ML20070U114

Answer Supporting NRC 830114 Motion for Summary Disposition of Issue 9 Re radiation-induced Degradation of Polymers.Nrc Final Rule on Environ Qualification of Electrical Equipment Compliance Schedules Remove Issue as Matter of Controversy

ML20070U114
Person / Time
Site:	Perry
Issue date:	02/08/1983
From:	Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20070U116	List: ML20070U114 ML20070U122 ML20070U131
References
NUDOCS 8302100202
Download: ML20070U114 (4)

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• DOCKETED U9RC February 8, 1983

,83 FFP -9 P!?:59 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC )

ILLdMINATING COMPANY,-ET AL. ) Docket Nos. 50-440

) 50-441 (Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANT 3' ANSWER IN SUPPORT OF NRC STAFF MOTION FOR

SUMMARY

DISPOSITION OF ISSUE h0. 9 On January 14, 1983, the NRC Staff (" Staff") filed a Motion for Smmmary Disposition of Issue #9. Issue No. 9 concerns radiation induced degradation of polymers, in particular those used as electrical cable insulation, at Perry Nuclear Power Plant ("PNPP").

The Staff in its motion points out that, under the Nuclear Regulatory Commiscion's recently promulgated final rule on environmental qualification of electrical equipment, 48 Fed. Reg. 2729 (January 21, 1983), the earliest deadline by which environ-mental qualification of safety related electrical equipment must be completed is March 31, 1985, a deadline which may be extended under procedures established by the rule itself. 10 C.F.R. 550.49 (g). Thus, Commission rules do not now require the type of demonstration which the contention would have the Licensing l

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c r Board require. The Staff further points out that Intervenor Ohio Citizens for Responsible Energy ("OCRE") has failed to provide the greater specificity required by the Licensing Board regarding OCRE's basis for believing particular electrical equipment or components, such as cables, co be potentially dangerous. The Staff's motion and accompanying affidavit also observe that the new final rule expressly permits accelerated age testing of equipment, thus preempting OCRE's concern with the validity of such testing. 48 Fed. Reg. at 2733. Finally, the Staff states that it will verify Applicants' commitment to implement appropriate surveillance and maintenance procedures capable of assuring thot any polymer degradation in safety related electrical equipment will not cause unsafe conditions to occur.

Applicants support the Staff's motion for summary disposition of Issue No. 9. Applicants agree that the compliance schedules established by the new rule have in effect removed the issue as a matter in controversy. Applicants also agree that the new rule explicitly permits accelerated aging. Applicants further agree that OCRE has failed to specify the basis for its contention as applied to particular equipment or components. For any or all of these reasons, the Staff's motion for summary disposition could be granted.

Independent of these grounds, the Staff's motion for summary

, disposition of Issue No. 9 should also be granted on the merits.

I

O '

As discussed in the Affidavit of Srinivasan Kasturi in Support of NRC Staff Motion for Summary Disposition of Issue No. 9

("Fasturi Affidavit") and the Affidavit of David R. Green in Support of NRC Staff Motion for Summary Disposition of Issue No. 9

(" Green Affidavit"), attached hereto, there is no reasonable basis to believe that radiation dose-rate effects on polymers at PNPP will cause unsafe conditions to occur.

First, the Kasturi Affidavit shows that no significant dose-rate effects occur (even for those few polymers where dose-rate effects have been suggested at all) until the polymer has i

accumulated a total integrated dose of one million to ten million rads. The Affidavit goes on to demonstrate that the integrated dose for 40 years of normal operation of almost all the equipment at Perry is at least one to three orders of magnitude below this threshold dose. There is also a threshold radiation dose necessary for polymer degradation to occur.

Second, the Sandia National Laboratory studies. relied upon by OCRE are of limited, if any, relevance to Perry. The dose rates considered by Sandia were generally far above those at Perry. So were the cumulative doses. The properties measured in the Sandia tests were not those relevant to the function of the material studied (i.e., electrical properties of cable insulation were not measured).

Third, a survey of five operating plants, with a total of 53 reactor years' experience, disclosed no evidence of polymer degradation due to dose-rate effects. Essentially the same

polymeric materials used at Perry were found in radiation zones similar to those at Perry. Yet no degradation due to radiation exposure was found.

Finally, as shown by the Green Affidavit, Perry will have a surveillance and maintenance program that will provide assurance that radiation degradation of polymers in safety related equipment will either be prevented, or discovered and corrected, before it can cause unsafe conditions to exist.

In conclusion, there is no genuine issue of material fact to be heard with respect to polymer degradation from dose-rate effects in safety related equipment at PNPP. The Staff's motion for summary disposition of Issue No. 9 sho.1d be granted.

Respectfully submitted, SHAW, PITTMAN, POTTS & TRONBRIDGE By: Af /

Jay Silbeig~, P.C. '"

Mic a 1IA. Swiger Counse for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: February 8, 1983

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