at 1 3. m
With respect to the MSIVs, a comprehensive study by the BWR Owners Group on MSIV. Leakage has determined that steam ero-sion is not a contributing factor to MSIV leakage.
Pender Af-fidavit at 1 41. This conclusion is consistent with the condi-tions to which the MSIVs will be exposed at PNPP.
Id. at 1 42.
In addition, those portions of the valves which will be sub-jected to steam flow are_overlayed with Stellite, an erosion-resistant material.
Id.
Thus, steam erosion is not e::pected to have any significant effects on the MSIVs.
Id.
III.
Conclusion In conclusion, there is no genuine issue of material fact to be heard with respect to Applicants' ability to prevent, discover, assess and mitigate the potential effects of steam erosion at_PNPP.
Applicants respectfully request that the Li-censing Board grant summary disposition of Issue No. 15 in their favor.
Respectfully submitted, f)
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h,. r E.
Silberg, P.C.'
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a 1 A. Swiger f )
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SHAW, PITTMAN, POTTS & TROWBRIDGE l
1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
February 5, 1985 e