ML20147B928

Affidavit of Hf Conrad.* Discusses Whether Contention I.V Raises Issues That Must Be Resolved Prior to Issuance of Low Power License.Operation of Plant at 5% Power Would Not Change Augmentation.Certificate of Svc Encl

ML20147B928
Person / Time
Site:	Seabrook
Issue date:	01/12/1988
From:	Conrad H Office of Nuclear Reactor Regulation
To:
Shared Package
ML20147B847	List: ML20147B842 ML20147B893 ML20147B911 ML20147B928
References
OL-1, NUDOCS 8801190031
Download: ML20147B928 (12)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )

) Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, g g. ) On-site Emergency Planning

) and Safety Issues (Seahrook Station, Units 1 and 2 )

AFFIDAVIT OF HERBERT F. CONRAD 1, Herbert F. Conrad, being first duly sworn, hereby affirm that the responses to the questions set forth herein are correct to the best of my knowledge and belief:

Q1: Mr. Con rad , by whom and in what capacity are you employed?

A1: I am employed by the United States Nuclear Regulatory Commission.

My present position is Senior Materials Engineer, Material Engineering Branch Office of Nuclear Reactor Regulation, in this capacity I am responsible for technical safety review and evaluation of materials used in the construction of nuclear power plant components. Specially, my responsibilities include the evaluation of materials application, heat treatment, fabrication , inspection and corrosion control.

02: Have you prepared a statement of your professional qualification?

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A2: Yes, a statement of my professional qualifications is attached as an exhibit to this affidavit.

Q3: Mr. Conrad, what is the purpose of your affidavit?

A3: My affidavit addresses the question whether NECNP's Contention I.V raises issues which must be resolved prior to the reauthorization of low power operations at the Seabrook facliity.

04: Mr. Conrad, NECNP Contention i.V states:

The Applicants have not demonstrated that they have met GDC 14,15, 31, and 32 insofar and to the extent that those CDC require a program of in-service inspection of steam generator tubes.

Does Applicants' inservice inspection program of steam generator tubes meet applicable regulatory requirements?

A4: Yes it does. The Staff's position on this issue is reflected in the following sections of NUREG-0896, the Safety Evaluation Report (SER) related to the oparation of the Seabrook Station. That SER states in pertinent part:

5.4.2.2 Steam Generator Tube Inservice Inspection 5.4.2.2.1 Compilance with the Standard Review Plans Seabrook Units 1 and 2 were reviewed in accordance with SRP 5.4.2.2 (NUREG-0800). However, the staff review will continue until the plant Technical Specifications governing steam generato" tube examinations are completed and are in conformance with the applicable standard Technical Specification.

5.4.2.2.2 Evaluation of the Inspection Program

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GDC 32 requires, in part, that RCPB components be designed to permit periodic inspection and testing of important areas and features to assess their structural and leaktight integrity. The design of all pressure-retaining parts of the steam generators at Seabrook Units 1 and 2 has been optionally upgraded to meet the ASME Code requirements for ASME Code Class 1 components. Provisions also have been made to permit inservice inspection of the Class 1 and 2 components, including individual steam generator tubes.

The applicant has committed to following the recommendations of [ Regulatory Guide) 1.83, Revision 1, "inservice Inspection of Pressurized Water Reactor Steam Generator Tubes," and N UREG-0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors," and to complying with the requirements of ASME Code Section X! with respect to the inspection methods to be used. The staff finds this commitment acceptable.

5.4.2.2.3 Conclusions Conformance with RG 1.83, NUREG-0452, and the Inspection requirements of ASME Code Section XI constitutes an acceptable basis for meeting, in part, the requirements of GDC 32.

05: Mr. Conrad, please explain the bases for the Staff's position that compliance with Regulatory Guide 1.83 constitutes an acceptable basis for meeting the requirements of GDC 32.

A5: As stated in Regulatory Guide 1.83, conformance with the provisions of the Regulatory Guide is a method acceptable to the NRC Staff for implementing General Design Criteria 14, 15, 31, and

32. Conformance to Regulatory Guide 1.83 reduces the probability and consequences of steam generator tube failures through periodic inservice inspection for early detection of defects and deterioration.

Part A and B of Regulatory Guide 1.83 fully describe the bases for the Staff's position.

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QG: Mr. Conrad , the - Ginna plant experienced a steam generator tube rupture cespite its licensee's ccmmitment to Regulatory Guide 1.83. What assurance does the Staff have that a similar rupture will not occur at Seabrook?

A6: As described in NUREG-0909, "NP.C Report on the January 25, 1982 Steam Generator Tube Rupture at R.E. Cinna Nuclear Power Plant" ( April 1982), the Ginna tube rupture event was caused by the presence of a foreign object. According to the December 22, 1987 Affidavit of Gregory A. Kann, the Seabrook Station's secondary side steam generator internals were inspected following hot functional testing, assessable areas of the lower tube sheet were inspected, with a miniature camera , and the separator area and related components were inspected. All debris located was removed and material and equipment inventory control was maintained to prevent the introduction of foreign objects into the steam generator. In addition, a loose parts monitoring system is employed to detect loose l

parts during plant operation. In my opinion, these provisions l

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provide reasonable assurance that a rupture caused by a loose part, i

t similar to that experienced at Ginna, will not occur at Scabrook.

l 07: Similarly, Mr. Conrad, what assurance does the Staff have that a rupture similar to the one that occurred at the North Anna plant will not occur at Seabrook?

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A7: The Seabrook plant is not considered to be susceptible to the fluid flow induced vibration fatigue failure mechanism that caused the North Anna steam generator tube rupture because it does not have carbon steel top support plates with drilled holes. As stated in section 5.4.2.1 of NUREC-0896, the Seabrook SER:

Steam Generator Materials:

The tube support will be manufactured from ferritic stainless steel material, which has been shown in laboratory tests to be corrosion resistant to the operating environment. The tube support plates will be designed and manufactured with broached rather than drilled holes. The broached-hole design promotes high-velocity flow along the tube, sweeping impurities away from the support plates locations.

The Staff's present understanding of the failure mechanism at North Anna is that the stresses in the steam generator tubes will not be high enough to cause a fatigue crack failure without the clamping action of the corrosion product buildup in the annalus between a drl!!ed hole in the top support plate and the tube caused by the "denting" process. This is prevented from happening in the Seabrook steam generators in three ways:

1. Highly corrosion-resistant ferritic stainless steel is used instead of susceptible carbon steel for the tube support plate material, thus preventing the formation of the iron oxide corrosion product.

2. An improved support plate design is used. The quatrefoil tube support plate hole design features four lobes and tube support lands. The lands support the tubing and the lobes provide a path for water to flow adjacent to the tubo. The quatrefoil design directs the flow along the tubes in a way that minimizes steam i formation and chemical concentration at tube-to-tube support plate intersections. The quatrefoil support plate results in higher average velocities adjacent to the i tubes than the original lower assembly support plates, l

which feature circulation flow holes between tube holes.

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The quatrefoil support plate minimizes sludge deposition. The combination of high velocities in the support plate region and corrosion resistant material should minimize the potential for tube corrosion in the vicin:ty of the support plates.

3. As stated in NUREG-0896 Supplement No. 5, Safety Evaluation Report related to the operation of Seabrook Station Units 1 and 2, Section 10.3.4, the Seabrook Technical Specifications will contain [Section 6.7.4c] a requirement to implement a secondary water chemistry monitoring and control program that conforms with N U RE G-0800, Standard Review Plan , Section 5.4.2.1.

The impicmentation of a water chemistry program conforming to these guidelines will minimize the possibility of an enviroment in the steam generator that will promote corrosion processes.

08: Mr. Conrad, please descrlhe the role of the Seabrook inservice inspection program of steam generator tubes, if any, in operating the Seabrook Station at five percent (5%) rated power.

A8: The Seabrook Station Technical Specifications require that the first inservice inspection be performed six months after full power operations begin but within 24 months of initial criticality.

Operation of the Seabrook Station at five percent of rated power would not change this requirement in any way. Nor would low power operations make steam generator tubes inspections more difficult to perform or prevent augmented inspections. W!U. re;p::t to assurance of steam generator tube integrity during operation at 5 percent of rated power, the Technical Specification requires that the full length of each tube in each of the four steam generators be l

eddy current inspected from the point of entry on the hot leg side completely around the U-bend to the top support of the cold leg.

This examination provides additional assurance of steam generator t

tube integrity for the Initial period of operation until the first inservice inspection, and establishes a baseline condition of the tubing a0ainst which future inservice inspections can be compared.

in Section 5.2.4.3 the Seabrook SER, the Staff concluded that Applicants' preservice inspection program was acceptable.

Q9: is there any factor which would lead to lesser chance of steam generator tube failure or degradation at 5 percent power than at .'00 percent power?

A9: Yes. The reduced fluid flow at 5 percent power is such a factor , if we consider the Ginna type of occurrence of a loose part in the steam generator, the reduced rate of fluid flow at 5 percent power would greatly reduce the driving force that could be caused by such a postulated loose part and thus reduce the likelihood of steam generator tube failure from such a cause. Even if we consider a North Anna type failure , which as I have stated is virtually impossible at Seabrook, the reduced rate of fluid at 5 percent power would not cause the flow induced vibrations which caused the North Anna tube rupture.

l Q10: Can the Seabrook Station be operated safely at 5 percent rated power in the absence of an adequate steam generator tut 4 inservice inspection program?

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8-I r A10: Yes. As _ stated in my response to the previous question, operation of Seabrook Station at 5 percent of rated power would not change or prevent augmentation (if it should be deemed desirable) of the planned steam generator tube inservice inspection p rog ra m.

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Mr. Conrad, does this complete yo. r affidavit?

Q11:

All: Yes it does.

3!"tk37 f 1we,.

lierbert F. C~onrad f Sworn to and subcribed befor me p 2th day of January 1987:

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U.S. NUCLEAR REGULATORY COMMISSION HERBERT F. CONRAD PROFESSIONAL QUALIFICATIONS My present position is Senior Materials Engineer, Material Engineering Branch Office of Nuclear Reactor Regulation. In this capacity I am responsible for technical safety review and evaluation of materials used in the construction of nuclear power plant components.

Specially, the responsibilities include evaluation of materials application, heat treatment, fabrication, inspection and corrosion control. I am a former member of the American Society of Mechanical Engineers Nuclear Code Committee Subgroup on Fabrication and Examination (Section lil).

I hold a M.S. In Metallurgy (1959) and a B.S. In Mechanical Engineering (1957) from the Massachusetts institute of Technology. I am registered by the State of California as a Professional Engineer in Mechanical Engineering and in metallurgical Engineering with more than 28 years of professional experience. I am a member of the American Society for Metals ( ASM). I have several publications in metallurgy, the most recent is a contribution to the ASM Metals Handbook, Volume 10, Failure Analysis ( ASM,1975).

I have been with the Nuclear Regulatory Commission since February 1973, two years of which were as a loan employee on detall from the University of California. Prior to my assignment to Washington, I was

,cmployed by the Lawrence Livermore Laboratory of the University of California as a Metallurgist.

DOLMETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '88 JM 14 P3 :56 BEFORE THE ATOMIC SAFETY AND LICENSING B00CRD5rdQN.0FFIcy ')'y

. o URANCH In the Matter of )

) Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, g al. ) On-site Emergency Planning

) and Safety issues (Seabrook Station, Units 1 and 2 )

CERTIFICATE OF SERVICE I hereby certify that copies of "NPC STAFF RESPONSE TO LICENSING BOARD ORDER OF NOVEMBER 27, 1987" in the above-captioned proceeding have been served on the following by deposit in the United States mall, first class, or as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by double asterisk, by hand delivery, or as indicated by triple asterisk, by express mail, this 12th day of January 1988.

Sheldon J. Wclfe, Esq. , Chairman

• Atomic Safety and Licensing Administrative Judge B oa rd

• Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 l Dr. Jerry Harbour Docketing and Service Section*

l Administrative Judge Office of the Secretary Atomic Safety ano Licensing Board U.S. Nuclear Regulatory Commission i U.S. Nuclear Regulatory Commission Washington, DC 20555 l Washington, DC 20555 l Dr. Emmeth A. Luebke Thomas G. Dignan, Jr. , Esq.***

l Administrative Judge Robert K. Gad,111, Esq.

l 5500 Friendship Boulevard Ropes s Gray l Apartment 1923N 225 Franklin Street l

Chevy Chase, Maryland 20815 Boston, MA 02110 Atomic Safety and Licensing H. J. Flynn, Esq.

l Appeal Panel

• Assistant General Counsel U.S, Nuclear Regulatory Commission Federal Emergency Management Agency Washington, DC 20555 500 C Street, SW Washington, DC 20472 l

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o Philip Ahren, Esq. Calvin A. Canney Assistant Attorney General City Hall Office of the Attorney General 126 Daniel Street State House Station Portsmouth, NH 03801 Augusta, ME 04333 Mr. Angle Machiros, Chairman Carol S. Sneider, Esq. Board of Selectmen Assistant Attorney General 25 High Road Gffice of the Attorney General Newbury, MA 09150 One Ashburton Place,19th Floor Doston, MA 02108 George Dana Bisbee, Esq. Allen Lampert Assistant Attorney General Civil l'.efense Director Office of the Attorney General Town of Brentwood 25 Capito! Street 20 Franklin Concord, NH 03301 Exeter, NH 03833 Ellyn R. Weiss, Esq.** William Armstrong Diane Curran, Esq. Civil Defense Director Harmon & Weiss Town oF Exeter 2001 S Street, NW 10 Front Street Suite 430 Exeter, NH 03833 Y!ashington, DC 20009 Robert A. Backus, Esq. Gary V/. Holmes, Esq.

Backus, Meyer & Solomon Holmes & Ellis 11G l.owell Street 47 Winnacunnet Road Manchester, NH 03106 Hampton, NH 03842 Paul McEachern, Esq. J. P. Nadeau Matthew T. Brock, Esq. Board of Selectmen Shaines & McEachern 10 Central Street 25 Maplewood Avenue Rye, NH 03870 P.O. Box 360 Portsmouth, NH 03801 Judith H. Mizner, Esq.

Charles P. Graham, Esq. Silverglate, Gertner, Baker, McKay, Murphy & Graham Fine & Good 100 Main Street 88 Board Street Amesbury, MA 01913 Boston, MA 02110 Sandra Gavutis, Chairman Robert Carrigg, Chairman Board of Selectmen Board of Selectmen RFD #1, Box 1154 Town Office Kensington, NH 03827 Atlantic Avenue North Hampton, NH 03870

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t William S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall Town Hall - Friend Street Newburyport, MN 09150 Amesbury, MA 01913 Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 Hon. Gordon J. Humphrey United States Senate 531 Hart Senate Office Building Washington, DC 20510 J A

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2Vrry Couns r C Staff l

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