ML20081C764
| ML20081C764 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/09/1984 |
| From: | Swiger M CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| Shared Package | |
| ML20081C768 | List: |
| References | |
| NUDOCS 8403150009 | |
| Download: ML20081C764 (5) | |
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~nisiED C0anESPONDENCE DOCKETED USNRC March 9, 1984 T4 MR 14 A!0:15 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION: %
1 Before the Atomic Safety and Licensing Board In the Matter of
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THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
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50-441
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(Perry Nuclear Power Plant,
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Units 1 and 2)
APPLICANTS' RESPONSE TO LICENSING BOARD'S MARCH 30, 1983 ORDER CONCERNING
SUMMARY
DISPOSITION OF ISSUE NO. 9 In its Memorandum and Order (Polymer Degradation:
Summary Disposition), LBP-83-18, 17 N.R.C. 501 (1983), the Licensing Board granted partial summary disposition of Issue No. 9, con-cerning polymer degradation in safety-related equipment caused by radiation dose-rate effects.
In that Memorandum and Order, the Licensing Board also admitted a genuine issue of fact con-cerning the adequacy of Applicants' inspection and anaintenance program to detect polymer degradation.
The Licensing Board established two conditions to its grant of partial summary disposition.
The first condition was that Applicants and the NRC Staff file a stipulation committing Applicants to completing their environmental qualification 9403150009 840309 PDR ADOCK 05000440 G
PDR TSO3
e program for electrical equipment by November 30, 1985.
17 N.R.C. at 507.
The second condition was that Applicants file an affidavit
" stating hat none of the Ferry electrical equipment located in zone CT-5 will employ polymers that have less than a 100% safe-ty margin except for specific equipment for which applicant discloses their safety margin and the polymer involved."
Id.
at 508.1/ The Licensing Board required the affidavit to sup-port its conclusion that polymer degradation would not create unsafe conditions in the interim period between the then planned Perry Nuclear Power Plant ("PNPP") Unit 1 fuel load date of December 19842/ and November 30, 1985.
See id. at 508.
On Applicants' motion for reconsideration and clarifica-tion, dated April 14, 1983, the Licensing Board during the May 9,
1983 telephonc conference call reconsidered the previously 1/
The assumption that 100 percent safety margins are built into safety-related electrical equipment at PNPP exposed to high levels of radiation was based on the statement contained in the Affidavit of Srinivssan Kasturi in Support of NRC Staff Motion for Summary Disposition of Issue No. 9, dated February 4,
1983, at 5 8, that " good engineering practice allows for a 100% safety margin in equipment design."
See id.
2/
As Applicants advised the Licensing Board by letter of February 24, 1984, completion of Unit 1 is now estimated for late 1985.
Thus, the interim ~~.iod between fuel load of Unit 1 and the completion of Appi cants' environmental qualification program for electrical equipment will be substantially shorter than the 11 months originally contemplated.
However, the atta-ched Affidavit of Srinivasan Kasturi shows that Applicants far exceed the Licensing Board's 100 percent safety margin require-ment even for the original 11 month interim period.
0 admitted issue of fact concerning Applicants' inspection and maintenance program and summarily disposed of the polymer deg-radation issue in full.
Tr. at 827-28.
The Licensing Board conditioned summary disposition on the submittal by Applicants of an affidavit stating the tests for polymer degradation in electrical cable insulation which Applicants plan to include in the surveillance and maintenance program for PNPP and an expert opinion that those tests are adequate to detect embrittlement.
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Id. at 828.
Applicants have submitted the required affidavits.
See Applicants' Response to Licensing Board's May 9, 1983 Order Concerning Issue No. 9, dated August 4, 1983, and attached af-fidavits of David R. Green and Srinivasan Kasturi.
The Licens-ing Board also accepted Applicants' brief on the motion as a fulfillment of itc condition concerning scheduling of Appli-cants' equipment qualification program for electrical equip-ment.
Id. at 827.
l During the May 9, 1983 telephone conference call, the Li-censing Board ccnfirmed that its summary disposition of Issue No. 9 did not affect its requirement for an affidavit address-ing safety margins in electrical equipment.
Tr. at 878-79.
Applicants hereby submit the attached Affidavit of Srinivasan Kasturi in Response to Licensing Board's March 30, 1983 Order Concerning Issue No. 9 ("Kasturi Affidavit").
La stated in the Kasturi Affidavit at 1 6, the application of each of the
l polymers in Zone DW-2, the radiation zone with the highest dose rate at PNPP,3/ provides a margin of safety well above 100 per-cent for the interim period prior to the completion of environ-mental qualification of electrical equipment.
The electrical cable and cable splice insulation located in Zone DW-2 have 100 percent safety margins based on an installed life of almost nine years of full power operation.
Id. at 1 5.
The limiting polymer materials in the solenoid valves, the other electrical equipment containing polymers in Zone'DW-2, have safety margins of 344 percent based on an installed life of 40 years of full power operation.
Id.
In conclusion, the Kasturi Affidavit shows that the elec-trical equipment located in Zone DW-2 is designed to provide more than sufficient margins of safety to assure that 1
3/
The Licensing Board's requirement that Applicants address the equipment located in Zone CT-5 was based on Table 3 of the February 4, 1983 Kasturi Affidavit, which shows Zone CT-5 as having the highest gamma radiation dose rate during normal full power operation (357 rads /hr).
However, as stated in the Affi-davit of David R. Green in Response to Licensing Board's May 9, 1983 Order Concerning Issue No.
9, dated August 3, 1983, at 2 n.1, it was later discovered that no polymers in Zone CT-5 will be exposed to that dose rate.
The normal full power dose rate for polymers in Zone CT-5 will be 100 rads /hr. Zone DW-2 will have a normal full power dose rate cf 160 rads /hr.
Id. at 2.
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any radiation dose-rate offects on polymers at PNPF during the interim period will not cause unsafe conditions to occur.
Respectfully submitted, SHAW, PITTMAN, POTTS G.TROWBRIDGE By:
%,'thec/ O. dd W JAY E.
- SILBERG, P.C.
MICHAEL A.
SWIGER Counsel for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
March 9, 1984 1
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